ExitTime Privacy Policy

Effective date: 28 September 2026

Version: 1.0

1. Introduction and Scope

1.1 This Privacy Policy explains how BY SİVİŞ BİLİŞİM TEKSTİL SANAYİ VE TİCARET LİMİTED ŞİRKETİ ("By Siviş", "we", "us" or "our") collects, uses, discloses, retains and protects information in connection with the ExitTime mobile application for iOS and Android, related customer support and any ExitTime web pages that we operate (together, the "Service"), and the choices and rights available to you.

1.2 This Privacy Policy applies to users of the Service worldwide. Section 19 contains additional disclosures for users in particular countries and regions.

1.3 Capitalised terms that are not defined in this Privacy Policy, including "App", "App Identifier", "Plan", "Leave Time", "Pro" and "Subscription", have the meanings given to them in the ExitTime Terms of Use.

1.4 This Privacy Policy does not apply to third-party services that you access through or in connection with the Service, such as App Stores or navigation applications. Those services are governed by their own privacy policies.

2. Who We Are and How to Contact Us

2.1 The Service is provided by BY SİVİŞ BİLİŞİM TEKSTİL SANAYİ VE TİCARET LİMİTED ŞİRKETİ, a limited liability company incorporated in the Republic of Türkiye, whose registered office is at Tomtom Mah. İstiklal Cad. Turhol Han No: 189 İç Kapı No: 7, Beyoğlu, İstanbul, Türkiye. We are responsible, as controller, for the personal data processed in connection with the Service.

2.2 We operate the Service from Türkiye and do not maintain establishments or representatives in other countries. Users and supervisory authorities in any country may contact us directly at support@bysivis.com, with "Privacy" in the subject line, or by post to our registered office.

3. Anonymous Use of the App

3.1 The App is designed to be used anonymously. We do not require you to create an account, and we do not ask for your name, email address, telephone number, date of birth or any other contact details in order to use the App.

3.2 When you first open the App, it generates a random App Identifier. Your Plans, settings and Subscription status are associated with that App Identifier and not with your name or contact details.

3.3 When you purchase a Subscription, Apple or Google processes the payment. We receive confirmation of the transaction and your Subscription status. We do not receive your payment card details, and we do not use transaction information to identify you.

3.4 We do not attempt to identify you. However, information linked to the App Identifier, such as location information, may constitute personal data under certain laws, and we protect it in accordance with this Privacy Policy.

3.5 If you contact us by email, we receive your email address and the content of your message, which we use to respond to you. If you write to us through the in-App support channel, we receive your message together with your App Identifier, and our reply reaches you as a notification in the App. Support messages are kept for up to 12 months after the conversation ends.

4. Information We Collect

4.1 We collect the following categories of information.

4.2 Sensitive information. We do not request sensitive information. However, certain destinations (for example, a medical facility or a place of worship) may indirectly reveal sensitive information. We use destinations only to provide and improve the Service, we do not analyse them to infer sensitive characteristics and we never disclose them to advertisers. You should not include sensitive information in Plan names or notes.

4.3 Optional information. Allowing location access and notifications is optional. Plan information is necessary for the Service to calculate Leave Times, and Subscription information is necessary to provide Pro. If you do not provide information that is necessary for a feature, that feature will not be available.

5. How We Use Information

5.1 We use the information described in section 4 to:

(a) set up the App, including onboarding and the generation of the App Identifier;

(b) provide the core Service, including calculating and updating Leave Times, storing and displaying Plans and applying your settings;

(c) send leave reminders, notifications relating to your Plans and Subscription, replies to your support messages, and occasional information about features and offers of the Service;

(d) provide, verify and manage Subscriptions, Trials, renewals and cancellations, and process refund notifications received from Apple and Google;

(e) personalise the Service, including suggesting default settings based on onboarding answers and presenting features relevant to Free Tier or Pro users;

(f) understand how the Service is used, measure the performance of features and screens, and develop and improve the Service;

(g) maintain the security and integrity of the Service, diagnose faults and prevent fraud and misuse;

(h) respond to enquiries and complaints;

(i) measure the effectiveness of our advertising, subject to your Device's tracking and advertising identifier settings; and

(j) comply with legal obligations, respond to lawful requests from public authorities, enforce our Terms of Use and establish, exercise or defend legal claims.

