1. Introduction
Welcome to Dually Up. We are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our dating application and related services.
By using Dually Up, you agree to the collection and use of information in accordance with this policy. We comply with the General Data Protection Regulation (GDPR) and the Turkish Personal Data Protection Law (KVKK - Law No. 6698).
Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access or use our services.
2. Data Controller
The data controller responsible for your personal data is:
For any questions regarding this Privacy Policy or your personal data, please contact us using the information above.
3. Personal Data We Collect
3.1 Information You Provide
- Account Information: Name, email address, phone number, date of birth, gender, and password when you create an account.
- Profile Information: Photos, biography, interests, preferences, occupation, education, and other details you choose to share on your profile.
- Dating Preferences: Gender preferences, age range preferences, distance preferences, and relationship goals.
- Verification Data: ID documents or photos submitted for profile verification purposes.
- Subscription Information: Subscription status and purchase receipts when you subscribe to Premium features through the Apple App Store or Google Play Store (payment details are processed directly by Apple/Google and not stored by us).
- Communications: Messages you send to other users, support requests, and feedback you provide.
3.2 Information Collected Automatically
- Device Information: Device type, operating system, unique device identifiers, browser type, and mobile network information.
- Location Data: GPS coordinates, city, and country (with your permission) to show you potential matches nearby.
- Usage Data: Pages visited, features used, time spent on the app, duel choices made, and interaction patterns.
- Log Data: IP address, access times, referring URLs, and error logs.
- Cookies and Similar Technologies: Information collected through cookies, pixels, and similar tracking technologies.
3.3 Information from Third Parties
- Social Media: If you sign up using a social media account (Google, Apple), we receive basic profile information from those platforms.
- Analytics Partners: Aggregated analytics data from our service providers.
4. How We Use Your Data
We process your personal data for the following purposes:
Matching & Connection
To facilitate the duel system, create matches, and enable communication between users.
Account Management
To create, maintain, and secure your account, and process your transactions.
Safety & Verification
To verify identities, prevent fraud, detect suspicious activity, and maintain platform safety.
Improvement & Analytics
To analyze usage patterns, improve our algorithm, and enhance user experience.
Communication
To send service updates, security alerts, and promotional messages (with consent).
Legal Compliance
To comply with legal obligations, respond to legal requests, and protect our rights.
5. Legal Basis for Processing
Under GDPR (Article 6) and KVKK (Article 5), we process your personal data based on the following legal grounds:
(GDPR Art. 6(1)(a), KVKK Art. 5(1))
(GDPR Art. 6(1)(b), KVKK Art. 5(2)(c))
(GDPR Art. 6(1)(f), KVKK Art. 5(2)(f))
(GDPR Art. 6(1)(c), KVKK Art. 5(2)(a))
6. How We Share Your Data
We do not sell your personal data. We may share your information with:
6.1 Other Users
Your profile information (photos, bio, age, location) is visible to other users as part of the matching process. You control what information you share on your profile.
6.2 Service Providers
We work with trusted third-party service providers who assist us in operating our platform:
- Cloud Hosting: Microsoft Azure for secure data storage and processing
- In-App Purchase Processing: Apple App Store and Google Play Store for subscription management (all payment information is handled directly by Apple and Google - we do not store or process payment details)
- Analytics: Google Analytics for usage analysis (anonymized where possible)
- Communication: Email and push notification service providers
- Verification: Identity verification service providers
6.3 Legal Requirements
We may disclose your information when required by law, legal process, or government request, or when necessary to protect the rights, property, or safety of Dually Up, our users, or others.
6.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your personal data may be transferred. We will notify you of any such change.
7. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy:
8. Your Rights
Under GDPR and KVKK, you have the following rights regarding your personal data:
Right to Access
Request a copy of all personal data we hold about you.
Right to Rectification
Correct any inaccurate or incomplete personal data.
Right to Erasure
Request deletion of your personal data ("right to be forgotten").
Right to Restriction
Limit how we process your data in certain circumstances.
Right to Portability
Receive your data in a structured, commonly used format.
Right to Object
Object to processing based on legitimate interests or marketing.
Right to Withdraw Consent
Withdraw consent at any time without affecting prior processing.
Right to Complain
Lodge a complaint with a supervisory authority (KVKK Board in Turkey).
How to Exercise Your Rights: You can exercise most of these rights directly in the app (Settings > Privacy) or by contacting us at info@mdatechnologies.net. We will respond within 30 days.
10. International Data Transfers
Your personal data may be transferred to and processed in countries outside Turkey and the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place:
- Adequacy Decisions: Transfers to countries recognized as providing adequate data protection.
