PRIVACY POLICY
Last updated February 05, 2025
This Privacy Notice for Hakan Martin (doing business as Sonara) ("we," "us," or "our"), describes
how and why we might access, collect, store, use, and/or share ("process") your personal
information when you use our services ("Services"), including when you:
■ Download and use our mobile application (Sonara), or any other application of ours that
links to this Privacy Notice
■ Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy
rights and choices. We are responsible for making decisions about how your personal
information is processed. If you do not agree with our policies and practices, please do not use
our Services. If you still have any questions or concerns, please contact us at
email@hakanmartin.com.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy Notice, but you can find out more
details about any of these topics by clicking the link following each key point or by using
our
table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we
may process personal information depending on how you interact with us and the Services, the
choices you make, and the products and features you use. Learn more about
personal
information you disclose to us
.
Do we process any sensitive personal information? Some of the information may be
considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic
origins, sexual orientation, and religious beliefs. We do not process sensitive personal
information.
Do we collect any information from third parties? We do not collect any information from third
parties.
How do we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply
with law. We may also process your information for other purposes with your consent. We
process your information only when we have a valid legal reason to do so. Learn more about
how we process your information.
In what situations and with which parties do we share personal information? We may
share information in specific situations and with specific third parties. Learn more about
when
and with whom we share your personal information
.
How do we keep your information safe? We have adequate organizational and technical
processes and procedures in place to protect your personal information. However, no electronic
transmission over the internet or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security and improperly collect, access, steal, or modify
your information. Learn more about
how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable
privacy law may mean you have certain rights regarding your personal information. Learn more
about
your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by visiting
http://delete-info.sonarabackend.com, or by contacting us. We will consider and act upon any
request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy Notice
in full
.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the
Services, express an interest in obtaining information about us or our products and Services,
when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on
the context of your interactions with us and the Services, the choices you make, and the products
and features you use. The personal information we collect may include the following:
■ email addresses
■ passwords
Sensitive Information. We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you choose to make
purchases, such as your payment instrument number, and the security code associated with your
payment instrument. All payment data is handled and stored by RevenueCat. You may find their
privacy notice link(s) here: https://www.revenuecat.com/privacy/.
Application Data. If you use our application(s), we also may collect the following
information if you choose to provide us with access or permission:
■ Geolocation Information. We may request access or permission to track
location-based information from your mobile device, either continuously or while
you are using our mobile application(s), to provide certain location-based
services. If you wish to change our access or permissions, you may do so in your
device's settings.
■ Push Notifications. We may request to send you push notifications regarding your
account or certain features of the application(s). If you wish to opt out from receiving
these types of communications, you may turn them off in your device's settings.
This information is primarily needed to maintain the security and operation of our application(s),
for troubleshooting, and for our internal analytics and reporting purposes.
All personal information that you provide to us must be true, complete, and accurate, and you
must notify us of any changes to such personal information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you
interact with our Services, including:
■ To facilitate account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and log in to your
account, as well as keep your account in working order.
■ To identify usage trends. We may process information about how you use our
Services to better understand how they are being used so we can improve them.
■ To save or protect an individual's vital interest. We may process your information
when necessary to save or protect an individual's vital interest, such as to prevent
harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we
have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent,
to comply with laws, to provide you with services to enter into or fulfill our contractual obligations,
to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid
legal bases we rely on in order to process your personal information. As such, we may rely on
the following legal bases to process your personal information:
■ Consent. We may process your information if you have given us permission (i.e.,
consent) to use your personal information for a specific purpose. You can withdraw your
consent at any time. Learn more about withdrawing your consent.
■ Legitimate Interests. We may process your information when we believe it is
reasonably necessary to achieve our legitimate business interests and those
interests do not outweigh your interests and fundamental rights and freedoms.
For example, we may process your personal information for some of the
purposes described in order to:
■ Analyze how our Services are used so we can improve them to engage and
retain users
■ Legal Obligations. We may process your information where we believe it is
necessary for compliance with our legal obligations, such as to cooperate with a
law enforcement body or regulatory agency, exercise or defend our legal rights,
or disclose your information as evidence in litigation in which we are involved.
