Lilithea

Lilithea · Legal

Privacy Policy

This policy explains, in plain language, what personal data we process when you use Lilithea, why and how we use it, who we share it with, and the rights you have.

01Who we are

The Lilithea mobile app (“Lilithea”) is published by CodeCraftopia. CodeCraftopia (“we”, “us”) is the data controller for your personal data under Turkey's Personal Data Protection Law No. 6698 (“KVKK”) and, for users in the European Economic Area (“EEA”), the General Data Protection Regulation (“GDPR”).

This policy also serves as our information notice under Article 10 of KVKK.

Data controller: CodeCraftopia Yazılım ve Danışmanlık Limited Şirketi (CodeCraftopia)

Email: info@lilithea.com

Address: Muratreis Mah. Selami Değirmeni Sok. Hızır Apt. No:32 D:4, 34664 Üsküdar, Istanbul, Türkiye

You can write to this address with any privacy question or request.

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02At a glance

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03Data we process

What we process depends on which Lilithea features you use.

Account and device

Required at sign-up

Optional profile details

Location (optional)

Your activity in the app

Messages

Purchases and coins

Safety and moderation records

Technical data

What we don't collect: your email address, phone number, a password, your contacts, your location in the background, or your card details. We also don't store your precise location.

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04Who sees what

In games

Your game partner doesn't see your name, photos or bio, only limited details such as your age, your signs and the interests you share. If you both choose to connect at the end of the game, your names, photos and profiles are revealed to each other.

In Discover

While you're visible in Discover, other users can see your name, age, gender, signs, bio, interests, intent, photos, your compatibility score with them, and whether you're online or when you were last active. If you both share your location, they also see the approximate distance between you (in km).

If you turn this setting off, only people you meet in games can find you.

When you like someone who has Premium, they can see your card in their list of people who liked them. Without Premium, they only see your sign, your age and your compatibility score.

Your connections

People you've connected with see your profile and the messages you send them.

What nobody sees

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05Purposes and legal bases

We process your personal data for the purposes below, relying on the legal bases in Articles 5 and 6 of KVKK. The equivalent GDPR bases apply to users in the EEA and the UK.

Creating your account and providing Lilithea

Sign-in, your profile, games and compatibility, Discover, connections, chat, coins and Premium.

Legal basis: entering into and performing our contract with you (KVKK Art. 5(2)(c); GDPR Art. 6(1)(b)).

Enforcing the 18+ age limit

Checking your age from your birth date.

Legal basis: performance of the contract and our legitimate interest in protecting minors (KVKK Art. 5(2)(c) and (f); GDPR Art. 6(1)(b) and (f)).

Distance-based matching

Applying distance limits and showing approximate distances when you turn on location sharing.

Legal basis: your explicit consent (KVKK Art. 5(1); GDPR Art. 6(1)(a)). You can withdraw it at any time by turning off location sharing.

Preferences that may reveal your sexual orientation

Your choice of which genders you want to see or be matched with in games may reveal information about your sex life or sexual orientation, which is a special category of personal data. We use these preferences only to give you the matches you ask for.

Legal basis: the explicit consent you give by setting these preferences (KVKK Art. 6; GDPR Art. 9(2)(a)). You can change them at any time.

Safety, moderation and preventing abuse

Photo screening, reviewing reports, banning accounts, rate limiting, server logs and security records.

Legal basis: our legitimate interest in protecting our users and the service, establishing, exercising or defending legal claims, and our legal obligations (KVKK Art. 5(2)(f), (e) and (ç); GDPR Art. 6(1)(f) and (c)).

Processing and recording purchases

Adding the coins or Premium you buy to your account and keeping transaction records.

Legal basis: performance of the contract and our legal obligations under tax and commercial law (KVKK Art. 5(2)(c) and (ç); GDPR Art. 6(1)(b) and (c)).

Showing ads

Funding the free version of Lilithea through advertising.

Legal basis: our legitimate interest (KVKK Art. 5(2)(f); GDPR Art. 6(1)(f)) and, where the law requires consent for personalised advertising or for accessing information on your device, your consent. See Ads for the data Google collects directly.

Improving Lilithea

Aggregate statistics such as daily active users and how often games are completed. We use these statistics in aggregate, not to look at individuals.

Legal basis: our legitimate interest (KVKK Art. 5(2)(f); GDPR Art. 6(1)(f)).

Communicating with you

Answering your questions and requests when you email us.

Legal basis: our legitimate interest and, for data protection requests, our legal obligation (KVKK Art. 5(2)(f) and (ç); GDPR Art. 6(1)(f) and (c)).

Legal obligations and official requests

Responding to lawful requests from competent authorities and courts.

Legal basis: processing expressly required by law and our legal obligations (KVKK Art. 5(2)(a) and (ç); GDPR Art. 6(1)(c)).

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06How we collect data

We collect personal data electronically, by fully or partly automated means, from:

Automated decisions

Compatibility scores and matchmaking are calculated automatically. Photo uploads are also checked automatically first: a photo that clearly breaks the rules is not uploaded, and borderline photos are passed to a person. Decisions to ban an account are made by our authorised moderators, not by automated systems. You have the right to object to an outcome against you that results solely from automated processing (see Your rights).

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07Photo safety and moderation

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08Messages

Your messages are stored on our servers so they can be delivered and your chat history can be shown. The connection between the app and our servers is encrypted with TLS.

Messages are not end-to-end encrypted, so they are technically accessible on our servers.

Only our authorised moderators access messages, and only when needed to review a report, investigate a safety or abuse concern, or meet a legal obligation. Every such access is logged. We don't use your messages for advertising.

