Effective date: [EFFECTIVE DATE — day of Notion publish]
Policy version: 2.3 · In-app notice version: kvkk-2026-09-18
App: Miniversite — iOS and Android (com.miniversite.app)
Contact: destek@miniversite.app
Summary
- Miniversite offers educational games for children in Turkish 1st grade (ages 6–8). The account is created by a parent or guardian.
- We do not collect the child's real name, age, date of birth, grade, school, photo or location. The child's in-app identity is a nickname and an avatar emoji.
- The account is created only by signing in with an Apple or Google account; from the parent we receive only the e-mail address passed to us by that provider (with Apple this may be a private relay address). No phone number is collected.
- There are no ads, no third-party analytics or tracking tools, no chat and no social sharing. Notifications are addressed to the parent only (when the weekly development report is ready; later reminders and news), never to the child, and can be switched off in Profile → Bildirimler (Notifications).
- The weekly AI development report is generated only with the parent's separate, optional explicit consent. For that report a performance summary that contains no name, nickname, account identifier or contact data is sent to an AI provider abroad.
- The account and all its data can be deleted from inside the app, immediately and permanently.
1. Data controller
Data controller under Turkey's Personal Data Protection Law No. 6698 ("KVKK"):
- Data controller: Miniversite — individual developer (natural person; identity and contact details are provided in the in-app privacy notice)
- Address: Cumhuriyet Mah. Fatih Sultan Mehmet Blv. Cadde224 Sitesi A Blok No:41A/A, 16140 Nilüfer/Bursa, Türkiye
- E-mail: destek@miniversite.app
Miniversite is distributed on the Turkish App Store and Google Play (Türkiye) [CONFIRM DISTRIBUTION SCOPE]. This policy is written under KVKK; where other laws apply to you, the same practices are described here factually.
2. Data we process
| Category | Examples | Source | Purpose | Legal basis (KVKK) |
|---|---|---|---|---|
| Parent contact data | The e-mail address passed to us by Apple or Google when signing in with those accounts (with Apple this may be a private relay address). No phone number is collected | The parent, at sign-up (Apple/Google sign-in) | Verifying the account, consent record, support | Art. 5/2-c (contract) |
| Child profile | Nickname (max. 30 characters), avatar emoji | Chosen in the account | Game experience; shown in the report header on the device only | Art. 5/2-c |
| Game performance data (pseudonymous) | Game type and mode, stage played, duration, correct/wrong counts, best streak, response-time summaries, mistake patterns (e.g. which number range was hard), daily totals, points earned, stage transitions | Generated as the child plays — stored only for verified accounts | Progress tracking, difficulty adaptation; with explicit consent, the weekly AI report | Art. 5/2-c; the AI report requires explicit consent (Art. 5/1) |
| Account and consent records | Randomly generated pseudonymous account ID; when the guardian declaration and the AI-report consent were given or withdrawn, the notice version read, the sign-in method (Apple/Google) | System | Account management, evidence | Art. 5/2-ç, 5/2-e |
| Security and device-integrity data | A signal attesting that the device and the app are unmodified (Android: Google Play Integrity; iOS: Apple App Attest / DeviceCheck), the app installation identifier (Firebase Installation ID), IP address, device/OS information | Every app launch | Preventing fake or modified clients and abuse | Art. 5/2-f (legitimate interest) |
| Use without an account | A random, pseudonymous user ID tied to the device; the chosen nickname/avatar | First launch | Letting the app work without an account | Art. 5/2-c |
| Notification data | The device's push token (Firebase Cloud Messaging registration token — a technical device identifier; at most 5 devices per account) and the notification preference | Only if the parent enables notifications (the OS permission is requested not at first launch but when the Koç tab is opened or AI-report consent is given) | Parent-addressed notifications: when the weekly development report is ready; later reminders and news. No notifications to the child | Art. 5/2-c; can be switched off any time in Profile → Bildirimler |
| Crash report | Device model, OS and app version, the technical stack trace at the time of the crash (no name, contact data or account ID) | If the app closes unexpectedly | Diagnosing and fixing errors | Art. 5/2-f (legitimate interest) |
We do not collect: the child's real name, surname, age, date of birth, grade, school, photo, location or contacts; the parent's phone number; payment-card data; audio or camera recordings; advertising identifiers; browsing history.
