Ferla Privacy Policy

Effective: 3 August 2026

Version: 3.0

Data controller

Name: 3AN CREATIVE STUDIO

Address: Kartaltepe Mah. Malazgirt Cad. No:10, B Blok Daire 134, 34295 Küçükçekmece / İstanbul, Türkiye

Country: Türkiye

Tax / registry no: 9960463053

KEP (registered e-mail, Türkiye only): None

VERBİS registration: Not required

EU representative (GDPR Art. 27): None

Contact for all privacy requests: info@ferla.app

1. What this policy covers

This policy explains what Ferla ("the app") collects, why, who it is shared

with, how long it is kept, and what you can do about it. It applies to the iOS

and Android apps published under the bundle identifier com.ferla.app and to

the Ferla backend services.

Ferla is a personal bookkeeping app. It is not a bank, and it does not

connect to your bank account.

2. Data we collect

Biometrics: if you turn on Face ID, Touch ID or fingerprint unlock, the check

happens inside your phone's own security chip. Ferla receives a yes/no

answer only. We never see, receive or store your fingerprint or face data.

We do not collect: your contacts, health data, browsing history, advertising

identifiers, precise background location, or bank login credentials.

3. Tracking and advertising

Ferla does no cross-app or cross-site tracking, shows no advertising,

and never sells or rents your personal data. The app does not use Apple's

App Tracking Transparency prompt because it has nothing to track.

4. Legal basis (GDPR Art. 6 / KVKK Art. 5)

Withdrawing consent stops future processing; it does not make earlier

processing unlawful.

5. Who processes your data (sub-processors)

AI providers do not use your data to train their models. AI requests go

through Ferla's own servers, carry only the context that the request needs, and

never carry your email address or password.

6. International transfers

Your account, records and analytics are hosted inside the European Union.

Some processing happens outside the EU and outside Türkiye, mainly in the

United States: AI answers, receipt reading, speech-to-text, spoken replies,

subscription checks, and app updates. This means that when you use the

assistant, scan a receipt or speak to Ferla, that request leaves the country.

• GDPR (Art. 44–49): transfers rest on the providers' Standard Contractual

Clauses and their data processing agreements.

• KVKK (Art. 9): these transfers are made on the basis of your **explicit

consent** for the optional features (assistant, receipt scan, voice), and on

standard contract undertakings for the rest. If you never use the AI features,

no personal data of yours goes to those providers.

• If you do not want data leaving the country, do not enable the assistant,

receipt scanning or the voice features; every other feature keeps working.

7. Security

• All traffic is encrypted in transit; stored data is encrypted by the hosting

provider.

• Every database table has row-level access rules: one account cannot read

another account's rows.

• Sign-in keys are kept in the phone's secure hardware store (iOS Keychain /

Android Keystore), never in plain files.

• The app can be locked with Face ID, Touch ID, fingerprint or a device

passcode.

• Crash reports are stripped of personal details before they are sent.
• No security is perfect. If a breach affects your rights we notify you and the

competent authority within 72 hours (GDPR Art. 33–34; KVKK: without undue delay).

8. Your rights

Under KVKK Art. 11 and GDPR Art. 15–22 you can, at any time and free of charge:

How to apply: send your request to info@ferla.app from the email

address on your account, or in writing to the postal address at the top of this

document. We reply within 30 days (KVKK Art. 13). We do not charge for this,

unless a request is clearly excessive or repetitive.

Ferla does not make any decision about you that produces a legal or similarly

significant effect purely by automated means.

9. Children

You must be at least 16 years old to create a Ferla account. This single

threshold is used in every country, because it is the highest age of digital

consent under GDPR Art. 8 and it is above the US COPPA threshold of 13.

Ferla is not directed at children, and we do not knowingly collect data from

anyone under 16. If a parent or guardian believes a child has created an

account, write to info@ferla.app and we will delete the account and its

data.

10. Analytics consent and cookies

The app is not a website and sets **no advertising cookies and no tracking

pixels**.

The only optional measurement is product analytics (PostHog). It is **off until

you say yes**: on first launch a plain-language card asks whether Ferla may

collect anonymous usage statistics, with a clear decline option. Declining

changes nothing about the app. You can change your answer at any time in

Settings → Privacy, and turning it off stops collection immediately.

Analytics events carry only an anonymous identifier plus non-personal context

(which screen, which feature). Amounts, names, notes and email addresses are

stripped automatically before anything is sent.

Aggregate statistics and benchmarks

If you have given analytics consent, we may also combine those measurements into

aggregate statistics — for example what share of people reach a savings goal,

or how spending typically spreads across categories — and use them to improve

Ferla and to show anonymous comparisons inside the app ("people with a similar

income save about X%").

These statistics describe groups, never a person. They are produced from data

that has been aggregated and stripped of identifiers first, and the result cannot

be traced back to you or to any single user. Withdrawing your consent stops your

data feeding new statistics; figures already aggregated contain nothing personal

and therefore cannot be unmixed.

We do not use the content of your transactions, notes, receipts or assistant

conversations to train artificial-intelligence models — neither ours nor anyone

else's. Our AI providers are contractually barred from training on what we send

them (see section 5).

11. Changes to this policy

If this policy changes in a way that matters, we show a notice inside the app

before the change takes effect, and we update the version number and the

effective date at the top. Older versions are kept on request.

12. Contact

info@ferla.app — we answer within 30 days.