This revision adds detail about Friends events, worldwide search, usernames, ratings and secure redemption of Apple offer codes. It does not change your existing accounts or subscriptions.
1. Controller
Kaynak UG (haftungsbeschränkt)
Erfweiler Str. 12
66994 Dahn
Germany
Email: support@kaynak.eu
Phone: +49 170 5265203
Privacy contact: datenschutz@cliqly.de
VAT identification number: DE464257971
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, the email address Apple provides for Cliqly (which may be a private relay address),
- 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.
The email address Apple provides for Cliqly is processed for sign-in, account association, account security and required service communications. We do not use it for advertising without a separate legal basis.
3.1 Subscription, transaction and entitlement data
When an optional subscription is purchased, restored or managed, we process the following in particular for server-side verification and access control:
- product identifier and the subscription tier derived from it,
- Apple transaction identifier and original transaction identifier,
- a pseudonymous, app-specific account-association identifier (
appAccountToken) derived from the provider identifier verified by Sign in with Apple; it contains no name, email address or payment details, - purchase, expiry, signature and verification timestamps, the verification source (app sync or Apple server notification) and, where applicable, grace-period, refund, revocation, upgrade and renewal status,
- the technical environment (production or test environment),
- the identifier, type and processing result of App Store server notifications and cryptographic hashes of verified signed messages,
- for monthly usage allowances, the relevant event action, a technical operation identifier, calendar month, reservation or completion status, and the subscription tier used for the decision.
The signed JWS supplied by StoreKit or Apple is processed transiently for cryptographic verification. We do not persist the complete JWS; we store only the information required for entitlement, status, duplicate and tampering protection, together with a SHA-256 hash. We do not receive or store full payment-card, bank-account or other payment details; Apple processes those within the App Store.
For offer codes, we also process the offer type and identifier, free-access duration, status confirmed by Apple and secure association with the current Cliqly account. Apple handles code entry and redemption. To establish the association, we may use Apple App Attest to verify that a request comes from a genuine Cliqly installation. This involves an app-specific key identifier, public verification key, replay counter, short-lived challenges, cryptographic hashes of the transaction and device binding, and verification and expiry timestamps. We verify Apple's evidence cryptographically; complete App Attest receipts and raw device identifiers are not persistently stored in our association tables. This serves secure activation and abuse prevention, not cross-device advertising.
3.2 Internal usage and diagnostic data
For internal product, operational and security analytics, we may analyse account-linked activities and product interactions, such as events created or attended, participation status and features used, together with counts of messages and media. We also process technical performance and diagnostic data, such as loading or execution duration, error states and feature reliability. Message and media counts show how many items exist; they are not used to analyse their content for advertising. Content may independently be processed where required for transmission, display, safety, reporting or moderation. We do not build advertising profiles from this data.
3.3 Legal-document and complaint data
To evidence which version was shown before sign-in and which Terms were accepted, we store the applicable document version, language, app version and build, and the timestamps for acknowledging the Privacy Policy and accepting the Terms. Acknowledging that the Privacy Policy was read is not blanket consent to all processing. Consent, for example for optional iOS permissions, is requested separately.
For content notices and appeals, we also process an operation identifier, the type and exact reference of the affected content, reason, explanation, any allegation of illegality and legal reference, processing status, human decisions with reasons, and an appeal where submitted. Authentication identifiers of the reporter or affected person are not disclosed to other users.
The public channel for notices of potentially illegal content can be used without a Cliqly account. Where required by law, we process the reporter's name and email address separately from the moderation view; those details may be omitted only under the narrow statutory exception for notices concerning child sexual abuse offences. To protect this channel against automated abuse, a network identifier and, where supplied, the email address are converted only into separate keyed pseudonyms. These rate-limit pseudonyms are retained no longer than the relevant hourly or daily window plus a short technical buffer, with a maximum of two days, and are not used for advertising or profiling. The access code issued to the reporter remains with that person; the server stores only its SHA-256 hash. Contact and case data are limited to the protected receipt, review and decision process.
