Türkiye'deki kullanıcılar için: Türkçe Aydınlatma Metni · Gizlilik ve KVK Politikası · Kullanım Şartları

This Privacy Policy explains how Tuncan Technology & Consulting DOO (Podgorica, Montenegro), operating under the UGY and Viaworks brands (“we”, “us”), collects, uses, and protects information in connection with the UGY mobile application and the ugy.app website (together, the “Service”). UGY is a free event-discovery app that helps people find local events in Montenegro and Türkiye.

We are the data controller for the personal data described here. We process personal data in accordance with the Montenegro Law on Personal Data Protection and, for users in the European Economic Area, the EU General Data Protection Regulation (GDPR). Where the two differ, we apply the stronger protection to everyone.

1. Who we are & how to contact us

Controller: Tuncan Technology & Consulting DOO, Podgorica, Montenegro.
Privacy contact: privacy@ugy.app · General support: support@ugy.app

2. Information we collect

2.1 Account & profile information

• Your email address and, optionally, a display name (used to create and secure your account via Firebase Authentication).
• Your app language (Turkish, English, or Montenegrin) and the city you choose, so we can personalise your feed and choose which regional announcements to send you (see 2.3).
• If you chose event interests in an earlier version of the app, we keep them until we delete them from all accounts; the current app no longer asks for them.
• Your onboarding progress and app preferences, including your notification settings, when the app asked you to allow notifications and how you answered, and when your device's notification permission changed.
• The time you last opened the app and your device's time zone (for example, Europe/Istanbul), recorded when you open the app, so we can decide whether to send you weekly suggestions and come-back reminders (for example, only if you have not opened the app recently), send them at a suitable local time and not too often. We record these whether or not you allow notifications or analytics.
• Your optional profile photo, username (public @handle), and a short bio, if you choose to add them. Profile photos are stored in Firebase Cloud Storage.

2.2 Feedback you send us

If you send feedback from within the app, we store the message text together with your user identifier so we can understand and follow up on it.

2.3 Device permissions you grant

• Location (optional): if you allow it, we use your device location to show events near you. Your precise GPS location is processed transiently to find nearby events and is not stored on our servers. We store the city you select. If you have an account and use your device location, we also store the UGY city your location is in (in Montenegro, the nearest one), or the fact that it is in none of them, never your coordinates. We use these cities to choose which regional announcements to send you (see Notifications below); a city you have selected, even earlier, takes precedence. The city derived from your location is updated when the app gets a new location fix while you use your device location, kept if you later switch to choosing a city yourself, and deleted when the app next detects that you have withdrawn location permission, or when you delete your account.
• Calendar (optional, app versions before 0.2.2 only): if you allow it, you can add an event to your device calendar. This happens on your device; we do not read your calendar.
• Notifications (optional): if you allow notifications on your device, we store a push notification token (on Android, also a Firebase Cloud Messaging registration token) and may send you reminders and change alerts for events you RSVP to, weekly event suggestions, a reminder when you have not opened the app for a while (a come-back reminder), and announcements from UGY. Which country's announcements you receive is decided by the city you have selected; if you have not selected one, by the city derived from your location; and if you use your device location and we have no UGY city for you (for example because you are not in any of our cities, including when you are abroad), by your app language: Turkish for Türkiye, Montenegrin for Montenegro. In that case, with any other app language, you receive no regional announcements. Weekly suggestions and come-back reminders are sent only if you have selected a city. For these two, we use your time zone to send them at suitable local times and limit how many you receive; reminders and change alerts are timed to the event's local time. For all automatic notifications (all of these except announcements), we keep a history (see section 6). If you use the app without an account (as a guest), you may receive only weekly suggestions and come-back reminders, not announcements, and we keep the same records for them. You can turn notifications off at any time in your device settings. In app version 0.2.2 or later, you can also stop weekly suggestions and come-back reminders under Profile > Permissions > Weekly suggestions; this switch does not affect reminders for events you RSVP to or announcements. On Android 12 and earlier, the system allows notifications when you install the app; you can turn them off the same way.

2.4 Consent and notice records

When you accept our terms, privacy policy, or analytics, we keep an audit record (the type and version of what you accepted, the date, and the IP address at the time) so we can demonstrate compliance.

We also keep a record of each version of our legal documents (this policy, our Terms or the Turkish data-protection notice, the KVKK Aydınlatma Metni) that the app shows you, once for each place in the app where it is shown (for example the Age & Terms step, sign-up, or a one-time notice that a document has been updated): which document and version, the page address, your app language, where in the app it was shown and when it was first shown there. This record is not a consent; it shows that you were informed.

2.5 RSVPs & activity

The events you RSVP to (“interested” or “going”) within the app. If you allow notifications, we use them to remind you about these events and may tell you if one is cancelled or changes time. The notification text, such as an event's name, time and venue, passes through our notification delivery providers (see section 5).

