Privacy Notice on the Protection of Personal Data
Effective date: 2026-10-09 · Version: 2026-10-09
The version you accept is recorded against your account under this label; when the text changes, your acknowledgment is renewed.
1. Data controller
The party acting as data controller under the Personal Data Protection Law (Law No. 6698, "KVKK") is:
| Full name | Samet Arslan (gerçek kişi) |
| Address | İstanbul / Ümraniye |
| Contact e-mail | kvkk@praedix.app |
| Website | https://praedix.app |
In this notice, "we", "Praedix" or "the platform" refer to the data controller above.
What Praedix is: Praedix is a free, publicly accessible prediction game built around Champions League matches. For each match the user picks home win, draw, or away win; the pick locks when the match kicks off; the user earns points once the match ends. There is no money in the system: no fee is ever charged and no prize is ever paid out. Praedix is not a betting, gambling, or games-of-chance product.
2. Personal data we process
The list below is the complete set of personal data we process. We do not collect personal data outside this list.
| Data | When it is obtained | Description |
|---|---|---|
| E-mail address | At registration and at every sign-in | Obtained through one of: sign in with Google, sign in with Apple, or a single-use link ("magic link") sent by e-mail. Account matching is always done via the verified e-mail address. |
| Display name | Created at registration, changeable by the user afterwards | Derived at first sign-in from the name supplied by the identity provider, or from the portion of the e-mail address before the @ sign. Visible to every other user on the leaderboards. |
| Avatar (profile picture) address | Only if signing in with Google or Apple, and only if the provider supplies it | The picture's link address is stored. |
| IP address | Only on sign-in and security events: a magic-link request, a sign-in (successful or failed), a rejected session refresh, hitting a rate limit | Retained to detect abuse (spam, automated requests, stolen sessions, inflating the rankings through multiple accounts). No IP record is kept for ordinary page views or in application error logs. |
| Predictions and score history | As the user makes predictions | Which pick was made for which match, points earned, and the trail of any changes to a prediction. |
| Group memberships | When a user creates or joins a group | Group name, group owner, memberships. |
| User reports | When a user reports another user | The reporting and reported user, the report's grounds, and its outcome. |
| Administrator action logs | When an administrator intervenes | Which administrator took which action and on what grounds. Kept so that result disputes can be resolved. |
| Sign-in and security event logs | When you sign in, request a magic link, have a session refresh rejected, or hit a rate limit | The type, outcome and time of the event; the IP address; where applicable, the user ID and an abbreviated e-mail address (e.g. s***l@gmail.com; the full address is not stored in this record). Kept so that abuse can be investigated afterwards. |
| Application error logs | When a warning or error occurs in the system | The technical detail and time of the error; where applicable, the user ID and an abbreviated e-mail address. The IP address and the full e-mail address are not written. Kept to investigate errors and to match your support message to the relevant error. |
| Site usage data (Google Analytics) | Only if you consent to analytics cookies | Pages visited, the link the site was opened from, device and browser type, approximate location (country/city level), and a random identifier in the cookie. Not linked to your account; your IP address is not stored in Google Analytics. |
We do not store passwords. There is no such thing as a password on Praedix; a "forgot my password" flow was never written. Sign-in happens either via Google/Apple or via a single-use link with a 15-minute lifetime. The raw code inside that link exists only in the e-mail sent to you; our database stores only its irreversible SHA-256 hash. Session-refresh records are protected the same way.
We do not process special-category personal data (health, religion, biometrics, union membership, etc.). We also do not process payment information, because no payment is ever collected.
3. Purposes for which we process personal data
- Creating your account and signing you in — your e-mail address is the account's identity; this is how we prevent the same person from opening a second account through a different sign-in method.
- Running the game — recording your predictions, locking them when the match starts, and scoring them once the match ends.
- Building the leaderboards — showing your display name and score on the general and group leaderboards.
- Operating groups — creating a group, joining one via an invite code, and group-level standings.
- Preventing abuse and maintaining security — detecting spam, automated requests, and stolen sessions via the IP recorded on magic-link requests and session refreshes.
- Enforcing community rules — reviewing display names that appear inappropriate, examining user reports, and suspending an account where necessary.
- Resolving disputes and preserving the accuracy of results — the prediction-change trail and the administrator action log make it possible to review "my points were calculated incorrectly"-type disputes retroactively.
- Fulfilling our legal obligations — responding to duly made requests from competent authorities.