5.2 We may create aggregated or anonymised information that does not identify any individual, and use it for any lawful purpose.

6. Location Information

6.1 We use location information to determine your starting point and to calculate and update Leave Times for your Plans. If you do not allow location access, the App uses the start address that you enter.

6.2 Location in the background is used only to notice that you have not yet left your starting point when it is time to leave, so that the App can remind you even while it is closed. The App explains this before requesting the permission. We do not use background location to record your journeys or to track your route.

6.3 We do not sell location information, we do not use it for advertising and we do not track your movements. The destinations and starting points you save in your Plans are kept as Plan information (see sections 4 and 13) and are used to improve the Service.

6.4 To calculate journey times, we transmit starting points, destinations, travel modes and times of travel to our map, geocoding, traffic and journey-time data providers. We do not provide them with information that identifies you; however, providers whose services are accessed directly from your Device may receive your IP address (see section 11.3).

6.5 Places saved in a Plan are retained as described in section 13.1. Location readings used to calculate Leave Times or to check whether you have left are retained for no longer than 30 days.

7. Device Permissions

7.1 The App requests the following permissions when the related feature is first used. You may review and change them at any time in your Device settings.

8. Notifications

8.1 If you allow notifications, we send leave reminders, notifications relating to your Plans and your Subscription, replies to messages you send through the in-App support channel, and occasional information about features and offers of the Service. The content of notifications may differ for Free Tier and Pro users.

8.2 You can manage or disable notifications at any time in your Device settings.

9. Analytics and Similar Technologies

9.1 The App uses software development kits (SDKs) and similar technologies that store information on, or access information from, your Device. We use them to provide the features you request, deliver notifications, verify purchases, maintain security, diagnose faults and understand how the Service is used.

9.2 Where the operating system of your Device requires your permission for a particular use, such as tracking under Apple's App Tracking Transparency framework, we request that permission through the operating system's permission prompt, and the relevant technology is used only if you grant it.

10. Subscriptions and Payments

10.1 Subscriptions are purchased through the Apple App Store or Google Play. Apple and Google process payment information, and handle refunds, as independent controllers under their own privacy policies.

10.2 We receive transaction and Subscription status information from Apple and Google, and we verify purchases with their systems, in order to provide Pro, manage renewals, Trials and cancellations, process refund notifications received from them and prevent fraud.

11. How We Share Information

11.1 We do not sell personal data. We disclose information only to the categories of recipients set out below.

11.2 Our service providers process information only on our instructions and under written contracts. We require every third party with which we share personal data to provide the same or an equivalent level of protection as that described in this Privacy Policy.

11.3 Where the App uses Google Maps Platform services, Google may collect information directly from your Device (such as IP address, search terms and location coordinates) when you use those features, in accordance with the Google Privacy Policy (https://policies.google.com/privacy).

12. International Transfers

12.1 We are established in Türkiye. Information is processed in Türkiye and in other countries in which our service providers operate, which may include the United Kingdom, member states of the European Economic Area and the United States. These countries may have data protection laws that differ from those of your country of residence.

12.2 Where the law of your country requires it, we protect transfers of personal data with appropriate safeguards, which may include adequacy decisions or regulations, standard contractual clauses (including the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum, and the standard contracts provided for under Turkish law), or certification of the recipient under the Data Privacy Framework.

13. Data Retention

13.1 We retain information only for as long as necessary for the purposes described in this Privacy Policy, and then delete or anonymise it in accordance with the following periods.

13.2 When you delete your data, it is deleted or anonymised in our live systems within 30 days and in our backups within 90 days, except for the record of Plan destinations and starting points described in section 13.1 and where we are required to retain information by law.

14. Data Security

14.1 We implement appropriate technical and organisational measures to protect information against unauthorised or unlawful processing, accidental loss, destruction or damage. These measures include encryption of data in transit, encryption of data at rest where supported by our service providers, access controls based on the principle of least privilege, pseudonymous identifiers, logging and monitoring, security assessment of service providers and a documented incident response procedure.

