CanSayNo Privacy Policy

Last updated: 8 November 2026

This policy explains how your personal data is processed when you use the CanSayNo mobile app (the "App"). It serves as the privacy notice under the EU General Data Protection Regulation ("GDPR"). It is also the information notice under Turkish Law No. 6698 on the Protection of Personal Data ("KVKK").

1. Controller

2. Data we process

Data Examples Source
Account data First name, last name, email address, password (stored only as an irreversible hash) You, at sign-up
Practice content Messages you write in practices, the AI character's replies, evaluation scores and feedback Created while you use the App
Progress data Number of practices, streak, points (XP), level, badges, daily usage count Created while you use the App
Subscription data Subscription product, status, start/end dates, store transaction IDs App Store / Google Play via RevenueCat. We never receive your card details.
Security logs IP address, device/browser information (user agent), device name, sign-in attempts, session records Created automatically when you sign in and use the App

We do not collect location, contacts, photos, microphone data or advertising identifiers. The App contains no ads, analytics or tracking tools. We do not sell your data or share it for advertising.

Reminder notifications are scheduled entirely on your device. Your preference and reminder time stay on the device and are not sent to us.

Tip: Avoid writing real people's names, health information or other sensitive details in practices. Scenarios are fictional and do not need real details.

Purpose Legal basis (GDPR Art. 6 · KVKK Art. 5/2)
Creating your account, signing you in, sending verification and password reset codes Performance of a contract (6(1)(b) · 5/2-c)
Running practices with the AI character and evaluating them Performance of a contract (6(1)(b) · 5/2-c)
Showing your progress, streak and badges Performance of a contract (6(1)(b) · 5/2-c)
Recognising and maintaining your premium subscription Performance of a contract (6(1)(b) · 5/2-c)
Account security and abuse prevention (rate limits, suspicious sign-in detection) Legitimate interests (6(1)(f) · 5/2-f)
Legal obligations and potential disputes Legal obligation; establishment, exercise or defence of legal claims (6(1)(c), 6(1)(f) · 5/2-ç, 5/2-e)

4. Who we share data with (international transfers)

We share only what is needed to run the App:

Provider Purpose Data shared Location
Anthropic PBC (Claude) Generating character replies and evaluations Your practice messages and scenario information. Your name and email are not sent. USA
RevenueCat Inc. Managing subscription status Your numeric account ID, subscription and transaction data USA
Apple / Google In-app purchases The store runs the purchase and processes payment details USA / EU
Hetzner Online GmbH App server and database All data described here Germany (EU)
Brevo SAS Verification and password reset emails Your email address, name, one-time codes France (EU)

Anthropic states that it does not use data sent through its API to train its models and retains it only for a limited period.

Transfers outside your country are made with appropriate safeguards: standard contractual clauses and the providers' data processing agreements.

Apart from the providers above, your data is disclosed to competent authorities only when the law requires it.

5. Retention

6. Your rights

You have the right to:

Send requests to info@factech.app from the email address registered to your account. We reply within 30 days.

7. Security

8. Age

The App is not intended for anyone under 16. If we learn that an account belongs to someone under this age, we delete it.

9. Changes

When we update this policy, the "Last updated" date changes. We announce significant changes in the App or by email.

10. Contact

info@factech.app