- Measuring site usage — only if you consent to analytics cookies; to see in aggregate which pages are used and to improve the site.
We do not use your personal data for marketing purposes, we do not profile you, and we do not sell it to any third party.
4. Legal grounds
| Processing | Legal ground under KVKK |
|---|---|
| E-mail, display name, avatar, predictions, group memberships — operating the account and the game | Art. 5/2-(c): Directly related to the conclusion or performance of a contract |
| Showing the display name to everyone on the leaderboard | Art. 5/2-(c): Inherent to the nature of the service; the leaderboard is the game itself |
| IP logging, session security, spam and abuse detection | Art. 5/2-(f): The data controller's legitimate interest — the security and sustainability of the service |
| Display-name moderation, user reports, account suspension | Art. 5/2-(f): Legitimate interest — protecting users from harassment and spam |
| Prediction-change trail and administrator action log | Art. 5/2-(e): Necessary for the establishment, exercise, or protection of a right |
| Anonymized data remaining after an account-deletion request | Anonymized data is not considered personal data (KVKK Art. 28); see Section 8 |
| Responding to requests from competent authorities | Art. 5/2-(ç): Fulfillment of a legal obligation |
| Non-essential cookies (analytics and advertising cookies) | Art. 5/1: Explicit consent (see Cookie Policy) |
5. How we collect personal data
We collect personal data entirely through automated means, directly from you:
- Because you provide it: your e-mail address at sign-in, your display name if you later change it, the predictions you make, the groups you create or join, and the user reports you submit.
- Through an identity provider: if you choose to sign in with Google or Apple, those providers pass us your verified e-mail address, your name, and (if available) your avatar address. You see which information will be shared when you confirm the sign-in.
- Automatically, by technical necessity: your IP address, when a magic link is requested and when a session-refresh record is created.
You never need to fill in a form, answer a survey, or upload a document to use Praedix; no such function exists.
6. Transfer of personal data
6.1 Domestically
Your data is stored in a data center in Germany, on a server we lease ourselves.
Backups: The database is backed up automatically every day. Backups are encrypted and kept in two locations — one on the server itself (Germany), and one in Turkey, on the data controller's own server. The purpose of the second copy is the possibility of losing the primary server entirely; the copy travels encrypted and stays encrypted — the decryption key does not exist on that machine. Because this copy is located in Turkey, it is not a cross-border transfer, nor is it given to any third party.
The hosting provider is Hetzner Online GmbH, with its data center in Germany.
Because the server is not located in Turkey, the hosting itself also qualifies as a cross-border transfer; its basis is the standard contract described in 6.2.
Your display name and score are public on the leaderboards — this is not a transfer but the service itself; as a consequence, however, these two pieces of information can be seen by anyone who visits the site.
Your predictions are visible to your group-mates. Other members of a group you belong to can see what you picked for a match once that match has locked. Before a match locks, no one can see your pick. This visibility is confined strictly to the groups you belong to: users who are not members of your group, and every other visitor to the site, cannot see your predictions.
Your e-mail address, IP address, and avatar address are never shown to any user.
6.2 Internationally
| Recipient | What it receives | Why | Location |
|---|---|---|---|
| Hetzner Online GmbH | All data the application holds (the server and database run here) | Hosting of the service | Germany (EU) |
| Resend | Only your e-mail address and the content of the e-mail containing the sign-in link | Sending sign-in e-mails. Sender address: giris@praedix.app |
Ireland (EU) — company headquartered in the US |
| Google (sign in with Google) | Authentication traffic, since you initiate the sign-in | Authentication — only if you choose this method | US / global |
| Apple (sign in with Apple) | Authentication traffic, since you initiate the sign-in | Authentication — only if you choose this method | US / global |
| Google (Gemini API) | Only your display name — no e-mail, IP or account ID | Display-name suitability check (flagging inappropriate names for administrator review). Under the terms of Google's free tier, this content may be used to improve Google's products | US / global |
| Google AdSense | Data collected via advertising cookies (device, browser, approximate location, etc.) | Ad delivery and measurement — only if you consent to cookies | US / global |
| Google Analytics 4 | Usage data collected via analytics cookies (pages visited, device/browser type, approximate location). Account ID, e-mail, and display name are not sent | Aggregate measurement of site usage — only if you consent to analytics cookies | US / global |
A note about Resend: The service is configured so that e-mails are processed in Ireland; your sign-in e-mails are processed within the European Union and are not sent to the US. Nevertheless, because Resend itself is a US-headquartered company, the transfer continues to be assessed under KVKK Art. 9 — choosing the processing region does not remove this obligation, it only determines where the data is physically processed.