The free-play family (Eğlence: colouring, song, balloon games) stores no performance data; colouring drawings stay on the device only.
Google Firebase processes IP addresses and request metadata in its own security logs for authentication and database requests.
3. Children's data
- The account is created by an adult who declares being over 18 and the child's parent or guardian; the declaration is recorded.
- Account operations (sign-up, sign-in), the subscription screen, external links (e-mail) and account deletion sit behind a parental gate ("What month is it now?").
- No identifying data is requested from the child. We recommend not entering a real name as the nickname.
- Notifications are addressed to the parent only (when the weekly development report is ready); no notifications are sent to the child, and notifications can be switched off in Profile → Bildirimler. The app shows no ads, contains no chat or social sharing and runs no third-party analytics or tracking tools (crash reporting is not analytics).
- The data sent for the AI report contains no identifying information, and the report is generated only with the parent's optional explicit consent (Section 7).
4. What we use the data for
(a) Creating the account and verifying the parent through their Apple or Google account; (b) recording the child's progress and adapting difficulty; (c) only with your explicit consent, the weekly AI development report; (d) account security and abuse prevention (including device-integrity attestation); (e) answering support requests; (f) meeting legal obligations and keeping evidence of transactions; (g) delivering the notifications the parent has enabled; (h) diagnosing and fixing app crashes.
Your data is never used for advertising, marketing or profiling, and never sold.
5. Legal bases
Account and progress data are processed under KVKK Art. 5/2-c (establishment and performance of a contract); no consent is requested or collected for this. Security, device-integrity attestation, abuse prevention and crash reporting rely on Art. 5/2-f (legitimate interest); record-keeping and evidence obligations on Art. 5/2-ç and 5/2-e. Notifications are delivered as part of the service under Art. 5/2-c; they are enabled only with the parent's OS permission and can be switched off at any time. Explicit consent is requested for exactly one processing activity: the AI-assisted weekly development report. It is optional, is not a condition for creating the account or using the app, and every other feature works the same whether it is given, refused or withdrawn.
6. Where your data is kept and who receives it
| Recipient / provider | Location | What it processes | Why | Safeguard |
|---|---|---|---|---|
| Google Firebase — Cloud Firestore (database) | European Union — Netherlands (europe-west4) | Account, profile, performance, consent and report data | Hosting | Google Cloud data-processing terms · [ART. 9 SAFEGUARD STATUS — counsel to complete] |
| Google Firebase — Cloud Functions | European Union — Belgium (europe-west1) | Verification, report generation and account-deletion functions | App functions | Same |
| Google Firebase — Authentication | USA / global (no region selection available) | The e-mail address from the parent's Apple/Google account, session | Authentication | [ART. 9 SAFEGUARD STATUS — counsel to complete] |
| Google Firebase — App Check + Google Play Integrity (Android) | USA / global | Device-integrity signal, installation ID, IP address | Preventing fake clients and abuse | Same |
| Apple — App Attest / DeviceCheck / APNs (iOS) | USA / global | Device-integrity signal; push token for parent notifications | Security, notification delivery | Apple platform terms |
| Google Firebase — Cloud Messaging (FCM) | USA / global | The device's push token; notification content (contains no child data) | Delivering parent notifications (only when enabled) | Google Cloud data-processing terms · [ART. 9 SAFEGUARD STATUS — counsel to complete] |
| Google Firebase — Crashlytics | USA / global | Crash report (device/OS/app version, technical stack trace; no identity or contact data) | Error diagnosis | Same |
| Anthropic (Claude API) | USA | A weekly performance summary containing no name, nickname, account ID or contact data — only with explicit consent | AI development report | Commercial API terms: data is not used to train models and is deleted within 30 days · [DPA / ART. 9 STATUS — counsel to complete] |
| Apple — Sign in with Apple | USA / global | The parent's Apple account identity; only the verified e-mail address (optionally a private relay address) is passed to us | Authentication (signing in with an Apple account) | Apple platform terms |
| Google — Google Sign-In | USA / global | The parent's Google account identity; only the verified e-mail address is passed to us | Authentication (signing in with a Google account) | Google terms |
| Apple App Store / Google Play and subscription infrastructure (RevenueCat) | USA | Not processed today — in-app subscriptions are not yet offered. Once they are, only purchase/subscription status is processed; card details belong to the store and are never sent to us | Subscription management | [TO BE ADDED WITH WP-R4 — notice version will be bumped] |
International transfers are subject to the safeguards required by KVKK Art. 9: [BEFORE LAUNCH: state the standard contract, undertaking or equivalent safeguard actually in place — counsel]. Your data is shared with no third party other than those listed.
