Privacy Policy

1. Introduction

Welcome to As a List ("we," "our," or "us"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains how we collect, use, disclose, safeguard, and otherwise process your information when you use our mobile application ("App").

2. Information We Collect

We collect information that you voluntarily provide to us:

• Personal Information: Name, email, usernames, passwords, contact preferences.
• Location Data: If you grant permission, we collect approximate location (coarse location) to recommend nearby lists and allow you to tag your lists with a location. We do not collect or store precise location data.
• User Content: Lists, tasks, notes, comments, and other content you create.
• Device Information: We collect device details (e.g., model, OS version, unique identifiers) to help secure your account and detect unauthorized logins.
• Media: If you grant permission, we access your camera or photo library to allow you to attach images.
• Purchase Information: If you subscribe to premium features, your purchase history and subscription status are processed by Apple App Store, Google Play Store, and our payment partner RevenueCat. We do not store your payment card details.

3. How We Use Your Information

We process your data based on valid legal grounds (UK GDPR / GDPR / KVKK / CCPA / Australian Privacy Act 1988):

• Contractual Necessity: To create your account, provide the Service, and manage your subscription.
• Legitimate Interest / Business Purpose: To secure our App (e.g., using device info to prevent fraud/unauthorized access) and improve performance.
• Consent: Where you have explicitly agreed (e.g., camera access, ad tracking).

4. Advertising & Tracking

Our free tier displays advertisements powered by Google AdMob. To show relevant ads, we may collect:

• Advertising Identifier (IDFA/GAID): Only with your explicit consent via the App Tracking Transparency prompt (iOS) or device settings (Android).
• Ad interaction data: Impressions, clicks, and ad performance metrics.

You can opt out of personalized ads at any time:

• iOS: Settings → Privacy & Security → Tracking
• Android: Settings → Google → Ads → Opt out of Ads Personalization

Premium subscribers do not see any advertisements.

5. Behavioral Analytics

With your explicit consent, we collect anonymous usage analytics to understand how the App is used and to improve your experience.

What we collect:

• Screen views (which pages you visit)
• Feature interactions (taps, scrolls, searches)
• Session duration and frequency
• Device type and OS version
• Subscription tier (free or premium)

What we do NOT collect:

• Your name, email, or any account details
• Your lists, items, comments, or any user-generated content
• Your contacts or photos (unless attached to a list)

Legal basis: Your explicit consent (GDPR Art. 6(1)(a) / KVKK md. 5/1). Analytics are disabled by default and only activated if you choose to opt in, either through the in-app prompt or via Settings → Privacy & Account → Usage Analytics.

Data retention: Analytics events are automatically deleted after 90 days.

Opt out & data erasure: You can disable analytics at any time from Settings. When you disable analytics, all previously collected data is permanently deleted. If you delete your account, all analytics data is also purged.

Service providers: Analytics data is processed via Firebase Analytics (Google) and Supabase (database). Both process data in accordance with their respective privacy policies and GDPR Data Processing Agreements.

6. In-App Purchases & Subscriptions

We offer premium subscription plans processed through Apple App Store and Google Play Store. Subscription management is facilitated by RevenueCat, Inc.

• Data shared with RevenueCat: Anonymous user identifier, purchase receipts, subscription status, and device type.
• Data NOT shared: Your name, email, or any personal content.

RevenueCat processes this data in accordance with their Privacy Policy.

Subscription payments are handled entirely by Apple/Google — we never receive or store your payment card information.

7. Publicly Shared Information & Web Accessibility

Please note that any content (lists, comments, profile information) that you voluntarily disclose for public viewing on the App becomes available to the public — both within the App and on the web.

• Web Access: Public lists may be accessible via unique web URLs (e.g., asalist.com/list/...) and may appear in search engine results.
• Social Previews: When shared on social media or messaging platforms, public lists generate preview cards (Open Graph images) that display the list title, description, and cover image.
• Embedding: Public content may be indexed by search engines, social media crawlers, and link preview services.

Once shared publicly, this content may be read, collected, cached, and used by others, including third-party services. We urge you to be careful about personal information when using social or sharing features. You can change a list's visibility to private at any time to remove web access.

8. AI-Powered Features

We use artificial intelligence to enhance your experience. When you use AI-powered features, your content is processed as follows:

• Translation & Correction: When you use automatic translation or text correction, your list content is sent to third-party AI providers (such as Google Gemini) for processing. This content is transmitted securely and is not stored by these providers beyond the processing session.
• AI List Creation: When you use AI-assisted list creation tools, your prompts and preferences are processed by AI providers to generate content.
• Content Analysis: We may analyse aggregated, anonymised content patterns to improve our AI features and recommendations.

Important: We do not use your private content to train external AI models. Your content is only sent to AI providers when you actively use an AI feature. Private lists are never shared with AI providers unless you explicitly trigger an AI action on that content.

AI providers we use:

• Google (Gemini) — subject to Google's AI terms and data processing agreements.

9. Information Sharing

We prioritize your privacy. We do not sell your Personal Information (name, email, etc.) to third parties.

However, we may share aggregated, anonymized, or de-identified data (which cannot reasonably be used to identify you) with third parties for purposes such as:

• Research and market analysis.
• Training artificial intelligence and machine learning models.
• Improving our Service and features.

Service providers we use:

• Supabase (database hosting)
• Firebase (analytics, crash reporting, push notifications)
• Google AdMob (advertising — free tier only)
• Google Gemini (AI features — translation, correction, generation)
• RevenueCat (subscription management)
• Apple/Google (in-app purchase processing)

10. International Data Transfers

Your data may be transferred to and processed in countries outside your country of residence, including the United States, where our service providers operate. We ensure appropriate safeguards are in place:

• UK/EU: Standard Contractual Clauses (SCCs) or adequacy decisions.
• Australia: We ensure overseas recipients comply with the Australian Privacy Principles (APPs).

By using the App, you consent to such transfers in accordance with applicable law.

11. Data Security

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, no electronic transmission over the Internet can be guaranteed to be 100% secure.

12. Your Rights

Depending on your location, you have the following rights:

UK & EU (GDPR / UK GDPR):

• Access, rectify, or erase your personal data
• Restrict or object to processing
• Data portability
• Withdraw consent at any time
• Lodge a complaint with the ICO (UK) or your local supervisory authority

California (CCPA/CPRA):

• Know what personal information is collected
• Request deletion of your data
• Opt-out of the sale of personal information (we do not sell your data)
• Non-discrimination for exercising your rights

Australia (Privacy Act 1988):

• Access and correct your personal information
• Complain to the OAIC if you believe we have breached the APPs

Türkiye (KVKK):

• Access, correct, or request deletion of your data
• Object to automated decision-making

You can manage your account settings and delete your account directly within the App.

13. Data Retention

We retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. If you delete your account, your data will be permanently deleted from our active databases within 30 days, except where we are required to retain it for legal obligations.

14. Children's Privacy

We do not knowingly solicit data from or market to children under 13 years of age (or 16 in the UK/EU).

15. Updates to This Policy

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date. We will notify you of material changes via in-app notification or email.

16. Contact Us