PRIVACY POLICY

HelpStreetCatEffective Date: 28.07.2026

1. General Provisions

1.1.This Privacy Policy (hereinafter referred to as the "Policy") establishes the procedure for the collection, receipt, use, storage, transfer, protection, deletion, and other Processing of Personal Data of Users of the HelpStreetCat digital Platform.

1.2.The Personal Data Controller is HELP STREET CAT E-TİCARET DANIŞMANLIK LİMİTED ŞİRKETİ, incorporated and operating in accordance with the laws of the Republic of Türkiye (hereinafter referred to as the "Company").

The Processing of Personal Data is carried out in accordance with Law No. 6698 of the Republic of Türkiye on the Protection of Personal Data (Kişisel Verilerin Korunması Kanunu, hereinafter referred to as "KVKK"), as well as other applicable laws and regulations.

1.3.This Policy applies to all instances of the Processing of Personal Data when using the HelpStreetCat mobile application, the official website https://helpstreetcat.com, as well as other digital services, web interfaces, software solutions, and functionalities provided by the Company under the HelpStreetCat brand.

1.4.This Policy constitutes an integral part of the HelpStreetCat User Agreement and shall apply in conjunction therewith unless otherwise expressly provided by this Policy or by mandatory provisions of Applicable Law.

1.5.This Policy informs the User of which Personal Data may be Processed by the Company, the sources from which such Personal Data may be obtained, the purposes for which it is used, the legal grounds on which its Processing and transfer are carried out, the period for which it may be retained, and the rights available to the User.

1.6.Familiarization with this Policy shall not, in itself, constitute the provision of separate consent to the Processing of Personal Data where Applicable Law requires such consent to be obtained. Where separate consent is required for a specific Processing operation, the Company shall request such consent separately.

1.7.The Company shall Process Personal Data in good faith, lawfully, and solely to the extent necessary to achieve the purposes set forth in this Policy, the User Agreement, and Applicable Law.

1.8.The User's refusal to provide Personal Data objectively required for registration, authentication, the performance of a Transaction, or the use of a particular function of the Platform may result in the inability to provide the relevant function or service.

1.9.The Company adheres to the principles of lawfulness, good faith, proportionality, and Personal Data minimization and does not request information that is not reasonably necessary for the operation of the Platform or for compliance with the requirements of Applicable Law.

2. Definitions

2.1.Unless otherwise expressly provided in this Policy, the terms used herein shall have the meanings assigned to them in the HelpStreetCat User Agreement.

2.2.Personal Data means any information relating directly or indirectly to an identified or identifiable natural person.

2.3.Processing of Personal Data means any operation or set of operations performed on Personal Data, whether by automated means or otherwise, including collection, receipt, recording, systematization, storage, updating, amendment, use, analysis, transfer, disclosure, anonymization, blocking, deletion, destruction, and any other operations provided for by Applicable Law.

2.4.User means an individual who uses the Platform, in whole or in part, regardless of whether such individual has an Account.

2.5.Company means HELP STREET CAT E-TİCARET DANIŞMANLIK LİMİTED ŞİRKETİ.

2.6.Platform means the HelpStreetCat digital ecosystem, including the mobile application, the official website, software, server infrastructure, digital services, and the related technical solutions.

2.7.Account means the User's personal account within the Platform, created following registration or authentication and enabling the User to access the relevant HelpStreetCat functions.

2.8.Authentication Provider means a person or entity that enables the User to register or sign in to an Account through its own information system, including Apple and Google.

2.9.Payment Provider means an application marketplace, bank, payment institution, acquiring service provider, or any other entity that processes payments in accordance with Applicable Law.

2.10.Transaction means any action performed by the User through the Platform, including feeding animals, using CatPayCoin, purchasing digital services, obtaining the relevant Platform functions, or any other actions provided for by the User Agreement.

3. What Personal Data We Process

3.1.The Company Processes only such Personal Data as is necessary for registration, authentication, use of the Platform, provision of the relevant functions, performance of the User Agreement, compliance with the requirements of Applicable Law, and achievement of the other purposes set forth in this Policy.