3.4 Usernames, Friends access and ratings
To allocate unique usernames, Supabase stores the chosen display name, its lowercase search and allocation key, the protected account association, and technical operation and publication states. This prevents duplicate allocation and unauthorised changes. The internal account link is not published as a search result.
Friends access is stored on the server with the involved accounts, confirmation by both people, status and timestamps. Private Friends event content, participation permissions and protected meeting locations are not added to the publicly readable event list. Blocks and removals are taken into account when checking protected access.
For ratings, we verify and store eligibility based on the past event, confirmed participation, the rating and rated accounts, the rating and technical operation identifiers. Public displays use the intended aggregate community values, not the protected verification records. Profile edits and moderator removal of a picture or bio may pass through these protected server functions to update the CloudKit profile securely.
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.
We process subscription and entitlement data in particular to perform the subscription contract, assign and restore purchased features, calculate usage allowances, and respond to renewals, expiry, grace periods, refunds or revocations under Article 6(1)(b) GDPR. Preventing duplicate processing, unauthorised activation, manipulation and fraud, and maintaining technical traceability serve our legitimate interests in a secure and reliable subscription service under Article 6(1)(f) GDPR. Article 6(1)(c) GDPR applies where retention or evidence is required by law.
We process legal-document records to perform the user contract, evidence compliance and defend legal claims under Article 6(1)(b), (c) and (f) GDPR. We process content notices, moderation decisions and appeals to comply with legal obligations, including the Digital Services Act where applicable, and for community safety and legal defence under Article 6(1)(c) and (f) GDPR.
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. The publicly readable profile stores neither the precise position nor a kilometre-level location for this purpose. It contains only the centre point of the Cliqly launch area as a broad regional assignment. Precise device location is not persistently stored as the profile location.
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.
5.1 Optional calendar export
Only when a user expressly selects “Add to Calendar” does Cliqly request write-only iOS calendar access and create the selected event through EventKit in the device calendar. Cliqly does not read existing calendar entries, upload calendar content to the Cliqly backend or use calendar data for analytics. Whether Apple Calendar synchronises an entry through iCloud depends on the user's Apple and calendar settings. Permission can be changed at any time in iOS.
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.
Publicly shared profile information and eligible public events can be found through search outside your own country or map area. This does not expand the areas where events can be created or permissions for private content and exact meeting locations. A country flag uses available location information; it does not indicate a person's nationality.
New prospective participants in Friends events need mutual following and Friends access confirmed by both people. Already confirmed participants retain access if that connection later ends; host removal, blocking or other justified restrictions can revoke access. Authorised moderators may inspect reported private content to handle the case.
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.
The profile-photo editor uploads a resized base image with separate framing data for the profile card and round avatar. Framing is only a display setting: parts outside the visible crop remain in the uploaded base image. Source location and camera metadata are not copied during this preparation. The blurred background is generated from the same image, not a separate uploaded photo.
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.
Protected content notices, related decision records and appeals are normally deleted no later than 18 months after the notice was received. An appeal remains available for at least six months after the communicated decision. Open proceedings, mandatory law or specifically required legal claims may require longer, purpose-limited restriction. Legal-document records are removed from the active backend when account deletion is completed unless mandatory law or a specifically required legal claim requires otherwise.
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.
The active appAccountToken mapping is needed for the life of the Cliqly account. Active subscriptions and subscriptions in an Apple grace period are not removed by the regular retention cleanup. While an account remains open, expired or revoked subscription chains and their verified transaction records are deleted 36 months after the relevant expiry or revocation date. Allowance operations are deleted 13 months after the start of the relevant calendar month. Technical receipt records for App Store server notifications, particularly the notification identifier, processing result and JWS hash, are kept for 180 days and then deleted. When an account is deleted, the account-linked token mapping, subscription chains, transaction records and allowance operations are removed from the active backend. Mandatory statutory retention duties and the preservation of specifically required legal claims remain unaffected; in that case, processing is restricted to the necessary purpose.