7. The AI development report
- The report is optional and off by default. At sign-up a separate, unticked checkbox asks for explicit consent and states, at that moment, what data goes where.
- You can withdraw consent at any time in Profile → "Yapay Zekâ Gelişim Raporu" (AI Development Report). Withdrawal stops any further transfer to the AI provider from that moment; reports already generated stay in your account until the account is deleted (account deletion removes them all).
- Reports are generated once a week (early Monday morning, Türkiye time) and only if at least three lesson sessions were played that week.
- Sent: week dates, session and minute counts, active days, per-subject accuracy and stage, strongest/weakest games (Turkish labels), frequent mistake patterns (e.g. "5→4"), difficulty profile, stage transitions and the comparison with the previous week.
- Never sent: the child's nickname, the parent's phone/e-mail, the account ID, device data, raw response times.
- The report is produced exclusively by automated AI analysis and is not a diagnosis. To object, use the "Rapora itiraz et" (Object to this report) link on the report screen or write to destek@miniversite.app (KVKK Art. 11/1-g).
8. Retention
| Data | Period |
|---|---|
| Account, profile, performance data, reports, consent records | Until the account is deleted |
| Deletion proof record (irreversible hash of the account ID; contains no contact data) | Permanent — kept solely as proof that deletion took place |
| Technical marker tracking the deletion process | At most 30 days |
| Device-integrity tokens | Expire and are renewed within hours |
| Push token | Until notifications are switched off, the user signs out or the account is deleted (at most 5 devices); an invalid token is removed on the first failed delivery attempt |
| Crash reports | 90 days in Google Firebase Crashlytics |
| Provider logs | Anthropic at most 30 days; Google and Apple security logs under their own retention periods |
Short-lived records are stamped for deletion at the end of these periods.
9. Account deletion
In the app: Profile → "Hesabımı Sil" (Delete My Account) → parental gate → sign in again with the Apple or Google account the account was created with → final confirmation (press and hold). The account and all its data are deleted immediately and permanently. If you can no longer access the app, e-mail destek@miniversite.app with the subject "Account Deletion Request" stating the e-mail address of the Apple/Google account linked to it; after identity verification the request is completed within 30 days at the latest. Details: /hesap-silme.
10. Your rights (KVKK Art. 11)
You have the right to learn whether your data is processed, to request information, to learn the purpose and whether data is used accordingly, to know the third parties it is transferred to, to request correction of incomplete or inaccurate data, to request deletion or destruction, to request that these actions be notified to recipients, to object to a result produced exclusively by automated analysis, and to claim compensation for damage caused by unlawful processing.
Requests: destek@miniversite.app (the in-app KVKK screen opens your e-mail app with a ready-made subject). Requests are answered within 30 days at the latest after identity verification. The nickname and avatar can be changed in the app; the linked Apple/Google account cannot — write to support for that.
11. Security
- All data travels over HTTPS/TLS-encrypted channels.
- The database is protected by access rules under which every user can reach only their own data; critical fields of account and consent records can be written only by the server.
- Authentication relies on Apple's and Google's own secure sign-in infrastructure; the app stores no passwords or verification codes.
- Device-integrity attestation guards against fake or modified clients.
- Cloud backup of app data is disabled.
12. What is stored on your device
Session and profile information (account ID, the linked account's e-mail address, nickname, avatar), game results not yet uploaded, the consent preference captured at sign-up, notification preference/permission flags and app-tour flags are kept in the operating system's storage area reserved for the app. Colouring drawings stay on the device only. Uninstalling the app removes this local data; server-side account data remains until the account is deleted.
13. Changes
This policy and the in-app notice are updated together; each update changes the in-app notice version and the new text is published on this page. You will be informed again in the app about changes that affect your consent.
14. Contact
E-mail: destek@miniversite.app
Postal address: Miniversite — Cumhuriyet Mah. Fatih Sultan Mehmet Blv. Cadde224 Sitesi A Blok No:41A/A, 16140 Nilüfer/Bursa, Türkiye