MirrorUp Privacy Policy
Summary. MirrorUp does not collect, store or transfer any personal data from its users. There is no server operated by the Developer, no user account system, no advertising network and no analytics tool. All content created in the Application remains on the user's own device. The text below sets out the details and the exceptions.
1. Controller and scope
1.1. This Privacy Policy (the "Policy") applies to the mobile and web application named MirrorUp (the "Application").
1.2. The developer of the Application, [Developer name] (the "Developer"), acts as the controller within the meaning of the EU General Data Protection Regulation ("GDPR") and as the data controller within the meaning of Turkish Law No. 6698 on the Protection of Personal Data ("KVKK").
1.3. The Policy covers processing activities that occur in the course of using the Application. The privacy policies of independent third-party services, such as the application store, remain reserved.
2. Definitions
2.1. Personal data means any information relating to an identified or identifiable natural person.
2.2. Device means the phone, tablet or computer on which the Application is installed.
2.3. Local storage means that data is held solely on the Device, within the Application's own area (browser storage and IndexedDB).
3. Data processed, purposes and legal bases
3.1. The Developer does not collect personal data through the Application. The data listed below is processed solely on the Device and is not transmitted to the Developer or to any third party.
| Data | Purpose of processing | Where it remains |
|---|---|---|
| Camera image | Light metering, flash metering and scoring the sharpness of the ground-glass image | Device memory only, momentarily. Not saved unless the user takes a photograph. |
| Content entered by the user (gear selection, film log entries, notes, settings) | Delivery of the Application's core functions | Local storage |
| Photographs taken within the Application | The user's own archive; exposure information is written into the photograph's EXIF fields | Local storage and, at the user's choice, the Device gallery |
| Test log (optional) | Allowing the user to examine measurement accuracy | Local storage. Off by default; contains no photographs and no location; exportable only manually by the user. |
3.2. The camera permission serves the performance of a function expressly requested by the user, within the meaning of Article 6(1)(b) GDPR and Article 5/2-(c) KVKK. The user may withdraw it at any time through the operating system settings.
3.4. The Application does not request location permission and does not process location data.
3.3. Where the camera permission is not granted, the light meter, flash meter and focus score functions are unavailable; the remaining functions of the Application (depth of field, bellows compensation, film log, gear selection) continue to operate.
4. Transfers, including transfers abroad
4.1. The Developer does not transfer any user data to third parties, whether domestically or abroad.
4.2. The Application sends a request to exactly one third-party address: the camera photographs displayed on the gear selection screen are retrieved from Wikimedia Commons (thumb.wikimedia.org). In the course of that request, and as with any visit to any internet page, the Device's IP address and browser information are visible to that server. Such requests are subject to the Wikimedia Foundation's own privacy policy. Images are retained on the Device once displayed and are not requested again.
4.3. The typefaces used in the Application form part of the Application's own files; no connection is made to any font service.
4.4. The Application operates with all of its functions without an internet connection.
5. Advertising, analytics and profiling
5.1. The Application contains no advertising network, analytics tool, crash-reporting service or third-party software development kit (SDK).
5.2. User behaviour is not tracked, no profiling is carried out and no automated decision-making is applied.
6. Retention
6.1. As the Developer holds no user data, no retention period arises on the Developer's side.
6.2. Data on the Device remains there until deleted by the user or until the Application is uninstalled. Backing up that data is the user's responsibility; for this purpose the Application provides a backup function in Settings and issues periodic reminders.
7. Purchases
7.1. Where the full version of the Application is purchased, the payment is processed entirely through the Google Play infrastructure.
7.2. The Developer has no access to, and does not store, card details, billing addresses, names or comparable payment data. The Application has access only to the fact that a purchase has been made.
8. Security
8.1. As data does not leave the Device, risks arising during transmission do not apply.
8.2. The security of data on the Device relies on the application isolation provided by the operating system and on measures such as the screen lock. Users are advised to keep their Device updated and to use a screen lock.
9. Rights of the data subject
9.1. The rights under Articles 15-22 GDPR and Article 11 KVKK (access, rectification, erasure, objection to processing, data portability) remain reserved.
9.2. As the Developer holds no data relating to the user, a substantial part of these rights may be exercised by the user directly and without an intermediary:
- Access and portability: all data may be exported as a standard file from Settings → Backup.
- Erasure: uninstalling the Application, or clearing the Application's storage from the Device settings, permanently deletes all data.
- Objection to processing: the camera permission may be withdrawn at any time from the operating system settings.
9.3. Requests concerning this Policy may be sent to the contact address below. Requests are answered within thirty days at the latest, in accordance with Article 13/2 KVKK.
10. Children's data
10.1. The Application is not directed at children and collects no personal data, including age.
11. Changes to this Policy
11.1. This Policy may be updated where necessary. In the event of an update, the effective date and version number on this page are amended.
11.2. Where a material change is made to processing activities, the change is also notified to the user within the Application.
12. Contact
12.1. For all questions, requests and notifications concerning privacy: mirrorup.support@gmail.com