Privacy Policy
Effective Date: 10 August 2025
Last Updated: 28 September 2026
This Privacy Policy explains how minisol ("we", "us", "our") collects, uses, discloses, and safeguards information when you use our mobile applications and related services (collectively, the "Apps"). This is a single policy that applies across all minisol Apps (for example Modly, Imagly AI and Nightcap); some features and data practices described here may not be present in every App. Where a feature is disabled or unavailable in a particular App, the related processing does not occur.
If you do not agree with this policy, please do not use our Apps.
1) Who we are & contact
Controller/Provider: minisol (operated via an individual developer account)
Contact email: umitcan@minisol.co
Postal address: Istasyon Mah. 1437. Sokak, Kocaeli / Türkiye
2) Information we collect
The types of data we may collect depend on the specific App and features you use.
A. You provide directly
- Account/profile info (if an App offers sign-in): name, email, display name, password (hashed), profile photo.
- Support messages and content you submit (tickets, feedback, bug reports, screenshots).
- User-generated content (UGC) if the App allows uploads or text input (for example images, photos of your home bar shelf, or text prompts you choose to submit to an AI feature).
- In-App preferences you set (for example the spirits and flavours you like in Nightcap, saved recipes and favourites).
B. Collected automatically
- Device and app info: device model, OS version, language/locale, time zone, App version, SDK versions, install and first-open timestamps, and a random App-generated user ID.
- Advertising identifier (IDFA on iOS) only if you grant permission through Apple's App Tracking Transparency prompt (see Section 5).
- Usage data: screens viewed, taps, session duration, feature interactions (for example that a recipe was opened or a subscription started), crash logs, and diagnostics.
- Approximate location (country/region) derived from IP address for fraud prevention and store/pricing purposes. Our product analytics (Mixpanel) is configured not to use IP addresses for location.
- Purchase metadata (non-card): in-app purchase receipts, subscription status, product identifiers, trial eligibility, renewal status.
C. From third parties (processors)
- RevenueCat (subscriptions & purchases): processes receipt data, the App-generated user ID and device/app identifiers to determine entitlement status. We do not receive your full payment card details.
- App distribution platforms (Apple App Store): may provide anonymized install and transaction signals.
- Mixpanel (product analytics; used in our newer Apps such as Nightcap): receives usage events together with the App-generated user ID and basic device information so we can understand how features are used and improve them. Data is stored in the European Union. We do not send precise location, contacts or photos to Mixpanel.
- Firebase Analytics / Crashlytics (if enabled in an App): may collect event/usage data, crash logs and device identifiers.
- Meta (Facebook) SDK (advertising measurement; used in Apps we promote with Meta ads, such as Nightcap): receives App events such as install, session start and subscription start so we can measure whether our advertising works. Whether your advertising identifier is included depends on your App Tracking Transparency choice (see Section 5).
- AI providers:
- AI image processing providers (for our AI photo Apps, such as Imagly AI) process the images you upload and generate edited/AI images on our behalf.
- OpenAI (OpenAI API) (for our AI text and recognition features, such as Nightcap's recipe suggestions and shelf scanner) processes the text you enter and, if you choose to scan, the photo you take, and returns a result to the App through our own secure server.
These providers retain the data they process only for a limited period (currently up to 30 days) for service delivery and abuse monitoring, are contractually limited to using it to provide the requested service to us, and do not use it to train their models.
Note: The exact services used can vary by App and may change over time. Where a service is not used in a given App, its related processing does not occur.
D. Photos, images, face data and AI inputs
For some of our Apps you can upload or capture photos (for example a portrait in Imagly AI, or a photo of your bottles in Nightcap) and enter text prompts:
- We only process these inputs to provide the requested feature (applying AI filters, generating images, recognising bottles on a shelf, suggesting recipes).
- Photos and prompts are sent only when you actively choose to use the feature. Our own servers forward them to the AI provider and do not keep a copy.
- We do not create or store face recognition templates, embeddings, or other biometric identifiers that could be used to recognize or track a person.
- We do not use photos, face data or prompts for identity verification, advertising, or user tracking.
- We do not sell your photos or prompts, and we do not use them to train our own or third-party AI models, unless we clearly ask for and obtain your explicit consent (which we do not currently do).
3) Why we use your information (purposes & legal bases)
We process data to:
- Provide and operate the Apps, features, AI results, and purchases/subscriptions (performance of a contract / legitimate interests).
- Maintain security, detect/prevent fraud and abuse (legitimate interests / compliance with legal obligations).
- Measure and improve performance and quality, fix bugs, and analyze usage (legitimate interests; for some regions we may rely on consent for analytics).
- Measure the effectiveness of our advertising (consent, given through Apple's App Tracking Transparency prompt; see Section 5).
- Customer support and communications you request (performance of a contract / legitimate interests).
- Comply with law, tax, accounting, and audit requirements (legal obligation).
- Notifications (if enabled and where you've consented, for example a short weekly suggestion in Nightcap or update/offer notifications; you can opt out in device settings at any time).
