Demostra
This notice has not been reviewed by a lawyer. The technical content is accurate — it describes what the app actually does. But the legal basis for the transfer abroad (§3 below) is still unresolved, and a lawyer's opinion should be obtained before this goes live.

1. Data controller

Demostra is built and operated by an independent developer; there is no company behind it. The data controller is that natural person.

Demostra
Contact: info@demostra.app

This notice is prepared under the EU General Data Protection Regulation (GDPR) and Turkish Personal Data Protection Law No. 6698 (KVKK), to meet the information duties in GDPR Art. 13 and KVKK Art. 10.

This is a privacy notice, not a consent form. The duty to inform depends on no approval; you are not asked to consent in order to read it. Operations that do require consent live in a separate document: Explicit Consent Text. (Board principle decision 2026/347 of 18 February 2026 requires the two to be separate.)

2. Your voice never leaves your device

Your speech is transcribed on your own phone. The audio is never sent to our servers and is not stored anywhere.

The microphone stays off until you tap “Start speaking”. This is deliberate: it prevents the unintended capture of conversations around you.

3. But the transcribed text is sent — and it goes abroad

To write summaries, generate questions and assess your explanation, the TEXT of your speech is sent to our AI provider.

That provider is OpenAI, which processes data in the United States. This means your text is transferred abroad.

Retention: the provider keeps API requests for 30 days for abuse monitoring, then deletes them. Zero Data Retention is available only for certain account types and we do not have it yet.

Model training: under the provider's published policy, inputs sent and outputs received through the API are not used to train its models by default. This is the provider's declared default, not a negotiated term.

The transfer is not only the AI provider

To be honest we list all of it — the app's server and database are also outside Türkiye. So it is not only your explanation: all data tied to your account sits abroad.

WhereWhat goesWhy
AI provider Explanation text, check-in answers, goal and topic names — without any identifier To produce the assessment
Application server (hosting) Every request to the app To run the service
Database Account, goals, check-ins, notes — all data To store it
Email provider Your email address and verification code To send codes and password resets

None of these has a Türkiye region. The same legal basis and the same missing safeguard apply to all of them — the section below covers them together.

Your identity is not sent to the AI provider. The request carries no name, email or user id, and the provider's own end-user identifier field is left empty. This does not remove the transfer in law — we hold the link — but it reduces what a leak would expose to text without identity.

What is sent:

The legal basis — and its limit

KVKK Art. 9 was amended by Law 7499 and, as of 1 June 2024, sets a tiered regime: (1) an adequacy decision, (2) failing that, appropriate safeguards, (3) failing that, only incidental cases.

As things stand the Turkish Board has issued no adequacy decision for any country. This transfer rests not on explicit consent but on performance of a contract: assessing your explanation is Demostra's core undertaking, and it cannot be performed without the transfer.

We do not tie the transfer to consent, because the service itself depends on it — and conditioning access to a service on consent renders that consent invalid under KVKK (Board decision 2023/692 of 2 May 2023). Instead we state plainly what happens, and the transfer is accepted as part of the Terms of Service. If you do not accept the Terms, no account is created.

Safeguard status. Article 9 requires an appropriate safeguard for transfers to countries without an adequacy decision. The Board has not issued an adequacy decision for any country to date; the standard-contract route requires the provider's signature, and that signature has not been obtained yet. The transfer currently rests on the legal ground of performance of the contract; there is no additional safeguard. This section is updated when that changes.

If signed, a standard contract is notified to the Board within five business days (Art. 9(4)(c)). You can delete your account at any time: Settings → Delete account.

4. What we store

Your password is never stored in plain text; it is hashed irreversibly (bcrypt). Password reset codes are also stored as hashes and are single-use.

Purpose and legal basis

Data is processed only to deliver the service itself: planning your goal, generating questions, assessing your explanation and scheduling reviews.

5. What we do not do

6. Friend and space features

When you connect with a friend, your streak and shared study time become visible to them. Before connecting, what will be shared is listed and your consent is taken.

In paired-case questions, both answers are shown to each other and processed together for comparison.

When you join a space, the time you spent in that session, the number of proofs you produced, your name and your avatar are visible to other members. Not visible: your goals, notes, other spaces, how many times you were interrupted, and your check-in answers. Joining is your own action for each session; a moderator cannot add anyone.

7. How long we keep it

We hold no payment details at all: subscriptions are billed by the Apple App Store and Google Play, and card details never reach us. Details: Refund and Withdrawal Policy.

8. How to exercise your rights

Under GDPR Art. 15–22 and Turkish KVKK Art. 11 you have the right to access, rectify, erase, restrict processing, port your data and object.

If you consented to sharing dictation corrections, you can withdraw that consent at any time under Settings → Data; withdrawing also deletes the contributions you made in that window.

9. Age limit

Demostra is not designed for people under 16. You declare that you are over 16 when you register. Accounts we learn belong to someone under 16 are closed.

10. Special category data warning

Speech transcripts are free-form. If you talk about health, beliefs or political views, that is recorded too and sent to the AI provider. The app cannot technically prevent this — which is why we recommend not discussing such information.

11. Changes

When this notice changes the date is updated, and material changes are announced in the app.

12. Contact

info@demostra.app · Consent text · Terms of Service · Refund policy · Delete account