14.2 No method of transmission or storage is completely secure. In the event of a personal data breach, we will notify the competent supervisory authorities and affected individuals where required by applicable law.

15. Your Choices and Rights

15.1 Choices. You can change location, notification and tracking permissions at any time in your Device settings, and you can delete individual Plans in the App.

15.2 Deleting your data. You can delete all data associated with your App Identifier at any time within the App, subject to section 13.2. You can also request deletion by emailing support@bysivis.com with "Privacy request" in the subject line, without the App being installed. Deleting your data or the App does not cancel a Subscription, which must be cancelled through your Apple or Google account settings.

15.3 Rights. Depending on the law of your country of residence, you may have the right to access, correct, delete or receive a copy of your personal data, to restrict or object to certain processing, and to withdraw consent. Section 19 describes these rights for certain countries and regions.

15.4 Exercising your rights. You may exercise your rights by emailing support@bysivis.com with "Privacy request" in the subject line. Because the App is used anonymously, we may ask you for information that allows us to identify the data associated with your installation of the App. We will not ask for more information than is necessary for that purpose. We will respond within the period required by the law applicable to you.

16. Children

16.1 The Service is intended only for individuals who are at least 18 years old or the age of majority in their country of residence, whichever is higher, and is not directed at children. We do not knowingly collect personal data from children.

16.2 If we become aware that we have collected personal data from a child, we will delete it without undue delay. If you believe that a child has provided us with personal data, please contact support@bysivis.com.

17. Automated Processing

17.1 The Service calculates Leave Times automatically, and we group users according to simple criteria (such as Free Tier or Pro status) to determine which content and messages to display or send. We do not make any decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.

18. Platform Privacy Disclosures

18.1 The privacy information we provide in the App Privacy section of the Apple App Store and in the Data safety section of Google Play summarises this Privacy Policy. In the event of any inconsistency, this Privacy Policy prevails.

18.2 The information above is associated with the App Identifier and not with your name or contact details. Information is encrypted in transit, and you may request its deletion as described in section 15.

19. Region-Specific Disclosures

19.1 United Kingdom, European Economic Area and Switzerland

If you are located in the United Kingdom, a member state of the European Economic Area or Switzerland, the following disclosures apply in addition to the rest of this Privacy Policy.

(a) Controller. The controller of your personal data is By Siviş, whose details are set out in section 2. You may contact us directly on any matter relating to the processing of your personal data.

(b) Lawful bases. We rely on the following lawful bases under the UK General Data Protection Regulation and the EU General Data Protection Regulation:

(c) Your rights. Subject to the conditions set out in applicable law, you have the right to access your personal data, to have it rectified or erased, to restrict its processing, to receive it in a portable format, to object to processing based on legitimate interests and to direct marketing, and to withdraw consent at any time without affecting the lawfulness of processing before its withdrawal. We will respond to requests within one month, which may be extended by two further months where necessary, taking into account the complexity and number of requests.

(d) International transfers. Where we transfer personal data outside the United Kingdom, the European Economic Area or Switzerland to a country without an adequacy decision or regulation, we rely on appropriate safeguards as described in section 12.2. You may request further information about these safeguards by contacting us.

(e) Complaints. If you have a complaint about our processing of your personal data, please contact us first at support@bysivis.com with "Data protection complaint" in the subject line. We will acknowledge your complaint within 30 days and inform you of the outcome without undue delay. You may also lodge a complaint with a supervisory authority: in the United Kingdom, the Information Commissioner's Office (www.ico.org.uk); in the European Economic Area, the data protection authority of the member state in which you live or work; and in Switzerland, the Federal Data Protection and Information Commissioner.

19.2 United States

If you reside in a state of the United States with a comprehensive consumer privacy law, including California, the following disclosures apply in addition to the rest of this Privacy Policy. This section also serves as our notice at collection for California residents.

