Privacy Policy
Effective date: January 1, 2025 · Last updated: April 4, 2026
This Privacy Policy applies to Essentia Memoria operated by its founders at Guzelyurt District, 2148th Street, No: 5/A Block A, Door/Flat No: 217 Esenyurt, Istanbul, Turkey. This policy covers the Essentia Memoria website, applications, and all associated services.
1. Data Controller
Data Controller: Essentia Memoria
Address: Guzelyurt District, 2148th Street, No: 5/A Block A, Door/Flat No: 217 Esenyurt, Istanbul, Turkey
Contact: contact@essentiamemoria.com
Phone: +90 543 688 76 18 (WhatsApp only)
This policy complies with the European Union General Data Protection Regulation (GDPR) and Turkish Personal Data Protection Law No. 6698 (KVKK / Kişisel Verilerin Korunması Kanunu).
2. Data We Collect
Account data: For a registered account, email address, display name, and username are mandatory — we need them to create your account, sign you in, and show you on the platform. For email/password sign-up, a password is also required (stored only as a hash). Preferred language, avatar, bio, and other profile fields are optional unless you choose to add them.
Contact, phone, and postal address (optional): If you enter them under Settings, we store them on your account to support marketplace orders, physical delivery or pickup, shipping labels where sellers or logistics need an address, invoicing or tax documentation where applicable, and real-world coordination (for example meetups, exchanges, or events you arrange through the platform). If you choose to verify your phone number, we may send a one-time SMS code to that number so we can confirm you control it, and — only if you turn this on after verification — require a short SMS code when you sign in with your password to reduce account takeover and fraud. Nothing in this block is shown on your public profile. You can edit or clear these fields anytime from Settings.
Mood and emotional data (sensitive): Mood entries, mood codes, emotional journal content, Atlas session data, and mindset interactions. This data is classified as sensitive personal data under both GDPR Article 9 and KVKK, as it relates to your psychological state and inner life. It is processed only with your explicit consent.
AI and Oracle content: Text and optional images you send to Oracle/AI features, related conversation context, and (where enabled) vector embeddings derived from your content for memory and relevance features. This processing may involve third-party AI infrastructure and underlying model providers.
Oracle media controls: Under Settings you can turn off Oracle use of images, video, audio, and document uploads separately (AI tagging and/or inline image analysis). Files you uploaded for other features may remain stored even when Oracle analysis for that type is off.
Essence (in-platform balance): “Essence” is a virtual utility used only inside Essentia Memoria (for example marketplace listings, unlocks, and in-app actions). It is not legal tender, not e-money issued by us, and we do not operate banking or payment services regulated as such. Purchases of digital goods on the site use this internal balance; physical goods you may sell or buy through separate channels (for example a linked third-party shop) are outside that in-site ledger unless we explicitly integrate a compliant flow.
Device and media (when you use the feature): Browser-based speech input where supported; optional microphone, camera, or screen sharing for voice/video or collective features when you explicitly start them; images you upload (for example to Oracle). We do not access the microphone or camera in the background without your action.
Community and marketplace: Forum posts, replies, reactions, listings, bids, orders, direct messages, and other content you submit in social or marketplace areas.
Optional wellness or day context: Voluntary entries such as meal or day-brief related data you save, and optional approximate coordinates you choose to store for life-context or Oracle features. If you use a weather-related add-on that needs coordinates, we may send latitude and longitude to Open-Meteo (see Section 9).
Regional personalization (optional, separate from shipping address): If you turn this on and provide optional city, region, country, and/or saved approximate coordinates, we may use those coarse signals to show you anonymous, aggregate hints — for example activity on the short-lived mood presence map near you, how many live streams or physical marketplace listings are associated with the same country label, and similar in-app context. We do not sell this as a profile to advertisers; it supports app functionality and personalization. You can turn regional personalization off anytime under Settings → Contact & approximate location while keeping or clearing your address fields separately.
Usage, in-app attention signals, and diagnostics: For signed-in users we may store short server-side records of app routes you open, collective hub search or feed filter choices, and similar interaction lines linked to your account to power personalized Oracle context (together with content you create). This is separate from generic page analytics where configured. Limited technical diagnostics and session signals may also be used to operate and improve the platform. You can turn off Oracle “mind” collection anytime under Settings → Privacy (your Oracle will then behave more like a guest: no new touch logs, no long-term memory updates from chat, and a stripped server context). You can also remove stored Oracle navigation / touch lines through account data export and selective erasure (for example the Oracle UI touches or mind-core categories in data controls).
IP geolocation: Your approximate location (city-level) may be derived from your IP address for the anonymous Presence Map feature. Your exact IP is not permanently stored for that purpose. You can disable related options in Privacy Settings where offered.
Payment data: Web purchases are processed by Gumroad (we receive order and fulfillment metadata, not your full card number). On Android, in-app purchases may be processed by Google Play Billing; Google handles payment credentials. We store subscription or purchase status, order references, and data needed to validate purchases (for example purchase tokens) — never raw card numbers on our servers.
Communications: Messages sent to us via contact forms or WhatsApp for support purposes.