3.2.Depending on the registration method selected by the User, the Platform functions used, and the Transactions performed, the Company may Process, including but not limited to, the following categories of Personal Data:

name or display name, if provided by the User or the relevant Authentication Provider;
email address;
telephone number;
Account information;
information relating to registration, email address verification, and restoration of access to the Account;
interface language;
country or region in which the Platform is used;
information about the device used;
technical device identifiers;
IP address;
Platform usage logs;
information about completed Transactions;
information relating to the use of CatPayCoin;
history of use of digital services;
customer support requests;
information voluntarily provided by the User while using the Platform;
information obtained during registration or authentication through an Authentication Provider;
materials voluntarily submitted by the User when contacting customer support.

3.3.The Company may also automatically collect technical information regarding the operation of the Platform, including information about the operating system version, Application version, device type, technical errors, failures, performance, network parameters, diagnostic data, and other technical information necessary to ensure the proper functioning of HelpStreetCat.

3.4.Where registration or authentication is performed through Apple or Google, the Company does not receive or store the User's password for the corresponding account.

3.5.The Company does not Process special categories of Personal Data unless such Processing is expressly provided for by the functionality of the Platform or is required by mandatory provisions of Applicable Law.

3.6.The Company does not request or require the provision of Personal Data exceeding the scope reasonably necessary for the provision of the relevant digital services.

3.7.The User independently decides whether to provide Personal Data unless otherwise required by mandatory provisions of Applicable Law or where such Personal Data is necessary for the use of specific Platform functions.

3.8.When payments are processed through the App Store, Google Play, or other Payment Providers, the Company does not receive or store the User's full bank card number, expiration date, security code (CVV/CVC), or any other complete bank card details. Such data is Processed by the relevant Payment Provider in accordance with its own terms and privacy policy.

4. Purposes of Processing Personal Data

4.1.The Company Processes Personal Data solely to the extent necessary to achieve lawful, predetermined purposes consistent with the Company's activities.

4.2.Personal Data may be Processed for the following purposes:

creation, maintenance, and deletion of the Account;
identification of the User;
providing access to HelpStreetCat digital services;
performance of the User Agreement;
processing, execution, and recording of Transactions;
accrual, use, deduction, and accounting of CatPayCoin;
provision, maintenance, and development of paid and free digital services;
ensuring the operation, maintenance, and development of the Platform and its infrastructure;
execution of User commands transmitted through the Platform;
processing User requests;
provision of technical support;
sending the User notifications relating to the use of the Platform, the Account, security, Transactions, and the performance of the User Agreement;
ensuring information security;
prevention of fraud, abuse, and other unlawful activities;
detection, investigation, and prevention of violations of the User Agreement;
analysis of the operation of the Platform;
diagnosis of technical errors;
improvement of the quality of digital services;
development of new functions and services;
conducting statistical and analytical research;
analysis of Platform usage in anonymized or aggregated form;
compliance with the requirements of Applicable Law;
compliance with mandatory requirements of governmental authorities;
protection of the Company's legitimate interests;
protection of the rights of Users and third parties;
achievement of other purposes directly related to the operation of the Platform.

4.3.The Company does not use Personal Data for purposes incompatible with the purposes for which it was originally collected unless otherwise required by mandatory provisions of Applicable Law or carried out with the User's consent.

4.4.The Company may use anonymized, aggregated, or statistical data that does not directly or indirectly identify a specific User for the analysis of the operation of the Platform, the development of new functions, the preparation of statistical materials, the improvement of digital services, the conduct of research, and other lawful purposes.

4.5.The use of anonymized data shall not constitute the Processing of Personal Data to the extent that such data no longer relates to an identified or identifiable User under Applicable Law.

5. Legal Bases for Processing Personal Data

5.1.The Company Processes Personal Data solely where there are appropriate legal grounds provided for under Applicable Law.

5.2.Such legal grounds may include:

the User's consent;
the necessity to perform the User Agreement or other contractual obligations;
compliance with obligations imposed upon the Company by Applicable Law;
protection of the legitimate interests of the Company, Users, or third parties in cases permitted by Applicable Law;
compliance with the requirements of governmental authorities;
establishment, exercise, or protection of the Company's rights and legitimate interests, provided that the requirements of Applicable Law are observed;
other legal grounds provided for by Applicable Law.

5.3.Where Applicable Law requires the User's separate consent for the Processing of certain categories of Personal Data or for particular methods of their use, the Company shall obtain such consent in the manner prescribed by the relevant legislation.

5.4.Where the Processing of Personal Data is based on the User's consent, such consent may be withdrawn in the manner prescribed by Applicable Law.

5.5.Withdrawal of consent shall not affect the lawfulness of the Processing of Personal Data carried out before the Company received the relevant notice, nor shall it prevent the continued Processing of Personal Data where such Processing is permitted or expressly required by Applicable Law regardless of whether the User's consent has been given.