(a) Categories of personal information. In the preceding 12 months, we have collected the following categories of personal information: identifiers (such as the App Identifier, Device identifiers, IP address and, where permitted, advertising identifier); commercial information (Subscription and purchase history); internet or other electronic network activity information (usage and diagnostic information); geolocation data (precise and approximate location); inferences (such as preferences and Free Tier or Pro status); and other information you provide (Plans, onboarding answers and communications, including in-App support messages). The sources, purposes, recipients and retention periods for this information are described in sections 4, 5, 11 and 13. We disclose each category to service providers for the business purposes described in section 11.

(b) No sale or sharing. We do not sell personal information and we do not share personal information for cross-context behavioural advertising. We have no actual knowledge of selling or sharing the personal information of consumers under 16 years of age.

(c) Sensitive personal information. Precise geolocation is sensitive personal information under certain state laws. We collect precise geolocation only with your consent, which you give through your Device's location permission and may withdraw at any time in your Device settings. We use it only to provide the Service you request and for other purposes permitted by law, and not to infer characteristics about you.

(d) Your rights. Subject to applicable law, you may have the right to know and access the personal information we have collected about you, to request its deletion or correction, to receive a portable copy, and to opt out of the sale or sharing of personal information or its use for targeted advertising. We will not discriminate against you for exercising your rights.

(e) Exercising your rights. You may submit requests by emailing support@bysivis.com. We will verify your request using information associated with your installation of the App. You may designate an authorised agent to submit a request on your behalf, subject to verification. We will respond within the period required by applicable law.

(f) Appeals. If we decline to take action on your request, you may appeal by emailing support@bysivis.com with "Privacy appeal" in the subject line. If you are not satisfied with the outcome of your appeal, you may contact the Attorney General of your state.

19.3 Türkiye

(a) This Privacy Policy constitutes our information notice under Article 10 of Law No. 6698 on the Protection of Personal Data ("KVKK"). Personal data is collected by electronic means through the App, including through the in-App support channel, and, where you contact us, by email. We process personal data on the grounds set out in Articles 5 and 6 of KVKK, including where processing is necessary for the establishment or performance of a contract, for compliance with our legal obligations or for our legitimate interests, and on the basis of your explicit consent where required. Transfers of personal data abroad are carried out in accordance with Article 9 of KVKK.

(b) Under Article 11 of KVKK you have the right to: learn whether your personal data is processed; request information about such processing; learn the purpose of processing and whether data is used for that purpose; know the third parties to whom your data is transferred in Türkiye or abroad; request the correction of incomplete or inaccurate data; request the deletion or destruction of your data under the conditions set out in Article 7 of KVKK; request that third parties to whom your data has been transferred be notified of any correction, deletion or destruction; object to any outcome to your detriment arising from the analysis of your data exclusively by automated systems; and claim compensation for damage arising from unlawful processing.

(c) Requests may be submitted in writing to our registered office, by email to support@bysivis.com, or by any other method permitted by the Communiqué on the Principles and Procedures for the Request to Data Controller. We will respond within 30 days, free of charge unless a fee is permitted by the Personal Data Protection Board. You may also lodge a complaint with the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu).

19.4 Other Countries

If you reside in any other country, you may have additional rights under the law of your country of residence. You may exercise those rights by contacting us as described in section 2.

20. Third-Party Services

20.1 The App may allow you to access third-party services, such as navigation applications and App Stores. When you use a third-party service, the third party's privacy policy applies to its processing of your information. We are not responsible for the privacy practices of third parties.

21. Changes to this Privacy Policy

21.1 We may update this Privacy Policy to reflect changes in our processing, the Service or the law. The effective date and version number at the top of this Privacy Policy identify the version in force. We will notify you of material changes in the App before they take effect and, where required by law, will seek your consent. Previous versions are available on request.

22. Contact

BY SİVİŞ BİLİŞİM TEKSTİL SANAYİ VE TİCARET LİMİTED ŞİRKETİ

Tomtom Mah. İstiklal Cad. Turhol Han No: 189 İç Kapı No: 7

Beyoğlu, İstanbul, Türkiye

Email: support@bysivis.com (subject: "Privacy")

Website: https://bysivis.com/