These transfers are carried out under KVKK Art. 9, on the basis of a standard contract. The basis for the transfer is not your explicit consent: because the sign-in e-mail is necessary for the service to function, a consent mechanism whose refusal would shut the service down entirely was deliberately not chosen.
Advertising and analytics cookies are separate from this and are subject to explicit consent (see Sections 6.4 and 6.5); refusing them does not disable any function of the game.
The standard contracts have been signed with Hetzner and Resend and notified to the Board under KVKK Art. 9. There is no separately signed standard contract with Google (Gemini API) for the display-name check; this transfer is limited to your display name and is governed by Google's terms of service.
6.3 Where we do not transfer personal data
We want to state these explicitly:
- We pull match fixtures and the data used in score calculations from external services. No personal data whatsoever is sent to these services; the data flow is one-directional — we only receive match information from them. They have no way of learning who you are, what you predicted, or that you use the site.
- The first layer of display-name moderation (the rule check) runs on our own server and calls no external service. In the second layer, only your display name is sent to Google's Gemini API (see 6.2); no other personal data is sent.
- We do not transfer your personal data to any third party for advertising, marketing, or data-sale purposes.
6.4 Advertising (Google AdSense)
The site displays Google AdSense advertisements. This means Google processes personal data through its own advertising cookies.
- Advertising cookies are not essential. They are placed only with your explicit consent; a cookie preference panel is shown on your first visit to the site.
- You may choose not to consent. If you decline, no advertising cookie is placed; no function of the game is disabled — you can still sign in, submit predictions, and view the leaderboards.
- You can change your preference at any time.
- In this context, Google acts as an independent data controller and its own privacy policy applies.
Apart from displaying advertisements, we do not transfer your personal data to any third party for advertising, marketing, or data-sale purposes. Your predictions, your score, and your group memberships are never used for ad targeting and are never sent to Google.
The names, durations, and purposes of the cookies Google places in this context are determined by Google and published in Google's own cookie list; we cannot alter that list. Details on advertising cookies are in Section 3 of the Cookie Policy.
6.5 Analytics (Google Analytics 4)
Google Analytics 4 is used to measure how the site is used in aggregate.
- Analytics cookies are not essential and are placed only with your explicit consent; the cookie preference panel asks about them separately from advertising cookies.
- You may choose not to consent. If you decline, the measurement script is never loaded; no function of the game is disabled.
- You can change your preference at any time; when you withdraw your consent, the analytics cookies are deleted from your browser.
- No information about your account is sent to Google Analytics; your IP address is not stored in Google Analytics.
- In this context, Google acts as a data processor, processing data on our behalf.
Details are in Section 4 of the Cookie Policy.
7. Retention periods
| Data | Period |
|---|---|
| Hash of the magic-link code | Expires 15 minutes after creation; used and expired records are deleted within 30 days |
| Session-refresh records (including IP) | For the duration of the session; canceled or expired records are deleted after 90 days |
| IP address on a magic-link request | Deleted after 6 months. Its sole purpose is abuse detection; retaining it longer serves no further purpose |
| Account data (e-mail, display name, avatar) | For as long as the account is open; anonymized as described in Section 8 upon an account-deletion request |
| Predictions and score history | Remain indefinitely even after anonymization (see Section 8) |
| User reports | Deleted 2 years after the report is closed — longer than a single season, so repeated abuse can be identified |
| Administrator action logs | 5 years. This record is the only means of resolving score disputes; a dispute can arise seasons later |
| Sign-in and security event logs (including IP) | Deleted after 180 days, the same commitment as for IP addresses (6 months) |
| Application error logs | Warnings are deleted after 30 days, errors after 90 days |
| Usage data in Google Analytics | Deleted in Google Analytics after 2 months. Analytics cookies in your browser last at most 13 months or are deleted when you withdraw your consent |
| Database backups | The copy on the server: 30 days; the second copy in Turkey retains the 15 most recent backups, with the oldest dropped as a new one arrives. Deletion/anonymization requests are not applied retroactively to backups that have not yet expired; backups fall out of the cycle on their own |
Prediction-correction records (the trail of an administrator's intervention) are subject to the same period as administrator action logs: 5 years.