6. Use of Cookies and Similar Technologies

6.1.When the official Website, web interfaces, or other online services of HelpStreetCat are used, the Company may use cookies, SDKs, pixels, local storage, device identifiers, tokens, event logs, and other similar technologies necessary for the operation of the Platform.

6.2.Such technologies may be used for the following purposes:

ensuring the proper functioning of the Platform;
saving User preferences;
maintaining authentication;
ensuring the operation of the Account and maintaining the User session;
ensuring security;
preventing fraud;
analyzing Platform performance;
diagnosing technical errors;
improving the user interface;
conducting statistical research;
obtaining anonymized statistics regarding the use of the Platform;
developing new functions.

6.3.The Company does not use tracking technologies to the extent prohibited by Applicable Law.

6.4.Where the use of particular technologies requires the User's prior consent, such consent shall be obtained in the manner prescribed by Applicable Law.

6.5.The User may restrict the use of cookies through the settings of the User's browser or device; however, such restriction may result in the inability to use certain functions of the Platform.

7. Transfer of Personal Data to Third Parties

7.1.The Company does not sell Users' Personal Data to third parties.

7.2.The Company may transfer Personal Data solely to the extent necessary to achieve the purposes set forth in this Policy, the User Agreement, or Applicable Law.

7.3.Personal Data may be transferred to the following categories of recipients:

cloud infrastructure providers;
server infrastructure providers;
telecommunications operators;
data storage service providers;
information security service providers;
authorization and authentication service providers;
technical support service providers;
analytics service providers;
User support service providers;
Payment Providers;
owners and operators of mobile application stores;
contractors;
subcontractors;
the Company's Affiliates;
governmental authorities in cases provided for by Applicable Law;
other persons where such transfer is necessary for the operation of the Platform or is expressly provided for by Applicable Law.

7.4.When engaging third parties, the Company shall take reasonable measures to ensure the confidentiality of Personal Data and compliance with the requirements of Applicable Law.

7.5.In the event of the Company's reorganization, sale of the business, sale of the Platform, transfer of individual assets, accession, division, merger, or any other corporate restructuring, Personal Data may be transferred to the relevant legal successor, provided that the requirements of Applicable Law are observed.

7.6.The Company shall not be responsible for the Processing of Personal Data by third parties following its lawful transfer where, after such transfer, those parties independently determine the purposes and means of further Processing of Personal Data in accordance with Applicable Law.

8. International Transfer of Personal Data

8.1.Due to the use of modern information technologies, cloud infrastructure, international providers of digital services, and other technological solutions, Personal Data may be Processed or transferred outside the Republic of Türkiye in cases permitted by Applicable Law.

8.2.The Company shall carry out the international transfer of Personal Data only where appropriate legal grounds exist and in compliance with the requirements of Applicable Law.

8.3.When carrying out the international transfer of Personal Data, the Company shall implement reasonable organizational, technical, and contractual measures aimed at ensuring an adequate level of protection of Personal Data.

8.4.Where Applicable Law requires the execution of specific agreements, the obtaining of the User's consent, or compliance with other conditions for the international transfer of Personal Data, the Company shall ensure compliance with such requirements.

8.5.The international transfer of Personal Data shall be carried out solely to the extent reasonably necessary to achieve the purposes of Processing Personal Data set forth in this Policy.

9. Retention of Personal Data

9.1.The Company shall retain Personal Data no longer than is necessary to achieve the purposes of its Processing, unless a longer retention period is required by Applicable Law or is necessary to protect the Company's legitimate interests.

9.2.The retention period for Personal Data shall be determined taking into account:

the purposes of the Processing;
the nature of the relevant Personal Data;
the period during which the User uses the Platform;
the requirements of Applicable Law;
the necessity of performing contractual obligations;
the necessity of handling requests and resolving disputes;
the necessity of preventing fraud;
the necessity of protecting the Company's legitimate interests.

9.3.Upon achievement of the purposes of the Processing or where further retention is no longer necessary, Personal Data shall be deleted, destroyed, anonymized, or archived in cases provided for by Applicable Law.

9.4.Deletion of an Account shall not, in itself, result in the immediate deletion of all Personal Data where its further retention is required for compliance with legal obligations, performance of outstanding obligations, handling of requests, prevention of fraud, or protection of the Company's legitimate interests.