2.6 Public event content (event sources)

UGY aggregates events that venues, promoters, festivals, and ticketing or listing platforms announce publicly on their own public websites, for example official venue and festival sites, tourism portals, and public event-listing and ticketing platforms. From each public source we extract only event-relevant information:

• the event title, description, date and time, and venue,
• the address of the event image, where available (the app loads the image from the source's own address),
• a link back to the original public source, and
• the ticket price and purchase link, where the source publishes them.

2.7 Usage analytics & diagnostics

• Analytics (PostHog): collected only if you consent in the app (analytics are off by default). We record a small set of in-app events, for example, app opens, completing onboarding, viewing or saving an event, performing a search, answering notification prompts, changes to your notification permission, and opening notifications (including, during a notification test, which test group you are in), to understand how the app is used and improve it.
• Notification use: separately from analytics, and whatever your analytics choice, we record when you last opened the app (used as described in 2.1) and when you open an automatic notification we sent you (used to measure how often notifications are opened).
• Error diagnostics (Sentry): if the app crashes or errors, we collect technical diagnostic data (device and app information, and an identifier to correlate the report) to fix problems. This is disabled in development builds.
• Website analytics (Google Analytics 4, on the ugy.app website): loaded through our cookie-consent tool (CookieYes) and active only if you accept analytics cookies. Analytics storage is denied by default (Google Consent Mode) until you consent. We use it to understand how the website is used and improve it.

2.8 Website waitlist

If you join the waitlist on the ugy.app website, we collect the email address you enter and your consent choices (agreeing to these terms, and optionally opting in to occasional product-update emails). We send a confirmation email to verify your address (double opt-in) and, once confirmed, use it only to notify you when UGY launches and to send the updates you opted into. You can unsubscribe at any time. Waitlist entries are stored on Cloudflare (Cloudflare D1) and confirmation and notification emails are sent via Resend.

3. How we use information

• To provide and personalise event discovery, including showing events near you.
• To create, secure, and manage your account.
• To send the notifications described in 2.3 if you allow notifications, to choose which regional announcements you receive, and to time, limit and measure them, which may include testing different notification frequencies or wording with groups of users and comparing how often each group opens notifications, turns notifications off or removes the app (which we infer when notifications can no longer be delivered).
• To aggregate publicly-posted event announcements into a single local discovery feed.
• To maintain compliance records, secure the Service, and fix bugs.
• With your consent, to measure and improve the app.
• To operate the ugy.app waitlist and let you know when UGY launches, if you sign up.

4. Legal bases for processing

• Performance of a contract: providing your account and the core Service.
• Consent: location, push notifications such as weekly suggestions, come-back reminders and announcements (you give this consent by allowing notifications on your device and can withdraw it in your device settings or, for weekly suggestions and come-back reminders, with the in-app Weekly suggestions switch in app version 0.2.2 or later), analytics, website waitlist sign-up, and any marketing. You can withdraw consent at any time.
• Legitimate interests: aggregating publicly-available business event announcements to offer a local event-discovery service, and keeping the Service secure and functional; if you allow notifications, sending you reminders and change alerts for events you RSVP to (you can stop them by turning notifications off or removing your RSVP); deciding whether, when and how often to send the notifications you allowed, limiting how often we ask you to allow notifications, avoiding duplicates, measuring how notifications are opened and testing improvements, for which we record when you last opened the app and your time zone; using the city derived from your device location (never your coordinates) to choose which country's announcements you receive; and, while you use your device location and no UGY city is known for you (also when you are outside our cities), using your app language to choose regional announcements. We balance these interests against your rights.
• Legal obligation: retaining consent records, and records of which version of our legal documents you were shown, where required.

5. Who we share information with

We do not sell your personal data. We use trusted service providers who process data on our behalf, under contract:

We may also disclose information if required by law or to protect the rights, safety, and security of our users and the Service.

6. How long we keep information

7. Your rights

Subject to applicable law, you have the right to:

• access the personal data we hold about you;
• correct inaccurate data;
• delete your data, in the app or via our Account & Data Deletion page;
• restrict or object to certain processing;
• receive your data in a portable format;
• withdraw consent at any time; and
• lodge a complaint with a supervisory authority.

To exercise these rights, email privacy@ugy.app. In Montenegro, the supervisory authority is the Agency for Personal Data Protection and Free Access to Information (AZLP). EEA users may also contact their local data protection authority.

8. Event organizers & source removal

If you organize an event whose public information appears in UGY and you would like it removed, email privacy@ugy.app or support@ugy.app. We honour valid removal requests within 7 days, process only publicly-published event information, and link back to the original public source.

9. International data transfers

Some of our providers process data outside Montenegro (for example, in the EU or the United States). Where data is transferred internationally, we rely on appropriate safeguards such as adequacy decisions or standard contractual clauses.

10. Children

UGY is not directed to anyone under 18, and we do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us data, contact privacy@ugy.app and we will delete it.

11. Changes to this policy

We may update this policy from time to time. We will post the updated version here and revise the “Last updated” date above. We also tell you about material changes in the app, with a one-time notice.

12. Contact

Tuncan Technology & Consulting DOO, Podgorica, Montenegro
privacy@ugy.app · support@ugy.app