These periods are enforced automatically: a cleanup job that runs every night deletes expired records, and every run leaves an auditable log entry. Deletion upon expiry requires no request.
8. Account deletion and anonymization
We write this section deliberately in plain terms, because it matters that a "deletion" request fully explains what actually happens.
When you request that your account be deleted, your account record is not completely removed from the database; it is anonymized. Specifically:
- Your e-mail address is replaced with a value that does not reveal your identity,
- Your display name becomes "Deleted user",
- Your avatar address is deleted,
- Your Google/Apple/e-mail identity links are deleted,
- All of your sessions are terminated.
As a result, the account can never be accessed again. If you later sign in again with the same e-mail address, a brand-new account is created from scratch; your old predictions and scores are not linked to that account.
Why the record is not deleted entirely: Predictions and score history remain, but detached from your identity. There are two reasons: (1) so that past match-day leaderboards are not retroactively distorted — if one user's predictions were deleted, everyone's rank on that match day would shift; (2) so that result disputes can still be resolved. Because the remaining data can no longer be linked to your identity, it no longer qualifies as personal data.
How to request it: Instantly, via the "Delete my account" button on your profile page. The request is not queued; the button runs the anonymization described above immediately. Alternatively you may write to kvkk@praedix.app — this route is completed within 30 days at the latest.
9. Your rights under KVKK Art. 11
By applying to the data controller, you have the following rights:
- To learn whether your personal data is being processed,
- If it is, to request information about that processing,
- To learn the purpose of the processing and whether the data is used consistently with that purpose,
- To know the third parties, domestic or foreign, to whom your data is transferred,
- To request correction if it has been processed incompletely or incorrectly,
- To request its deletion or destruction under the conditions of KVKK Art. 7,
- To request that any correction, deletion, or destruction be notified to the third parties to whom the data was transferred,
- To object to a result arising to your detriment that occurs solely through automated analysis of the processed data,
- To request compensation for damage suffered due to unlawful processing.
How to apply. All of the channels listed in the "Communiqué on the Procedures and Principles Regarding Applications to the Data Controller" are valid:
| Channel | How | How your identity is verified |
|---|---|---|
| E-mail from your account's e-mail address | kvkk@praedix.app | Since it arrives from the address registered in our system, we do not ask for further documentation — this is the fastest route |
| Secure electronic signature | Signed document, kvkk@praedix.app | The signature verifies it |
| Mobile signature | Signed document, kvkk@praedix.app | The signature verifies it |
| In writing, in person, or through a notary | İstanbul / Ümraniye | Identity document / notary |
Praedix does not keep your full name or national identity number; we recognize your account solely by your e-mail address. This is why writing from your account's e-mail address is the most practical way for us to locate you, and it makes it unnecessary for us to request further documentation for your identity.
For the information your application should contain and sample wording, see the Data Subject Application Form page. Completing the form is not mandatory; a free-form application containing the same information is equally valid.
Timeframe and fee. Applications are resolved as soon as possible given their nature, and no later than 30 days. If processing involves an additional cost, a fee set by the Board's tariff may be charged; if the request arose from our own error, any fee charged is refunded.
Complaint. If your application is rejected, if you find the response insufficient, or if you receive no response within 30 days, you may lodge a complaint with the Personal Data Protection Board within 30 days of learning of the response, and in any case within 60 days of the date of your application.
Some requests do not require an application: changing your display name and deleting your account can be done instantly from your profile page (see Section 8).
10. Children's data
Praedix is intended only for users who have reached the age of 18. If you are under 18, do not create an account.
When you create your account for the first time, you are asked to explicitly declare that you are over 18 and that you accept these notices; you cannot use the application without declaring this. Your declaration is recorded together with its date and the version of the text you accepted.
We do not verify your age with a document. Requiring an identity document would mean collecting far more, and far more sensitive, personal data than this rule protects; in keeping with the principles of proportionality and data minimization, a declaration-based approach was adopted instead.
If we learn that an account belongs to a user under 18, we close the account and delete their personal data. You can report such a case to kvkk@praedix.app.
11. Changes to this notice
When we change this notice, we publish the updated version at this address and change the version date. For significant changes we additionally notify users through an in-app announcement; once the version changes, you cannot continue using the application until your acknowledgment is renewed — so it is not possible to miss a change.