10. Protection of Personal Data

10.1.The Company shall implement reasonable organizational, technical, and administrative measures to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful acts.

10.2.To ensure the security of Personal Data, the Company may use modern information security measures, including:

access control;
authentication and authorization;
encryption;
backup;
access control for information systems;
security logs;
information security event monitoring;
threat detection tools;
other information protection technologies.

10.3.Despite implementing reasonable security measures, no method of transmitting or storing information can guarantee the absolute security of data.

10.4.The User shall also take reasonable measures to protect their Personal Data, including maintaining the confidentiality of the credentials used to access the Account, using up-to-date software, and protecting the devices used to access the Platform.

10.5.Upon becoming aware of information security incidents, the Company shall, without undue delay, take reasonable measures to eliminate such incidents, minimize their potential consequences, and fulfill its obligations under Applicable Law.

11. User Rights

11.1.The User shall be entitled to exercise all rights granted under Applicable Law with respect to the Processing of their Personal Data.

11.2.Subject to the requirements of Applicable Law, the User shall have the right to:

obtain information regarding the Processing of their Personal Data;
access their Personal Data;
obtain information regarding the sources from which their Personal Data was obtained, where required by Applicable Law;
request the rectification of inaccurate or incomplete Personal Data;
request the deletion of Personal Data in cases provided for by Applicable Law;
request the restriction of the Processing of Personal Data;
object to the Processing of Personal Data in cases provided for by Applicable Law;
withdraw previously given consent to the Processing of Personal Data where such Processing is based on that consent;
request the provision of their Personal Data to the extent and in the manner provided for by Applicable Law;
apply to the competent public authorities on matters relating to the protection of Personal Data;
exercise any other rights granted under Applicable Law.

11.3.To exercise their rights, the User may contact the Company using the communication methods specified on the Platform.

11.4.The Company shall consider such requests within a reasonable period of time, taking into account the nature of the request, the requirements of Applicable Law, and the need to verify the authority of the applicant.

11.5.Prior to providing information or complying with the relevant request, the Company may request information necessary to verify the identity of the User or their authority.

11.6.The Company may refuse, in whole or in part, to satisfy a request only in cases provided for by Applicable Law.

12. Processing of Minors' Personal Data

12.1.HelpStreetCat is intended for use by individuals who possess the legal capacity required under Applicable Law.

12.2.Where the use of the Platform by minors is permitted, the Processing of their Personal Data shall be carried out in compliance with the requirements of Applicable Law.

12.3.Where Applicable Law requires the consent of a minor's legal representative, the Company may request confirmation of such consent before providing the relevant digital services.

12.4.If the Company becomes aware that a minor's Personal Data has been obtained in violation of the requirements of Applicable Law, the Company may take reasonable measures to terminate the relevant Processing, restrict access to the Platform, or delete such data, unless otherwise provided by Applicable Law.

13. Amendments to this Privacy Policy

13.1.The Company may amend this Privacy Policy at any time where such amendments are necessitated by:

changes in legislation;
changes in the requirements of public authorities;
development of the Platform;
introduction of new digital services;
changes in the methods of Processing Personal Data;
technological developments;
improvements to information security measures;
correction of errors, inaccuracies, or inconsistencies;
other reasonable circumstances related to the Company's activities.

13.2.The revised version of this Privacy Policy shall become effective upon its publication on the Platform, unless the Company specifies a different effective date.

13.3.Where mandatory provisions of Applicable Law require Users to be notified of amendments to this Privacy Policy, the Company shall provide such notification in a manner it considers reasonable and sufficient.

14. Contact Information

14.1.For matters relating to the Processing of Personal Data, the User may contact the Company using the communication methods specified on the official HelpStreetCat Website or through the Platform, including by email at: privacy@helpstreetcat.com.

14.2.The Company shall consider Users' requests within a reasonable period of time in compliance with the requirements of Applicable Law.

15. Governing Law

15.1.This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Türkiye, unless otherwise required by mandatory provisions of private international law or other mandatory provisions of Applicable Law.

15.2.If any provision of this Privacy Policy is held to be wholly or partially invalid or unenforceable, such invalidity or unenforceability shall not affect the validity of the remaining provisions of this Privacy Policy, which shall continue in full force and effect to the maximum extent permitted by Applicable Law.

15.3.In all matters not expressly governed by this Privacy Policy, the provisions of the HelpStreetCat User Agreement and the mandatory provisions of Applicable Law shall apply.

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