■ Vital Interests. We may process your information where we believe it is necessary
to protect your vital interests or the vital interests of a third party, such as
situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express
consent) to use your personal information for a specific purpose, or in situations where
your permission can be inferred (i.e., implied consent). You can withdraw your consent
at any time.
In some exceptional cases, we may be legally permitted under applicable law to process
your information without your consent, including, for example:
■ If collection is clearly in the interests of an individual and consent cannot be
obtained in a timely way
■ For investigations and fraud detection and prevention
■ For business transactions provided certain conditions are met
■ If it is contained in a witness statement and the collection is necessary to assess,
process, or settle an insurance claim
■ For identifying injured, ill, or deceased persons and communicating with next of
kin
■ If we have reasonable grounds to believe an individual has been, is, or may be
victim of financial abuse
■ If it is reasonable to expect collection and use with consent would compromise
the availability or the accuracy of the information and the collection is reasonable
for purposes related to investigating a breach of an agreement or a contravention
of the laws of Canada or a province
■ If disclosure is required to comply with a subpoena, warrant, court order, or rules
of the court relating to the production of records
■ If it was produced by an individual in the course of their employment, business, or
profession and the collection is consistent with the purposes for which the information
was produced
■ If the collection is solely for journalistic, artistic, or literary purposes
■ If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We may share information in specific situations described in this section and/or with
the following third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data
with third-party vendors, service providers, contractors, or agents ("third parties") who perform
services for us or on our behalf and require access to such information to do that work. We have
contracts in place with our third parties, which are designed to help safeguard your personal
information. This means that they cannot do anything with your personal information unless we
have instructed them to do it. They will also not share your personal information with any
organization apart from us. They also commit to protect the data they hold on our behalf and to
retain it for the period we instruct.
The third parties we may share personal information with are as follows:
■ Cloud Computing Services
Amazon Web Services (AWS)
■ Purchase Implementation
RevenueCat
We also may need to share your personal information in the following situations:
■ Business Transfers. We may share or transfer your information in connection with, or
during negotiations of, any merger, sale of company assets, financing, or acquisition of all
or a portion of our business to another company.
■ Offer Wall. Our application(s) may display a third-party hosted "offer wall." Such
an offer wall allows third-party advertisers to offer virtual currency, gifts, or other
items to users in return for the acceptance and completion of an advertisement
offer. Such an offer wall may appear in our application(s) and be displayed to you
based on certain data, such as your geographic area or demographic information.
When you click on an offer wall, you will be brought to an external website
belonging to other persons and will leave our application(s). A unique identifier,
such as your user ID, will be shared with the offer wall provider in order to prevent
fraud and properly credit your account with the relevant reward.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in
this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out
in this Privacy Notice, unless a longer retention period is required or permitted by law (such as
tax, accounting, or other legal requirements). No purpose in this notice will require us keeping
your personal information for longer than the period of time in which users have an account with
us.
When we have no ongoing legitimate business need to process your personal information, we
will either delete or anonymize such information, or, if this is not possible (for example, because
your personal information has been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and
technical security measures.
We have implemented appropriate and reasonable technical and organizational security
measures designed to protect the security of any personal information we process. However,
despite our safeguards and efforts to secure your information, no electronic transmission over
the Internet or information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will
not be able to defeat our security and improperly collect, access, steal, or modify your
information. Although we will do our best to protect your personal information, transmission of
personal information to and from our Services is at your own risk. You should only access the
Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do
we knowingly sell such personal information. By using the Services, you represent that you are at
least 18 or that you are the parent or guardian of such a minor and consent to such minor
dependent’s use of the Services. If we learn that personal information from users less than 18
years of age has been collected, we will deactivate the account and take reasonable measures
to promptly delete such data from our records. If you become aware of any data we may have
collected from children under age 18, please contact us at email@hakanmartin.com.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some regions, such as the
European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have
rights that allow you greater access to and control over your personal information. You may
review, change, or terminate your account at any time, depending on your country, province, or
state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under
applicable data protection laws. These may include the right (i) to request access and obtain a
copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the
processing of your personal information; (iv) if applicable, to data portability; and (v) not to be
subject to automated decision-making. In certain circumstances, you may also have the right to
object to the processing of your personal information. You can make such a request by
contacting us by using the contact details provided in the section "
HOW CAN YOU CONTACT
US ABOUT THIS NOTICE?
" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your Member State data protection
authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information
Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal
information, which may be express and/or implied consent depending on the applicable law, you
have the right to withdraw your consent at any time. You can withdraw your consent at any time
by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT
US ABOUT THIS NOTICE?
" below.
However, please note that this will not affect the lawfulness of the processing before its
withdrawal nor, when applicable law allows, will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than consent.
Account Information
If you would at any time like to review or change the information in your account or
terminate your account, you can:
■ Log in to your account settings and update your user account.
■ Contact us using the contact information provided.
■ http://delete-info.sonarabackend.com
Upon your request to terminate your account, we will deactivate or delete your account and
information from our active databases. However, we may retain some information in our files to
prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms
and/or comply with applicable legal requirements.
If you have questions or comments about your privacy rights, you may email us at
email@hakanmartin.com.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and collected. At this stage, no uniform
technology standard for recognizing and implementing DNT signals has been finalized. As such,
we do not currently respond to DNT browser signals or any other mechanism that automatically
communicates your choice not to be tracked online. If a standard for online tracking is adopted
that we must follow in the future, we will inform you about that practice in a revised version of this
Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because
there currently is not an industry or legal standard for recognizing or honoring DNT signals, we
do not respond to them at this time.
10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana,
Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon,
Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive
details about the personal information we maintain about you and how we have processed it,
correct inaccuracies, get a copy of, or delete your personal information. You may also have the
right to withdraw your consent to our processing of your personal information. These rights may
be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal information in the past twelve (12)
months:
Category
Examples
Collected
A. Identifiers
Contact details, such as real name, alias,
postal address, telephone or mobile contact
number, unique personal identifier, online
identifier, Internet Protocol address, email
address, and account name
NO
B. Personal information as
defined in the California
Customer Records statute
Name, contact information, education,
employment, employment history, and financial
information
NO
C. Protected classification
characteristics under state or
federal law
Gender, age, date of birth, race and ethnicity,
national origin, marital status, and other
demographic data
NO
D. Commercial information
Transaction information, purchase history,
financial details, and payment information
NO
E. Biometric information
Fingerprints and voiceprints
NO
F. Internet or other similar
network activity
Browsing history, search history, online
behavior, interest data, and interactions with
our and other websites, applications, systems,
and advertisements
NO
G. Geolocation data
Device location
YES
H. Audio, electronic, sensory,
or similar information
Images and audio, video or call recordings
created in connection with our business
activities
NO
I. Professional or
employment-related
information
Business contact details in order to provide
you our Services at a business level or job title,
work history, and professional qualifications if
you apply for a job with us
NO
J. Education Information
Student records and directory information
NO
K. Inferences drawn from
collected personal information
Inferences drawn from any of the collected
personal information listed above to create a
profile or summary about, for example, an
individual’s preferences and
characteristics
NO
L. Sensitive personal
Information
NO
We may also collect other personal information outside of these categories through instances
where you interact with us in person, online, or by phone or mail in the context of:
■ Receiving help through our customer support channels;
■ Participation in customer surveys or contests; and
■ Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or
for:
■ Category G - As long as the user has an account with us
Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT INFORMATION
DO WE COLLECT?
"
How We Use and Share Personal Information
Learn more about how we use your personal information in the section, "HOW DO WE
PROCESS YOUR INFORMATION?
"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written
contract between us and each service provider. Learn more about how we disclose personal
information to in the section, "
WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?
"
We may use your personal information for our own business purposes, such as for undertaking
internal research for technological development and demonstration. This is not considered to be
"selling" your personal information.
We have not sold or shared any personal information to third parties for a business or
commercial purpose in the preceding twelve (12) months. We have disclosed the following
categories of personal information to third parties for a business or commercial purpose in the
preceding twelve (12) months:
The categories of third parties to whom we disclosed personal information for a business or
commercial purpose can be found under "
WHEN AND WITH WHOM DO WE SHARE YOUR
PERSONAL INFORMATION?
