Privacy Policy

Last updated: 26/09/2026

Your security matters to us. That is why the personal data you share with us is protected with care.

As the data controller, Clump uses this privacy and personal data protection policy to explain which personal data we process and why, with whom and why the data may be shared, how and on what legal grounds we process it, and what rights you have regarding your data.

Personal Data We Collect, How We Collect It and Legal Grounds

When you use the Clump app, the personal data below is processed as you enter it or as far as it is needed for the app to work, within and for the duration of our service and contract relationship, on the grounds of performing the contract and our legitimate interests. Live location sharing (the family tracking link) is additionally based on your explicit consent.

• Account information: your name, e-mail address, phone number (if you enter it) and profile photo (if you upload one). If you sign in with Google or Apple, the name and e-mail address these providers pass to us.
• Location: when you join a ride, your precise location, heading and speed for the duration of the ride, including while the app is in the background as long as the ride continues. Your location is shown to the other participants of the ride. No ride location records are kept outside a ride.
• Identifiers and device information: your user ID (account number) and your device's push notification token, used to deliver notifications.
• Content you create: group names, descriptions, emblems and cover photos; the routes and stops you plan; and the quick messages, road reports and SOS alerts you send during rides.

Tracking, Analytics and Advertising

Clump does not track you across other apps or websites. The app uses no analytics or advertising tools and no cookies, and your personal data is never sold or shared for advertising.

Voice Communication

What you say in a ride's voice channel is transmitted in real time to the other participants of the group. Audio is not recorded or stored.

Service Providers (Data Processors)

• Agora: real-time transmission of the voice channel.
• Firebase Cloud Messaging (Google): delivering notifications to your device, using your push notification token.
• Sign in with Google and Sign in with Apple: verifying your identity if you choose one of these methods.
• Apple (maps and weather): in the iOS app, maps are shown with Apple Maps; for the weather along a route, the locations of points on the route are sent to Apple's weather service. The map provider for the Android app has not been decided yet; this text will be updated when it is.

Some of these service providers are located outside Türkiye; your data is transferred only for the purposes above and with the necessary technical and organisational measures.

User Content, Blocking and Reporting

In the app you can block other users and report users and groups for inappropriate content. Reports are reviewed; content that breaks the rules may be removed and the accounts concerned may be suspended. The list of users you have blocked is stored in your account.

Deleting Your Account

You can delete your account at any time from within the app (Settings). When you delete your account, your account information and ride location records are deleted; records that must be kept by law are kept only for the legally required period.

Purposes of Processing Your Personal Data

The personal data you share with us is processed and updated during the contract and service period, in a manner appropriate and proportionate to its purpose, in order to enter into contracts with you so that you can use our services, to fulfil the requirements of the services we provide in the best way and in line with our contracts, to enable you to exercise the rights arising from these contracts, to develop our products and services according to your needs and inform you of these developments, to bring you together with broader service providers within the legal framework, and to fulfil legal obligations (sharing personal data with judicial and administrative authorities upon request).

To Whom and for What Purposes Personal Data May Be Transferred

The personal data you share with us may be transferred to third parties, institutions and organisations in Türkiye and abroad from which we receive or to which we provide services, with which we have a contractual relationship or cooperate in order to carry out our activities, and to judicial and administrative authorities upon request, provided that the necessary technical and administrative measures are taken.

Live Location Sharing (Family Tracking Link)

This feature runs only if you turn it on and is based on your separate explicit consent. Anyone who has the link you create during a ride (clumpapp.com/t/…) can follow your ride in a browser without an account. You decide who receives the link; the recipient may forward it.

• What viewers see: only your location (about 10 m precision), heading, speed (visible by default; you can hide it), phone battery level (if the app sends it), the planned route and stops, estimated arrival and remaining distance, ride status (riding, on a break, no connection, arrived), the group size, the first word of your name and your initials. Other riders, your profile photo, phone number and e-mail address are never shown.
• Duration: A new link is created for every ride. A link is valid for at most 24 hours and closes automatically 30 minutes after the ride ends. If you leave the ride, the link stays open and viewers see that you left (with the time, without your location); when you rejoin, sharing continues where it left off. You can stop or renew the link at any time. After the ride ends viewers see only the arrival summary, not your last position.
• Stopping: You can stop sharing at any time with one tap in the app; the link stops working within seconds. Renewing the link also revokes the old one.
• Privacy zone: Around the route start, the destination and your first position of the ride (1 km by default; 0, 500 m, 1 km or 2 km), your location is hidden and the route line is cut. Zone centres are randomly offset and never drawn on the map.
• SOS: If you send an SOS, people who have the tracking page open see the SOS time and position (even inside a privacy zone). The alert disappears when you cancel the SOS. No SMS or notification is sent to viewers.
• Viewer count: To show you "N people watching", viewers' IP addresses are not stored; a non-reversible digest is kept only in a short-lived cache. The tracking page uses no cookies and loads no analytics.
• Retention: Share records (a hashed form of the link, creation/end times, view count) and SOS records are kept. Your ride location history is currently kept indefinitely; this text will be updated when a retention period is set. These data are deleted when you delete your account.
• Map service: The tracking page uses Apple MapKit JS (temporarily OpenStreetMap); the map provider may see the viewer's IP address. Your location is not sent to the map provider; it is drawn in the browser.
• Withdrawing consent: When you stop sharing and no longer use the feature, no new links are created. To withdraw your consent and request deletion of these records, contact us at the address below.

Your Rights as a Data Subject

Under Article 11 of the Turkish Personal Data Protection Law (KVKK), everyone may apply to the data controller to:

• learn whether their personal data is processed,
• request information about it if it has been processed,
• learn the purpose of processing and whether the data is used in line with that purpose,
• know the third parties in Türkiye or abroad to whom the data is transferred,
• request correction if the data is incomplete or inaccurate,
• request deletion or destruction of the data,
• request that the actions under (e) and (f) be notified to third parties to whom the data was transferred,
• object to a result against them arising from analysis of the data exclusively by automated systems,
• claim compensation for damage caused by unlawful processing of the data.

To exercise these rights, you can contact us at contact@clumpapp.com.

Contact

You are entirely free to accept or not accept the processing of only the personal data necessary to serve your requests under this privacy and personal data processing policy. If you continue to use the app, you will be deemed to have accepted it. If you do not accept it, please remove the app from all your devices. For more information, please feel free to contact us at contact@clumpapp.com.