PRIVACY POLICY
Welcome to the reload.app website (the “Site”).
Reload is committed to protecting the personal data of people who use the Site. This notice describes how we process personal data and, where required, the legal bases we rely on. It is intended to align with the EU General Data Protection Regulation 2016/679 (“GDPR”) and other applicable privacy laws. For information about cookies and similar technologies, please see our Cookie Policy.
1. Data controller
The data controller is Reload, with registered office at Maslak Mah. AOS 55. Sk. 42 Maslak B Blok No: 4, İç Kapı No: 540, Sarıyer/İstanbul, Türkiye (hereinafter, “Reload” or the “Data Controller”). You can contact the Data Controller at can@reload.app.
2. Types of data collected and purposes of processing
Depending on how you use the Site, the following categories of personal data may be collected and processed:
(a) Identity and contact details you provide when you register on the Site, subscribe to updates, join a waitlist, or create an account where such features are offered (for example, name, email address, company, and similar fields).
(b) Content you upload or send through the Site, such as files, messages, or other materials attached to forms, solely to handle your request or provide the requested service.
(c) Data you provide in connection with purchases, billing, or other contractual steps (for example, billing details and transaction records), to perform the contract and comply with accounting, tax, and other legal obligations.
(d) Data collected when you contact us by email or through the Site (including the content of your message and technical metadata such as timestamps), to respond to enquiries and provide support.
(e) Data used for direct marketing, such as sending newsletters or promotional communications about Reload’s products and services, where permitted by law and, where required, based on your consent or soft opt-in rules that apply.
(f) Data used for analytics, product improvement, and aggregated statistical research (for example, usage metrics where not governed solely by our Cookie Policy).
3. Legal basis of the processing
Except for data collected through cookies or similar technologies (which are described in the Cookie Policy), processing typically relies on:
- Contract and legal obligation — for processing described in points 2(a), 2(b), and 2(c), where necessary to perform a contract with you or to comply with legal duties connected to that relationship (including defence in legal proceedings where applicable).
- Legitimate interests — for processing described in point 2(d), where we have a legitimate interest in responding to enquiries, securing the Site, preventing abuse, and improving our communications, balanced against your rights.
- Consent — for processing described in points 2(e) and 2(f), where applicable law requires consent for marketing or certain analytics activities, or where we choose to rely on consent.
4. Data retention and methods of processing
Personal data are kept only for as long as needed for the purposes described above, unless a longer period is required or permitted by law. Indicative retention periods include:
- 2(a) — registration or account-related data: up to 24 months after the end of the subscription or a comparable period of account inactivity, unless a different period applies by law or contract.
- 2(b) — uploaded content tied to a specific request: typically deleted or anonymised once the request is completed, and in any case within a reasonable period not exceeding 24 months unless retention is required for legal claims or compliance.
- 2(c) — contractual and billing records: for as long as needed to fulfil the contract and meet legal obligations, generally up to 10 years where tax and accounting rules require longer storage.
- 2(d) — correspondence and support data: up to 24 months from the last relevant communication, unless a longer period is justified for ongoing disputes or compliance.
- 2(e) — marketing data: up to 2 years from the last relevant interaction or until you withdraw consent or object, whichever comes first, subject to local rules.
- 2(f) — analytics datasets: up to 2 years in identifiable form where not aggregated or anonymised earlier.
Processing is carried out using electronic and, where relevant, telematic tools, with measures designed to protect confidentiality, integrity, and availability of personal data in line with applicable law and good industry practice.
5. Compulsory or optional nature of the data
Apart from browsing data covered by the Cookie Policy, providing personal data for general enquiries or marketing is generally voluntary. Where you wish to use specific services (for example, purchases, account access, or file uploads offered on the Site), certain information may be necessary; without it, we may be unable to provide those services.
Categories of recipients of personal data
Personal data may be accessed or processed by:
- employees and consultants of the Data Controller acting under appropriate instructions;
- service providers (processors) that host the Site, provide email delivery, analytics, customer support tooling, or security services;
- payment processors or financial institutions, solely to the extent needed to process payments you initiate; and
- public authorities or private parties where we are legally required or expressly permitted to disclose information.
We may also disclose information to law enforcement or courts when required by applicable law or a lawful request, or where reasonably necessary to investigate misuse of the Site, protect the rights and safety of Reload, our users, or others, or defend legal claims.
6. Transfer outside the EU / EEA
We do not sell your personal data. Your data may be processed in countries outside your country of residence, including outside the European Economic Area. Where such transfers occur, we implement appropriate safeguards required by applicable law (such as standard contractual clauses or equivalent mechanisms), together with technical and organisational measures to protect the data.
7. Exercise of rights
Under the GDPR and similar laws, you may have the right to access, rectify, erase, restrict processing, object to certain processing, and receive a copy of your data in a portable format where technically feasible. Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
You may exercise these rights by contacting us at can@reload.app. You may also lodge a complaint with a data protection supervisory authority in your country of residence, place of work, or the location of an alleged infringement.
Changes. We may update this Privacy Policy from time to time. The “PRIVACY POLICY” heading above will show the document type; material changes will be reflected on this page with an updated effective date where we provide one, or by other appropriate notice where required by law.