"
Your Rights
You have rights under certain US state data protection laws. However, these rights are not
absolute, and in certain cases, we may decline your request as permitted by law. These rights
include:
■ Right to know whether or not we are processing your personal data
■ Right to access your personal data
■ Right to correct inaccuracies in your personal data
■ Right to request the deletion of your personal data
■ Right to obtain a copy of the personal data you previously shared with us
■ Right to non-discrimination for exercising your rights
■ Right to opt out of the processing of your personal data if it is used for targeted
advertising (or sharing as defined under California’s privacy law), the sale of
personal data, or profiling in furtherance of decisions that produce legal or
similarly significant effects ("profiling")
Depending upon the state where you live, you may also have the following rights:
■ Right to access the categories of personal data being processed (as permitted by
applicable law, including Minnesota’s privacy law)
■ Right to obtain a list of the categories of third parties to which we have disclosed
personal data (as permitted by applicable law, including California's and
Delaware's privacy law)
■ Right to obtain a list of specific third parties to which we have disclosed personal
data (as permitted by applicable law, including Minnesota's and Oregon's privacy
law)
■ Right to review, understand, question, and correct how personal data has been
profiled (as permitted by applicable law, including Minnesota’s privacy law)
■ Right to limit use and disclosure of sensitive personal data (as permitted by
applicable law, including California’s privacy law)
■ Right to opt out of the collection of sensitive data and personal data collected
through the operation of a voice or facial recognition feature (as permitted by
applicable law, including Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us by visiting http://delete-info.sonarabackend.com, by
emailing us at email@hakanmartin.com, or by referring to the contact details at the bottom of this
document.
Under certain US state data protection laws, you can designate an authorized agent to make a
request on your behalf. We may deny a request from an authorized agent that does not submit
proof that they have been validly authorized to act on your behalf in accordance with applicable
laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same
person about whom we have the information in our system. We will only use personal information
provided in your request to verify your identity or authority to make the request. However, if we
cannot verify your identity from the information already maintained by us, we may request that
you provide additional information for the purposes of verifying your identity and for security or
fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional
information to verify your identity before processing your request and the agent will need to
provide a written and signed permission from you to submit such request on your behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request,
you may appeal our decision by emailing us at email@hakanmartin.com. We will inform you in
writing of any action taken or not taken in response to the appeal, including a written explanation
of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your
state attorney general.
California "Shine The Light" Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our
users who are California residents to request and obtain from us, once a year and free of charge,
information about categories of personal information (if any) we disclosed to third parties for
direct marketing purposes and the names and addresses of all third parties with which we shared
personal information in the immediately preceding calendar year. If you are a California resident
and would like to make such a request, please submit your request in writing to us by using the
contact details provided in the section "
HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
"
11. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.
Australia and New Zealand
We collect and process your personal information under the obligations and conditions set by
Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020 (Privacy Act).
This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular:
what personal information we collect from you, from which sources, for which purposes, and
other recipients of your personal information.
If you do not wish to provide the personal information necessary to fulfill their applicable purpose,
it may affect our ability to provide our services, in particular:
■ offer you the products or services that you want
■ respond to or help with your requests
■ manage your account with us
■ confirm your identity and protect your account
At any time, you have the right to request access to or correction of your personal information.
You can make such a request by contacting us by using the contact details provided in the
section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
"
If you believe we are unlawfully processing your personal information, you have the right to
submit a complaint about a breach of the Australian Privacy Principles to the Office of the
Australian Information Commissioner and a breach of New Zealand's Privacy Principles to the
Office of New Zealand Privacy Commissioner.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information.
You can make such a request by contacting us by using the contact details provided in the
section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?
"
If you are unsatisfied with the manner in which we address any complaint with regard to our
processing of personal information, you can contact the office of the regulator, the details of
which are:
The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za &
POPIAComplaints@inforegulator.org.za
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an
updated "Revised" date at the top of this Privacy Notice. If we make material changes to this
Privacy Notice, we may notify you either by prominently posting a notice of such changes or by
directly sending you a notification. We encourage you to review this Privacy Notice frequently to
be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
email@hakanmartin.com or contact us by post at:
Hakan Martin
__________
Istanbul, Istanbul 34295
Turkey
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence in the US, you may have the
right to request access to the personal information we collect from you, details about how we
have processed it, correct inaccuracies, or delete your personal information. You may also have
the right to withdraw your consent to our processing of your personal information. These rights
may be limited in some circumstances by applicable law. To request to review, update, or delete
your personal information, please visit: http://delete-info.sonarabackend.com.
