1. Controller
Kaynak UG (haftungsbeschränkt)
Erfweiler Str. 12
66994 Dahn
Germany
Email: support@kaynak.eu
Privacy contact: datenschutz@cliqly.de
2. Scope
This Policy explains how personal data is processed in Cliqly. The EU General Data Protection Regulation (GDPR) applies to people in the EU and EEA. We also account for the Swiss Federal Act on Data Protection (FADP) for people in Switzerland. Any additional mandatory rights under the law applicable at a person’s location remain unaffected.
Cliqly is only intended for adults aged 18 or older.
3. Categories of data
Depending on use, we process:
- account, authentication and session data, including Sign in with Apple,
- profile data such as display name, username, bio, interests, image, role, badges, language and privacy settings,
- follows, follow requests, blocks and invitations,
- event data, including content, categories, location, time, host and participation status,
- Crew memberships, roles, invitations, polls, planning signals and media,
- messages, reactions and replies in authorised event or Crew contexts,
- profile, Crew and event images and event photos,
- ratings, rankings and community signals,
- reports, moderation decisions, warnings and suspensions with required context,
- device, push, error and security data where needed for delivery, stability and abuse prevention,
- location data when a location feature is used and iOS permission has been granted.
4. Purposes and legal bases
We process data to provide accounts and requested features under Article 6(1)(b) GDPR, based on consent under Article 6(1)(a), to comply with legal duties under Article 6(1)(c), and for legitimate interests under Article 6(1)(f), particularly safety, moderation, fraud prevention, service stability, legal defence and product improvement.
Under Swiss law, processing follows the principles of lawfulness, proportionality, purpose limitation, transparency and data security. Consent can be withdrawn at any time with future effect.
5. Location and launch areas
Cliqly launches in Frankfurt with a 17 km radius and Geneva with a 20 km radius. The Geneva launch area may include the Swiss and supported French parts of the cross-border metropolitan region.
Device location is processed only with iOS permission and for location-based features. Cloud-based profile discovery uses only a coarsely rounded location with approximately one-kilometre precision. Precise device location is not persistently stored as the profile location for this purpose.
Event hosts choose between an exact and approximate address. Exact meeting details are disclosed only in line with the access status shown in the app.
6. Visibility inside Cliqly
Profile, event, Crew and network data is displayed only as required by the relevant feature and chosen visibility settings. Private profiles and non-public content are intended only for the authorised audience. Hosts and confirmed participants may see additional event information.
7. Photos and media
Media is processed only when selected or uploaded. iOS photo permissions can be changed at any time. Uploaders and authorised hosts can delete media; other users can report it. Reported media may be preserved until review is complete.
8. Chats and retention
Event chats are restricted to hosts and confirmed participants. Regular event-chat messages are scheduled for deletion 24 hours after the event starts. Crew planning signals are normally deleted after 14 days. Content linked to an open report may be restricted and retained until moderation and applicable appeal periods are complete.
Other data is kept only as long as required for the account, feature, safety purpose, legal obligation or claim. Retention depends on the data category, purpose and any unresolved dispute or report.
9. Moderation and safety
Reports include the reported content, selected reason, technical references and context required for review. Automated filters may block or flag content for human review. Material sanctions can be reviewed. Decision and complaint records are kept only as long as needed for safety, evidence, legal defence and legal obligations.
10. Notifications
Push notifications are sent only after iOS permission. Settings can be changed in Cliqly or iOS. Apple processes a device token for delivery. Notification content is minimised where feasible.
11. Service providers
We use service providers only where needed to operate and secure Cliqly, particularly:
- Apple for Sign in with Apple, CloudKit, Apple Push Notification Service, WeatherKit, MapKit, StoreKit and related iOS services,
- Supabase for selected authentication, role, safety, moderation and server-side backend functions.
We do not sell personal data, share it for third-party advertising or display third-party advertising. Optional subscriptions finance the operation and development of Cliqly.
12. International transfers
Where data is processed outside the EU, EEA or Switzerland, we use legally recognised safeguards where required, such as adequacy decisions or standard contractual clauses, and consider Swiss data-protection requirements.
13. Export and account deletion
Users can request an export and delete their account in the app. Deletion ends the session and initiates deletion or irreversible anonymisation of associated personal data and relationships. A later permitted registration starts a new profile without previous follows or profile data.
Limited exceptions apply where data must be restricted and retained for legal duties, unresolved reports, enforced bans, security evidence or legal claims. A minimal identifier may be retained to prevent evasion of a permanent ban.
14. Automated decisions
Cliqly uses recommendations, rankings and safety filters. It does not make solely automated decisions intended to produce legal or similarly significant effects. Human review of a material moderation decision can be requested at datenschutz@cliqly.de.
15. Your rights
Subject to applicable law, you may have rights to access, correction, deletion, restriction, portability, objection, withdrawal of consent and complaint to a supervisory authority. People in Switzerland may contact the Federal Data Protection and Information Commissioner (FDPIC). People in the EU or EEA may contact the authority at their habitual residence.
Requests can be sent to datenschutz@cliqly.de. We may request proportionate identity verification to prevent unauthorised disclosure.
16. Security
We use appropriate technical and organisational measures, access controls, role checks, transport encryption and data minimisation. No system is entirely risk-free. Incidents are assessed and, where required, reported under applicable law.
17. Changes
We update this Policy when functions, providers or legal requirements materially change. The current version is available in the app and material changes will be communicated appropriately.