We recommend not sharing sensitive information such as ID, bank details or passwords in messages.

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09Location

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10Ads

The free version of Lilithea shows ads through Google AdMob, Google's advertising service: full-screen (interstitial) ads when the app opens, and optional rewarded ads you can watch to earn coins. Premium members don't see ads.

To show and measure ads and to prevent ad fraud, Google may collect data directly from your device through the AdMob software in the app. This includes your advertising identifier (the Android advertising ID, or the IDFA on iOS if you allow it), IP address, device and app information, and your interactions with ads. Google processes this data under its own policies and as its own responsibility.

We don't give Google your profile details, photos, messages or location for advertising.

How to limit ad tracking

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11Purchases

Coin packs and Premium are bought as in-app purchases through the Apple App Store or Google Play. Apple or Google processes the payment; we never see your card or payment details.

We receive details such as the product, the transaction ID and the time of purchase from the store, and our servers check the transaction ID with Apple or Google to confirm the purchase is genuine. We use these details to add what you bought to your account, make sure the same transaction isn't processed twice, and handle refund or support requests. Apple and Google process payment data under their own privacy policies: Apple Privacy Policy, Google Privacy Policy.

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12Notifications and device permissions

All permissions are optional and can be revoked in your device settings at any time.

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13Who we share data with

We don't sell your personal data. We share it only in the cases below, and only as much as needed:

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14International transfers

The following providers are located outside Turkey (for example in the United States). When their services are used, your personal data is transferred abroad:

We carry out these transfers in line with Article 9 of KVKK, as amended in 2024 by Law No. 7499: on the basis of an adequacy decision where one exists for the destination country; otherwise with one of the appropriate safeguards listed in the law, such as standard contracts; and, where neither is available, only occasionally and in the cases the law allows (for example where the transfer is necessary to perform a contract with you, or with your explicit consent after being informed of the possible risks).

When you download Lilithea or make purchases through the App Store or Google Play, you deal directly with Apple or Google through your own account, and what you give them is covered by their privacy policies.

Users in the EEA and the UK: your data is sent to us as a controller based in Turkey and may be processed in other countries by our service providers. In those cases we rely on the transfer safeguards provided under the GDPR, such as European Commission adequacy decisions or standard contractual clauses.

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15How long we keep data

We keep personal data only for as long as it's needed for the purpose it was collected for, and for any period required by law:

When these periods end, we delete, destroy or anonymise the data in line with Article 7 of KVKK and the Regulation on the Deletion, Destruction or Anonymisation of Personal Data. The next section explains what happens when you delete your account.

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16Deleting your account

You can delete your account in the app at any time: Settings → Delete account. This can't be undone. If you can't open the app, follow the steps on the account deletion page.

What happens straight away

What isn't deleted straight away

The information below is not deleted together with your account. It stays linked to the closed account's internal ID, is no longer associated with your name or device, isn't shown to other users, and is kept only for the purposes listed and for the periods in How long we keep data:

If you'd like this information deleted too, write to info@lilithea.com. We'll delete it unless a legal obligation or a legal claim requires us to keep it.

Uninstalling the app doesn't delete your account. Because your account is tied to your device, you may lose access to it if you uninstall the app. If you want to delete your account, delete it in the app first. If you've lost access, email us with details that help us find your account (for example your user ID from Settings, or your display name).

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17Security

No system is completely secure. If we learn that your data has been obtained unlawfully by others, we'll inform you and the Personal Data Protection Board as soon as possible, as required by Article 12 of KVKK and other applicable law.

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1818+ only

Lilithea is only for people who are 18 or older. We ask for your birth date at sign-up, and anyone under 18 is turned away both in the app and on our servers.

If we learn that someone under 18 is using Lilithea, we close their account and delete their data. If you suspect this, report the profile in the app with the “Underage user” reason, or email info@lilithea.com.

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19Your rights

Your rights under KVKK

Under Article 11 of KVKK, you have the right to:

How to make a request

Email your request to info@lilithea.com. Under the Communiqué on the Procedures and Principles of Applications to the Data Controller, your request should include your name and surname, your Turkish ID number if you're a Turkish citizen (otherwise your nationality and passport or ID number), an address or email address for our reply, and what you're asking for. Please also include the user ID shown in Settings so we can find your account. We may ask for more information to confirm the account is yours.

We'll respond free of charge within 30 days at the latest. If handling the request involves a separate cost, a fee may be charged according to the tariff set by the Personal Data Protection Board.

If your request is rejected, you find our answer insufficient, or we don't reply in time, you can complain to the Personal Data Protection Board within 30 days of learning of our reply, and in any case within 60 days of your request.

Users in the EEA and the UK (GDPR)

You have the right to access your data, have it corrected or erased, restrict its processing, receive it in a portable format, object to processing based on legitimate interests, withdraw consent at any time, and not be subject to solely automated decisions with significant effects. You can also complain to the data protection authority in the country where you live or work.

Controls in the app

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20Changes to this policy

We may update this policy from time to time. The current version is always published on this page, with its effective date at the top. We'll let you know about significant changes before they take effect, in the app or in another reasonable way.

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21Contact us

For any question or request about this policy or your personal data:

CodeCraftopia Yazılım ve Danışmanlık Limited Şirketi

Muratreis Mah. Selami Değirmeni Sok. Hızır Apt. No:32 D:4, 34664 Üsküdar, Istanbul, Türkiye

info@lilithea.com

For the rules of using Lilithea, see our Terms of Use.

This policy is published in Turkish and English.

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