Privacy Policy

Effective 21 August 2026 · Covers the Modella iOS app and modella.savaskoc.de

Summary

• Modella has no accounts. Photos, generated images and created models stay on the user's iPhone.
• The app sends images to an AI provider only when the user starts a generation, and only to produce that image.
• Credits are tracked under a pseudonymous ID, not under a name or e-mail address.
• Anonymous usage statistics are collected. No photos or measurements are part of them.

1. Who is responsible

Savaş Koç, sole developer, Türkiye ("the Developer") operates the Modella app and this website. Contact: s.wie.savas@gmail.com.

The Developer is the data controller (veri sorumlusu) under Türkiye's Personal Data Protection Law No. 6698 ("KVKK"). This notice is the information KVKK Article 10 requires. For users in the European Economic Area (EEA) and the United Kingdom, the Developer is also the controller under the GDPR and UK GDPR.

In this notice, "user" means the person using the app, and "provider" means a company that processes data on the Developer's behalf.

2. Data that stays on the device

Modella has no user accounts. The app stores garment photos, generated try-on images and user-created models (photo, gender, body measurements) only on the user's iPhone. The Developer cannot access them. Deleting the app deletes this data.

3. Data sent for image generation

When the user starts a try-on or creates a model, the app sends the images involved and a text prompt to an AI image provider. The provider returns the generated image.

• For a try-on: the selected model image and one to four garment photos.
• For "My Models": the user's own photograph, plus the gender and the height, weight, bust, waist and hip measurements the user entered. This is the user's likeness and body data.

Purpose: producing the image the user requested. Legal basis: KVKK Art. 5(2)(c) — processing needed to perform the requested service (GDPR Art. 6(1)(b)).

The Developer does not store any image on a server. The app sends nothing unless the user starts a generation.

4. Purchases and credits

Generations cost credits. RevenueCat holds each user's credit balance under an app user ID. This ID is a stable pseudonymous value supplied by AIProxy: either a value derived from the user's App Store purchase, or a random value saved in the user's iCloud key-value store. It lets the balance survive a reinstall and follow the user's Apple account. The Developer never receives the user's name, e-mail address or Apple ID.

The Developer's credits server at modella.savaskoc.de receives only this ID, the operation type ("photo" or "model") and a key that prevents double charging. It stores short markers for that purpose and nothing else — no images, balances or other personal data.

Apple processes payments. The Developer receives no payment details. Legal basis: KVKK Art. 5(2)(c) (GDPR Art. 6(1)(b)).

5. Usage statistics

The app sends anonymous usage events to TelemetryDeck — for example "generation started", "generation failed", "result saved", "paywall shown" with the screen that opened it, or "purchase completed" with the product name. TelemetryDeck identifies devices only by a one-way scrambled value (a salted hash) that cannot be turned back into the device. The events contain no images, measurements or identifiers that lead back to the user.

Legal basis: KVKK Art. 5(2)(f) — the Developer's legitimate interest in knowing whether the app works (GDPR Art. 6(1)(f)).

6. Who receives data

• AIProxy (Optimize Fitness, Inc., USA) — forwards generation requests and checks that they come from a genuine copy of the app (Apple DeviceCheck).
• OpenRouter (USA) and Google (Gemini image model) — generate the image from the submitted photos and prompt.
• RevenueCat, Inc. (USA) — credit balances and purchase status.
• Cloudflare, Inc. (USA) — hosts the website and the credits server.
• TelemetryDeck GmbH (Germany) — anonymous usage statistics.
• Apple — payments and the App Store, as an independent controller.

7. Transfers outside Türkiye

The providers above process data in the United States and Germany. Under KVKK Art. 9, these transfers rely on the safeguards available for each provider: standard contracts published by the Personal Data Protection Board, or the provider's own commitments. Where no such safeguard applies, the transfer relies on the user's explicit consent. The user gives that consent by starting a generation or a purchase after reading this notice.

For EEA and UK users, transfers rely on the EU Standard Contractual Clauses or the EU–US Data Privacy Framework.

8. How long data is kept

• Images and models on the device: until the user deletes them or the app.
• Generation requests: only for the duration of the request, under the AI providers' own terms. The Developer keeps nothing.
• Credits server markers: the free-credits marker is kept permanently so free credits cannot be claimed twice; spend markers expire after 30 days.
• RevenueCat records: as long as the app user ID exists.
• Usage statistics: as aggregated, anonymous data.

9. Permissions

The app asks for camera access to photograph garments or the user, and for permission to add images to the photo library when the user saves a result. Both are optional. The user can change them in iOS Settings at any time.

10. Website

modella.savaskoc.de is a static website. It sets no cookies, uses no analytics and loads no third-party content. Cloudflare processes server request data as needed to deliver and secure the site.

11. The user's rights

Under KVKK Art. 11, the user may:

• learn whether their personal data is processed, and request information about it;
• learn the purpose of processing and whether the data is used for that purpose;
• learn which third parties receive the data, in Türkiye or abroad;
• request correction of incomplete or inaccurate data, and deletion or destruction of data;
• request that those corrections and deletions are passed on to third-party recipients;
• object to a result produced solely by automated analysis;
• claim compensation for damage caused by unlawful processing.

EEA and UK users also have the GDPR rights to restriction of processing, data portability and objection.

Because the app has no accounts, the user controls most data directly on the device. For data held under the app user ID, the user can write to s.wie.savas@gmail.com and include that ID. The Developer answers within 30 days, as KVKK Art. 13 requires.

The user can complain to the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu) or, in the EEA or UK, to the local supervisory authority.

12. Children

Modella is rated 4+ on the App Store. Purchases require an Apple account, which Apple restricts by age. The Developer does not knowingly process personal data of children under 13 (under 16 in the EEA); the user's own photo and measurements are only used when the user creates a model.

13. Changes

The Developer publishes any changes to this policy at modella.savaskoc.de/privacy with a new effective date.