- Standard Contractual Clauses: EU-approved contractual provisions with service providers.
- Binding Corporate Rules: Where applicable with corporate group members.
- Your Consent: Where required and appropriate.
Our primary data storage is within the European Union (Microsoft Azure EU data centers) to ensure GDPR compliance.
11. Data Security
We implement robust security measures to protect your personal data:
While we strive to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure. We encourage you to use strong passwords and keep your login credentials confidential.
12. Children's Privacy
Dually Up is strictly for users aged 18 and over. We do not knowingly collect personal data from anyone under 18 years of age.
If we discover that we have collected personal data from a child under 18, we will delete that information immediately. If you believe a child has provided us with personal data, please contact us at info@mdatechnologies.net.
13. California Privacy Rights (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with additional rights regarding your personal information.
13.1 Your California Rights
As a California resident, you have the right to:
- Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, purposes, and third parties with whom we share it.
- Right to Delete: Request deletion of your personal information, subject to certain exceptions.
- Right to Correct: Request correction of inaccurate personal information.
- Right to Opt-Out of Sale/Sharing: We do not sell your personal information and do not share it for cross-context behavioral advertising.
- Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.
- Right to Limit Use of Sensitive Personal Information: You may limit our use of sensitive personal information to only what is necessary for the Service.
13.2 Categories of Personal Information
In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA:
- Identifiers (name, email address, device identifiers)
- Personal information categories listed in Cal. Civ. Code § 1798.80(e) (name, address, phone number)
- Characteristics of protected classifications (age, gender)
- Internet or other electronic network activity (usage data, interaction history)
- Geolocation data (with your consent)
- Audio, electronic, or visual information (photos you upload)
- Inferences drawn from the above to create a profile
13.3 How to Exercise Your Rights
To exercise your California privacy rights, please contact us at privacy@duallyup.com or through the in-app privacy settings. We will verify your identity before processing your request and respond within 45 days.
Do Not Sell or Share My Personal Information: Dually Up does not sell your personal information to third parties and does not share your personal information for cross-context behavioral advertising purposes as defined by the CCPA/CPRA.
14. United Kingdom Privacy Rights
If you are a resident of the United Kingdom, you are protected under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Your rights under these regulations are substantially similar to those under the EU GDPR as described in Section 8 above.
14.1 UK Representative
For UK-specific data protection inquiries, please contact us at privacy@duallyup.com.
14.2 UK Supervisory Authority
You have the right to lodge a complaint with the Information Commissioner's Office (ICO):
- Website: ico.org.uk
- Phone: +44 (0303) 123 1113
14.3 International Transfers from the UK
When we transfer personal data outside the UK, we rely on UK adequacy regulations, UK International Data Transfer Agreements (IDTAs), or the UK Addendum to the EU Standard Contractual Clauses to ensure adequate protection.
15. Global Data Protection Rights
Depending on your location, you may have additional privacy rights under your local data protection laws. We are committed to respecting these rights wherever you are located.
15.1 European Economic Area (EEA)
If you are in the EEA, you may lodge a complaint with your local Data Protection Authority (DPA). A list of EEA DPAs is available at edpb.europa.eu.
15.2 Brazil (LGPD)
If you are a resident of Brazil, you have rights under the Lei Geral de Proteção de Dados (LGPD), including the right to access, correct, delete, and port your personal data. You may file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).
15.3 Australia
If you are an Australian resident, you have rights under the Australian Privacy Act 1988. You may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.
15.4 Canada (PIPEDA)
If you are a Canadian resident, your personal information is protected under the Personal Information Protection and Electronic Documents Act (PIPEDA). You may file a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.
15.5 Exercising Your Rights
Regardless of your location, you can exercise your privacy rights by contacting us at privacy@duallyup.com or through Settings > Privacy in the app. We will respond within the timeframe required by your applicable local law (typically 30 days).
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons.
When we make significant changes, we will:
- Update the "Last updated" date at the top of this policy
- Notify you via email or in-app notification
- Request your consent again where required by law
We encourage you to review this Privacy Policy periodically. Your continued use of Dually Up after any changes indicates your acceptance of the updated policy.
17. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:
General Inquiries
info@mdatechnologies.netPrivacy Requests
privacy@duallyup.comAddress
MDA Technology and Software Services
Merkez, Hasat Sk. No:52
34381 Sisli/Istanbul, Turkey
Data Protection Authorities: You have the right to lodge a complaint with the supervisory authority in your jurisdiction:
- Turkey (KVKK): kvkk.gov.tr
- EU: Your local Data Protection Authority — List of EEA DPAs
- UK (ICO): ico.org.uk
- California: California Attorney General