3. How We Use Your Data
We use your data to: provide and personalize the platform experience; operate the emotional Atlas and mood tracking features; power Oracle/AI responses and related memory features; send essential service communications; process and validate payments (including Google Play where applicable); fulfill marketplace and delivery-related obligations when you supply a contact or address; where enabled, derive coarse regional context (city/region/country or approximate coordinates you chose) for in-app recommendations and Oracle copy as described in Section 2; enforce our Terms of Service; measure sign-ups and purchases with analytics and (where configured) conversion tags; and improve our services through aggregated analytics.
We never sell your personal data or mood data to any third party. We do not use your emotional or psychological content to target third-party ads. Measurement tools such as Google Analytics or Google Ads conversion tags may receive event or device-related data as described in Section 9; you can use browser controls, consent tools where shown, and Google’s ad/analytics settings to limit some measurement.
4. Legal Basis for Processing (GDPR / KVKK)
Contract: Processing necessary to deliver the service you registered for (account, features, subscriptions), and — when you buy or sell through marketplace flows — to perform the contract (for example using an address you provided for shipment or pickup coordination).
Consent: Mood data, emotional journal, geolocation for Presence Map — you may withdraw consent at any time. Optional contact, phone, and postal address in Settings are provided voluntarily; you may clear them anytime.
Legitimate interest: Security monitoring, fraud prevention, platform improvement.
Legal obligation: Retention of financial records as required by Turkish commercial law.
5. Data Retention
Account data: retained until you delete your account. After deletion, data is held in soft-delete state for 30 days for recovery, then permanently erased. Mood data is deleted immediately upon account deletion request.
Financial records: retained for 10 years as required by Turkish law (Türk Ticaret Kanunu).
Log data: retained for a maximum of 90 days.
6. Your Rights
Under GDPR and KVKK you have the right to: Access your data; Rectify inaccurate data; Erase your data (right to be forgotten); Restrict processing; Data portability (export as JSON); Object to processing; Withdraw consent at any time.
Export & partial erasure: Open /ar/privacy/data-controls (or the locale-free redirect /privacy/data-controls for store listings). Download a mind archive (Oracle + ontology + atlas state) or a full JSON export; erase selected data categories without deleting your account.
Delete your account: While signed in, open /[locale]/settings?section=danger (example: /en/settings?section=danger or /tr/settings?section=danger). Use ?section=danger&delete=1 to scroll to the delete flow and open the confirmation panel. 30-day recovery window; API: POST /api/user/delete-account with {"confirm":true} and session cookies.
To exercise any right, email: contact@essentiamemoria.com
7. Children's Privacy
Essentia Memoria is not intended for children under the age of 13. We do not knowingly collect personal data from children under 13. If you believe a child under 13 has provided data, please contact us immediately at contact@essentiamemoria.com and we will delete the data.
7a. Child safety standards (CSAE / Google Play)
For our public standards on child safety, child sexual abuse and exploitation (CSAE), reporting channels, and law-enforcement cooperation — including the in-app contact path required by Google Play — see Child Safety Standards. A locale-free redirect for store listings: /privacy/child-safety → English page.
8. IP Geolocation Disclosure
We use your IP address to derive your approximate city-level location for the anonymous Presence Map feature only. This is disclosed here in compliance with GDPR transparency requirements. Your exact IP is not permanently stored. You can opt out of geolocation in your profile Privacy Settings.
9. Third-Party Services
Google: We may use Google Analytics 4 (usage and conversion measurement; sign-up events may include a pseudonymous user identifier you already have in the app), optional Google Ads conversion measurement when configured, Google reCAPTCHA on relevant forms, and (for Android) Google Play for in-app purchases and related Play services. Google’s policies apply: Google Privacy Policy.
Payments: Gumroad for web checkout; Google Play for in-app purchases on Android. Additional payment integrations may exist in our codebase for operational flexibility but are not offered as active checkout paths unless we enable them.
Email: Transactional and system email may be sent via providers such as Resend (or comparable SMTP/API providers).
AI infrastructure: Oracle and related features may send prompts and optional images to third-party AI gateways (for example OpenRouter) and underlying model providers. Those providers process content only to generate responses and related technical functions (such as embeddings when enabled).
Weather (Open-Meteo): For optional Oracle weather features, we may request current conditions from the public Open-Meteo API (no separate API key on our side). Only the coordinates needed for that request are sent. We do not use a commercial weather API in production unless we configure one later and update this policy.
Each third party operates under its own privacy policy and terms. Where we act as controller, we choose subprocessors that align with applicable data protection requirements and use contractual safeguards for international transfers where required.
10. Data Security
We use industry-standard encryption (AES-256-CBC for sensitive fields, TLS in transit), bcrypt password hashing, JWT-based authentication with short expiry, and regular security audits. No system is 100% secure, but we are committed to protecting your data.
11. International Transfers
Our servers are located in the EU/EEA. Any transfer of data outside this zone is subject to Standard Contractual Clauses (SCCs) as required by GDPR Chapter V. As a company registered in Turkey, KVKK transfer provisions also apply.
12. Cookie Policy
We use essential cookies for authentication and security. Where enabled, analytics or advertising measurement scripts (for example Google Analytics / Google tags) may set additional cookies or use similar storage; you can control many cookies via your browser and, for Google, via Google’s tools. See our full Cookie Policy for details.
13. Changes to This Policy
We will notify you by email and in-app notification of material changes. Continued use of the platform after 30 days constitutes acceptance.