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Privacy Policy

Effective date: June 02, 2025 • Last updated: June 02, 2025

SoberX — Habit Change Support

If you are located in the European Economic Area or the United Kingdom, please read our GDPR Privacy Notice at https://soberx.app/privacy/gdpr which applies to you in addition to this Policy.

1. Who We Are

SoberX is developed and operated by ICI Tech Teknoloji A.Ş. ("Company", "we", "us", or "our"), a technology company registered in Turkey.

CompanyICI Tech Teknoloji A.Ş.
Websitehttps://soberx.app/
Emailapp@icitech.com.tr
Data ControllerICI Tech Teknoloji A.Ş.

We process personal data in compliance with the Turkish Personal Data Protection Law No. 6698 (KVKK) and, where applicable, internationally recognized privacy standards.

Medical Disclaimer: SoberX is a self-help habit-change and habit-change-support companion. It is not a medical device, diagnostic tool, clinical treatment, telehealth service, or substitute for professional care. Nothing in this app or on this website constitutes medical advice or guarantees any outcome. If you are in crisis, please contact local emergency services or a qualified clinician immediately.

2. Scope of This Policy

This Privacy Policy applies to:

  • The SoberX iOS app (distributed via the Apple App Store)
  • The SoberX Android app (distributed via Google Play)
  • The SoberX website at https://soberx.app/
  • Any related support, marketing, or communication channels operated by us

This Policy does not apply to third-party websites or services that may be linked from the Platform. We encourage you to review the privacy policies of any third-party services you use.

3. Data We Collect

We collect only the data necessary to provide, maintain, and improve the Platform. Several categories below are optional or never leave your device — these are clearly marked.

3.1 Account Information

Collected only if you choose to create an account:

  • Email address
  • Password (stored as a one-way hash — we never see your plain-text password)
  • Optional: display name, username, profile photo

No account required. SoberX can be used fully offline without creating an account. If you choose not to register, none of this category is collected.

3.2 Habit and Tracking Data

  • Selected habit category (nicotine, alcohol, gambling, social media, sugar, caffeine, or similar)
  • Start date and clean time
  • Self-defined goals and personal motivation text
  • Daily log entries: sober, partial, or slip
  • Streak length, milestone records
  • Savings calculations (money, time, calories, or custom metric)
  • Daily Commitment records
  • Evening review and reflection entries

3.3 In-App Tool Usage Data

  • Urge Wave: session timestamps, completion status
  • Risk Radar: time-of-day urge patterns derived from your own logs
  • Quick Reset: session start/end times, breathing cycle counts
  • Daily Commitment: completion timestamps

This data stays on your device. None of the above is transmitted to our servers unless you explicitly enable cloud backup.

3.4 Voice Release Data

  • Microphone input recorded during a Voice Release session
  • Temporary audio processing to generate a calm reflection response
  • Transcript text generated from your voice input

Audio stays on your device. Voice recordings and transcripts are stored locally and are never uploaded to our servers or shared with any third party.

3.5 Support Circle Data

  • Names and contact details (phone number and/or email) of trusted people you choose to add

Support Circle contacts stay on your device. This information is never transmitted to our servers or any third party.

3.6 Subscription and Purchase Data

When you subscribe to SoberX Premium:

  • Subscription tier and status (active, expired, trial, cancelled)
  • Purchase date, renewal date, and transaction ID
  • Platform of purchase (App Store or Google Play)
  • RevenueCat customer ID (a pseudonymous identifier)

We do not see your payment card details. All payment processing is handled entirely by Apple or Google.

3.7 Device and Technical Data

  • Device type and model
  • Operating system and version
  • App version
  • IP address (truncated where possible)
  • Unique device identifiers (advertising ID is not used)
  • Time zone and locale settings
  • App session timestamps and duration
  • Crash logs and error reports

3.8 Push Notification Data

  • Device push notification token (if you grant notification permission)
  • Notification delivery and open events

3.9 Communications Data

If you contact us via email, in-app support, or feedback forms:

  • Your email address
  • The content of your message
  • Correspondence history

3.10 Legal and Compliance Data

Where required by law:

  • Information in correspondence with regulatory authorities
  • Data included in court, enforcement, or arbitration files
  • Records required under applicable Turkish law

4. How We Collect Your Data

MethodExamples
Directly from youAccount registration, manual log entries, support messages, in-app settings
Automatically during useSession data, crash reports, device info, app version
From third-party servicesSubscription and purchase status from RevenueCat; payment confirmation from Apple or Google
From your device sensorsMicrophone input (Voice Release only, with your permission)

5. Legal Bases for Processing

Under KVKK and applicable law, we process your personal data on the following legal bases:

Legal BasisWhen We Rely on It
Performance of contractProviding account features, syncing data across devices, handling subscription access
Legitimate interestImproving app quality, security monitoring, fraud prevention, crash analysis
Legal obligationResponding to lawful requests from authorities, financial record-keeping
Establishment, exercise, or defence of legal claimsHandling disputes, enforcing our Terms of Service
Explicit consentSending marketing emails, enabling optional analytics, processing sensitive recovery data where consent is required

Where we rely on legitimate interest, we have assessed that our interests do not override your rights and freedoms. You may object to such processing — see Section 17.

