Mommy & Mini — Privacy Policy

Last updated: 4 June 2026
Document structure: This document has two parts. Part A is the privacy notice / disclosure (Art. 10 KVKK; informational, no consent required). Part B is the separate Explicit Consent statement for the few processing activities that require it. Per the Turkish DPA guidelines, the privacy notice and explicit consent are kept separate, and consent is not a precondition for using the App.

1. Introduction & Scope

This Privacy Policy explains how personal data of users ("you") of the Mommy & Mini mobile app ("App") is processed under the EU General Data Protection Regulation ("GDPR"), the UK GDPR, and Türkiye's Personal Data Protection Law No. 6698 ("KVKK").

The App is offline-first: your health, menstrual cycle, pregnancy and baby tracking data is stored locally on your device by default. Data is sent to our servers only via the optional "Cloud Backup / Sync" feature that you enable with your explicit consent. Unless you enable it, this data never leaves your device.

2. Data Controller

EntityAD MODERN TANITIM MEDYA ORGANİZASYON LİMİTED ŞİRKETİ
AddressMustafa Kemal Mh. 2155. Cd. No:4/18 Ankara 06530 Türkiye
Emailinfo@app-modern.com
Websitehttps://app-modern.com

3. Personal Data We Process

CategoryDataSource
IdentityDisplay nameYou / Apple-Google sign-in
ContactEmail; phone (only when posting a marketplace listing)You / sign-in provider
Special Category — Health (GDPR Art. 9)Period/cycle, ovulation, pregnancy week, weight, blood pressure, heart rate, medications, mood, baby growth/vaccines/feedingYou
Journal (free-text notes)Your own diary/journal notes; being free text they may contain special-category (health/emotional) content and are protected with the same safeguardsYou
LocationCity (chosen by you; no device location services used)You
PhotosMarketplace listing photosYou
User ContentListing text, user-to-user messagesYou
Security / DiagnosticsCrash logs, performance data, account ID (redacted)Automatic
Advertising (limited)Advertising identifier (IDFA/AAID), ad interaction. Ads are not personalized — the identifier is used only for frequency capping, fraud prevention and aggregate measurementAutomatic
Financial (limited)Pro subscription status/transaction ID. Card/payment details are collected by Apple/Google, never by us.App Store / Play

4. Purposes of Processing

5. Legal Bases (GDPR Art. 6 & 9)

ProcessingLegal Basis
Health data on deviceArt. 9(2)(a) — your explicit consent + provision of the core service
Health data cloud syncArt. 9(2)(a) — separate explicit consent
Journal (free-text) notes processing/syncArt. 9(2)(a) — explicit consent, as they may contain special-category content
Account, authentication, sessionArt. 6(1)(b) — performance of a contract
Marketplace, messaging, moderationArt. 6(1)(b) contract & Art. 6(1)(f) legitimate interests
Crash/diagnostics, securityArt. 6(1)(f) legitimate interests
Non-personalized advertising + limited identifier useArt. 6(1)(f) legitimate interests (no personalization → no consent required)
Legal obligationsArt. 6(1)(c) legal obligation
Where we rely on consent, you may withdraw it at any time in app settings or by contacting us. Withdrawal does not affect processing carried out before withdrawal.

6. Additional Safeguards for Health Data

7. International Transfers (GDPR Chapter V)

ProcessorPurposeData
Supabase (EU / Frankfurt)Cloud database, auth, storage (optional sync)Account, health, content
Google AdMobAd serving/measurementAdvertising ID, usage
Sentry (EU/Germany)Crash/diagnosticsError logs, account ID (redacted)
Apple / GoogleIn-app purchase, notifications (APNs/FCM)Device/subscription tokens

Under GDPR (Chapter V) and Turkey's KVKK (Art. 9, as amended by Law No. 7499 of 2/3/2024), transfers abroad are made on the basis of (i) an adequacy decision, (ii) appropriate safeguards (e.g. Standard Contractual Clauses, binding corporate rules, written undertaking), or (iii) where neither exists, on an occasional basis with your explicit consent after you are informed of the possible risks (KVKK Art. 9(6)(a); GDPR Art. 49).

⚠️ Cross-border transfer risk notice: There is currently no adequacy decision issued by the Turkish DPA for the countries where these providers operate. When transferred abroad, your data may be subject to that country's laws, which may not offer the same level of protection as the KVKK. For this reason, transfer of your special-category health data abroad (Supabase) relies solely on your explicit consent; if you do not consent, your data is not transferred abroad and stays on your device. To strengthen protection, the Supabase and Sentry servers we use are located in the European Union (Germany / Frankfurt) region.

8. Retention

9. Your Rights (GDPR Art. 15–22)

You have the right to access, rectify, erase, restrict and object to processing, data portability, to withdraw consent, not to be subject to solely automated decisions, and to lodge a complaint with a supervisory authority (in Türkiye, the KVKK Board). You can also use the in-app data export and account deletion features.

10. How to Contact / Request

Send requests to info@app-modern.com. We respond within 30 days.

11. Children

The App is intended for users aged 18 and over. We do not knowingly collect data from minors; such data is deleted if identified.

12. Cookies, SDKs & Automatic Collection

We use SDKs for advertising (AdMob), diagnostics (Sentry) and notifications. Ads are not personalized; your advertising identifier is not used for behavioural profiling — only for frequency capping, fraud prevention and aggregate measurement. The App works fully even if you decline the iOS App Tracking Transparency (ATT) prompt.

13. Security (GDPR Art. 32)

We apply TLS-encrypted transport, row-level access control (RLS), authorization, log redaction and regular security reviews. Where required, data breaches are reported to affected users and the relevant authority without undue delay (within 72 hours of becoming aware, per the Turkish DPA's principle decision and GDPR Art. 33).

14. Changes

We may update this policy; significant changes will be notified in the App. The current version is always published at this address.

Part B — Explicit Consent

The following are subject to your explicit consent within the meaning of KVKK Art. 3(1)(a) (specific, informed and freely given). Consent is not a precondition for using the App. You are not required to consent; if you decline, only the related feature is unavailable and core (offline) use is unaffected.

  1. I consent to processing of my special-category health data for cloud backup/sync (Art. 9(2)(a) GDPR / KVKK m.6/3-a) and its transfer abroad via Supabase (EU/Germany; KVKK m.9/6-a), having been informed of the possible risks of cross-border transfer.

No consent is requested for advertising: ads are not personalized and are processed under legitimate interests (Art. 6(1)(f)).

You may withdraw consent at any time in Settings or via info@app-modern.com.