Short-lived offer-association challenges are valid for at most two minutes; expired challenges are removed by the cleanup job after one day. App Attest key associations are cleaned up after 90 days without use. Completed account deletion removes the associated keys, challenges and pending associations from the active backend. Username associations, Friends permissions and personal rating evidence are needed for their respective account features and are included in account deletion. The limited exceptions for legally necessary evidence described below continue to apply.
9. Moderation, content notices and safety
Formal content notices can also be submitted without a Cliqly account: Open the secure Cliqly notice portal.
Reports include the reported content, selected reason, technical references and context required for review. A formal notice of potentially illegal content should identify its exact location, provide a substantiated explanation, any relevant legal basis and a good-faith confirmation. Receipt and a decision are confirmed electronically where contact details are available and communication is legally permitted.
For a material decision, the affected person and, where provided for, the reporter receive the result, restriction, material facts, contractual or legal basis, use of automated means and available redress. Decisions to remove or restrict visibility, issue a warning or restrict an account are made by an authorised person; safety filters may only block technically or prioritise content for review. A reasoned appeal may be submitted for renewed human review within the stated period, which is at least six months after the communicated decision.
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.
News published by the operator may appear in the app and inbox in the relevant language. Publication does not automatically send a push notification to everyone. Optional writing and translation assistance for the operator processes deliberately selected news drafts on their compatible device using Apple's frameworks. Private chats, user profiles and moderation cases are not automatically supplied to this editorial assistant.
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, including protected storage and verification of subscription entitlements and usage allowances.
Apple independently administers App Store purchases and payments under Apple's terms and supplies us with verifiable transaction, renewal, expiry, refund and revocation information. Supabase processes data required for our backend functions on our instructions where it acts as a processor under data-protection law.
CloudKit stores, in particular, public profiles, profile pictures, public events and aggregate community values intended for discovery and display, together with private profile state in the relevant Apple account. Supabase additionally handles secure Apple account binding, authoritative username allocation and new rating records, Friends permissions and private Friends events, protected messaging and Crew access, participation and allowances, subscriptions and offer proofs, legal-document records, reports, moderation, appeals and deletion workflows. Existing private CloudKit data may also remain during the transition and stays included in export and deletion. This separation prevents security-critical permissions from being derived solely from a publicly readable app record.
Using Supabase may generate operational Auth, API and Edge Function logs. These may include the IP address, user agent, timestamp, requested endpoint, status or error code, technical region and request or execution duration. We use them for authentication and access protection, secure operation, abuse and error detection, and technical troubleshooting. Retention for Auth, API and Edge Function logs is governed separately by the periods applicable to the Supabase project, product, plan and configuration in use; these periods may change and are therefore not promised as a fixed number of days. The current Supabase documentation and project configuration apply. Access is restricted to personnel who need it.
Providers process data according to their function and applicable contractual and legal requirements. We select and review them so that the level of protection required for the relevant processing is maintained through contractual or legal obligations and appropriate technical and organisational measures. Cliqly does not perform cross-app or cross-website tracking for advertising or advertising measurement, disclose data to data brokers or sell personal data. We do not share data for third-party advertising or display third-party advertising. Optional subscriptions finance the operation and development of Cliqly.
12. International transfers
Where configurable, we select European processing appropriate for the supported regions. Because Apple, Supabase or their subprocessors may provide individual services from other countries, we review the providers, processing locations and subprocessors in use. 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, perform required transfer assessments, 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.
Deleting the Cliqly account does not cancel an Apple subscription. It must be cancelled separately in Apple's subscription management. Apple may continue to process purchase and subscription data under its own legal obligations and send subscription-status server notifications after the Cliqly account has been deleted. If a Cliqly account is later created with the same account verified through Sign in with Apple, the pseudonymous app-specific association identifier may be derived again and a still-active subscription can be reassociated only after renewed cryptographic verification; deleted profile and network data is not restored.
Limited exceptions apply where data must be restricted and retained for legal duties, unresolved reports, enforced bans, security evidence or legal claims. On completed deletion, links to a reporting, affected, appealing or deciding person are removed or irreversibly detached from moderation evidence that must remain. 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.