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

6. How We Use Your Data

Core App Functionality

  • Creating and authenticating your account
  • Syncing your habit data across your devices (if cloud backup is enabled)
  • Delivering personalized progress, milestone, and savings summaries
  • Powering Risk Radar pattern summaries based on your own logs
  • Managing your subscription status and unlocking Premium features

App Quality and Safety

  • Diagnosing crashes and fixing bugs
  • Monitoring for security threats and unauthorized access
  • Analyzing aggregate usage patterns to improve features

Communications

  • Sending transactional notifications (e.g., subscription receipts, password resets)
  • Responding to your support requests
  • Sending marketing or promotional messages (only with your explicit consent)

Legal and Compliance

  • Meeting our obligations under Turkish law
  • Responding to lawful requests from courts or authorities
  • Protecting our legal rights in disputes

7. What We Do Not Do

Given the sensitive nature of recovery data, we make the following explicit commitments:

  • We do not sell your personal data to any third party, ever.
  • We do not share your addiction category, sobriety status, urge logs, risk scores, journal content, daily logs, or Support Circle contacts with Meta (Facebook/Instagram), TikTok, Google Ads, Snapchat, or any other advertising network or data broker.
  • We do not use your in-app recovery activity for ad targeting or behavioral profiling.
  • We do not use advertising identifiers (IDFA / GAID).
  • We do not share Voice Release audio with any third party or use it to train AI models.
  • We do not require a public profile or social account to use SoberX.

8. Data Stored Only on Your Device

Certain sensitive data is designed to remain local on your device:

  • Voice Release recordings and transcripts
  • Support Circle contact details
  • Urge Wave logs and Quick Reset sessions

This data does not leave your device unless you explicitly enable cloud backup.

9. Subscriptions and Billing

Subscriptions are processed via Apple (App Store) or Google (Play). We may receive subscription status and a pseudonymous customer identifier via RevenueCat. We do not receive or store your payment card details.

10. Third-Party Services

We may use third-party services to provide app distribution, payment processing, subscription status management, and infrastructure.

For the GDPR/EEA/UK-specific processing, please see our GDPR Privacy Notice.

11. Data Sharing and Disclosure

We share personal data only where necessary and with appropriate safeguards, including service providers, Apple/Google, RevenueCat, and where required by law.

We never share local-only recovery data (Voice Release, Support Circle, Urge Wave logs) with advertising platforms.

12. International Data Transfers

ICI Tech Teknoloji A.Ş. is established in Turkey.

  • For EEA/UK users: international transfers are addressed in our GDPR Privacy Notice, including safeguards under GDPR Article 46 (such as Standard Contractual Clauses (SCCs)) and, for the UK, UK IDTA / Addendum mechanisms.
  • For other users: where cross-border transfers occur, we apply appropriate safeguards and security measures.

You may request information about applicable safeguards by contacting us at app@icitech.com.tr.

13. Data Retention

We retain personal data only as long as necessary for the purposes described in this Policy or as required by law. Local-only data remains on your device until you uninstall the app or clear app data.

14. Security

We implement appropriate technical and organizational measures to protect your data, including encryption in transit, access controls, and security monitoring. You can also enable biometric or passcode locking within the app where available.

15. Push Notifications

If you enable notifications, we process a device push token and delivery/open events to deliver notifications. You can disable notifications at any time in your device settings.

16. Children's Privacy

The Platform is intended for users aged 18 and older. We do not knowingly collect personal data from children.

17. Your Privacy Rights

Depending on your location and applicable law, you may have rights such as access, correction, deletion, objection, and withdrawal of consent.

  • EEA/UK users: please see our GDPR Privacy Notice for the full list of rights, including the right to data portability (GDPR Art. 20).

To exercise rights, contact us at app@icitech.com.tr.

18. Cookies and Tracking Technologies

Our marketing website may use cookies. Where required, a consent banner is shown. We do not use cookies to infer health status or recovery journey from in-app data.

19. Changes to This Policy

We may update this Privacy Policy from time to time. The latest version will be published on our website.

20. Contact Us

21. Governing Law

This Policy is governed by applicable laws, including Turkish law where relevant.