4) In-app purchases & subscriptions
Purchases for iOS are processed by Apple. We don't receive your full payment method details. RevenueCat helps validate receipts and manage your entitlements (what content/features you have access to). You can manage or cancel subscriptions in your Apple ID settings, and in most Apps from Settings → Manage subscription.
5) Advertising measurement and App Tracking Transparency
Some Apps (currently Nightcap) include the Meta (Facebook) SDK so we can measure whether our ads on Meta platforms lead to installs and subscriptions.
- On iOS the App asks for your permission through Apple's App Tracking Transparency prompt before any tracking takes place.
- If you allow tracking, the SDK may share your device's advertising identifier (IDFA) and App events (install, session start, subscription start or trial start) with Meta, and Meta may combine them with data it holds about you to measure and optimize our ads.
- If you decline, no advertising identifier is shared and your data is not linked with Meta's data. Apple's privacy-preserving SKAdNetwork framework may still report aggregated, anonymous install counts that cannot identify you.
- You can change your choice at any time in iOS Settings → Privacy & Security → Tracking.
We do not show third-party ads inside our Apps, and we do not share your data with data brokers.
6) Sharing your information
We share information only as needed to run the Apps and as required by law:
- Service providers / processors (RevenueCat; Mixpanel and other analytics or crash reporting providers; Meta for advertising measurement; AI providers such as OpenAI and AI image processing providers; our hosting and server providers such as Cloudflare and Google Firebase) under contracts that limit their use of your data and require them to protect it appropriately.
- Affiliates and successors (if we reorganize, merge, or transfer assets, your data may transfer accordingly).
- Legal compliance (to comply with applicable law, court orders, or to protect rights, safety, and security).
- With your consent or at your direction.
We do not sell your personal information.
7) International transfers
We may process and store data in countries outside your own, including the United States (RevenueCat, Meta, OpenAI, Cloudflare) and the European Union (Mixpanel). Where required, we implement appropriate safeguards (for example standard contractual clauses) to protect your information.
8) Data retention
We keep personal data only as long as necessary for the purposes described above. For example:
- Purchase/subscription records: for as long as your subscription or entitlement is active and for a reasonable period afterward to meet tax/audit obligations.
- Analytics and diagnostics: retained for a limited period to analyze trends and app stability; you can ask us to delete the events tied to your App user ID at any time.
- Support records: retained as needed to address your request and for internal accountability.
- Photos, images, prompts and generated outputs (AI features): stored in the App on your device; on our side only as long as needed to provide the service (for example to let you view or re-open recent creations) and then deleted or anonymized after a limited retention period. Our current maximum retention for such content is up to 30 days, and our AI providers apply a similar maximum (currently up to 30 days) when processing on our behalf. Nightcap shelf photos are not stored on our servers at all.
If you would like us to delete your photos, generated images, or other personal data earlier than our standard retention period where technically feasible, you can contact us at umitcan@minisol.co and we will handle your request in accordance with applicable law. When no longer needed, data is deleted or anonymized.
9) Your rights & choices
Depending on your location, you may have rights to:
- Access, correct, or delete personal data;
- Object to or restrict certain processing;
- Port your data;
- Withdraw consent where processing is based on consent (for example by changing your Tracking or Notifications choice in iOS Settings).
To exercise rights, contact us at umitcan@minisol.co. We may need to verify your identity, for example by asking for the App user ID shown in the App's Settings. You also have the right to lodge a complaint with your local supervisory authority.
Region-specific notices
- EEA/UK: minisol is the controller for personal data processed via the Apps. Our legal bases are outlined above.
- California (CCPA/CPRA): We do not "sell" personal information. Sharing advertising identifiers with Meta for ad measurement, when you allow tracking, may be considered "sharing" under California law; you can opt out at any time by declining or withdrawing tracking permission in iOS Settings. You may request access or deletion by emailing us. We honor authorized agent requests as required.
- Türkiye (KVKK): If you reside in Türkiye, you have rights under Law No. 6698, including to learn whether data is processed, request information, learn purposes, know third parties to whom data is transferred, request rectification, deletion, and object to certain results. Contact us to exercise these rights.
10) Children's privacy and age limits
Our Apps are not directed to children under 13 (or the minimum age required in your country). We do not knowingly collect personal data from children. Apps whose content concerns alcoholic beverages (for example Nightcap) are intended only for adults of legal drinking age in their country and carry a corresponding age rating on the App Store. If you believe a child has provided data, contact us and we will take appropriate steps.
11) Security
We use reasonable administrative, technical, and organizational measures to protect your information, including encrypted connections (HTTPS) between the Apps, our servers and our providers. No method of transmission or storage is 100% secure.
12) Third-party links and content
The Apps may link to third-party websites or services we don't control. Their privacy practices are governed by their own policies.
13) Changes to this Policy
We may update this Policy from time to time. We'll revise the "Last Updated" date above and, where required, notify you in-App or by other means. Your continued use of the Apps after an update means you accept the changes.
14) How to contact us
Questions or requests about this Policy: umitcan@minisol.co
Postal address: Istasyon Mah. 1437. Sokak, Kocaeli / Türkiye