Cookie Policy
Last updated: 20.02.2026 · Version: 1.0
This policy provides transparent information about the cookies and similar tracking technologies (pixels, SDKs, device/advertising identifiers, etc.) used on web domains operated within the scope of the WIN platform ("Platform") and in the WIN mobile application. This text should be evaluated together with the Privacy Policy and the KVKK Clarification Notice.
- Mandatory cookies/trackers: Required for the secure operation of the Platform and the provision of core functions; this category cannot be disabled. - Non-mandatory categories (analytics, marketing, etc.): You can manage your preferences and withdraw your consent at any time. - Mobile app difference: In mobile apps, instead of classic browser cookies, SDKs and device/advertising identifiers (IDFA/GAID) may often be used.
Related documents
Section 1: Purpose, scope, and legal basis
This section explains (i) the purpose of the policy, (ii) which products/ channels it covers, and (iii) key legal references.
1.1 Purpose
The purposes of this policy are:
- to provide clear and understandable information about cookies and similar tracking technologies used within the scope of the Platform,
- to enable users to control their cookie/tracker preferences and manage their consents,
- to ensure transparency of privacy and data protection standards regarding personal data processed through cookie/tracking technologies.
1.2 Scope (which channels)
This policy applies to cookies and tracking technologies used in the following channels:
- WIN mobile application (iOS/Android),
- WIN web domains (https://whoisnextapp.com/ (opens in a new tab) and https://legal.whoisnextapp.com/ (opens in a new tab)),
- campaign/landing pages that may be related to the Platform (again under these domains).
Note: In mobile applications, classic browser "cookies" may not always be used. However, technologies such as SDKs and device/advertising identifiers can function similarly to cookies, so they are addressed together within the scope of this policy.
1.3 Legal basis (general reference)
WIN's cookie/tracking approach is designed with particular consideration to the following regulations:
- Law No. 6698 on the Protection of Personal Data (KVKK)
- Communique on the Procedures and Principles to Fulfill the Obligation to Inform under KVKK
- Regulation on the Transfer of Personal Data Abroad
- Law No. 6563 on the Regulation of Electronic Commerce (ETK) and Regulation on Commercial Communication and Commercial Electronic Messages (especially regarding marketing/communication consents)
- General Data Protection Regulation (GDPR) (if services are offered in the EU/EEA or data of users in the EU/EEA is processed)
1.4 Data controller and contact
For cookie/tracking activities covered by this policy, the data controller is the operator of WIN Services: WIN TECH Bilişim Organizasyon ve Ticaret A.Ş. For the data controller's contact details and application methods under KVKK, please review the KVKK Clarification Notice. For any questions, you can contact us at support@whoisnextapp.com.
Section 2: What are cookies and similar tracking technologies?
This section explains what cookies/tracking technologies are, how they work, and the differences between web and mobile application contexts.
A cookie is a small text file that can be stored on your device through your browser when you visit a website, usually containing a unique identifier and certain preference/session information.
Cookies may be used, for example, for the following purposes:
- Session management (preserving "logged in" status if you have signed in),
- Security (detecting abuse and fraud),
- Remembering preferences (such as language/theme),
- Performance/analytics (understanding site traffic and usage statistics),
- Marketing (campaign measurement, ad effectiveness).
2.1 First-party / third-party
- First-party cookies/trackers: Technologies placed directly by WIN or operating as part of WIN's technical infrastructure.
- Third-party cookies/trackers: Technologies that may be placed or operated by providers from which WIN receives services (analytics, advertising, customer support, security, etc.).
2.2 Session / persistent
- Session cookies: Valid during the browser session; may be deleted when the browser is closed.
- Persistent cookies: Stored on your device for a certain period; may be used for purposes such as remembering preferences.
2.3 Similar non-cookie technologies
In addition to cookies, WIN may use the following technologies (and may address them within the concept of "cookies" under this policy):
- Web beacon/pixel: Small code fragments used to understand access to content or page views.
- SDKs: Measurement/analytics or advertising components in mobile apps that function similarly to cookies.
- Local storage: Mechanisms on browser/device where certain settings can be stored.
Section 3: Which categories of cookies/tracking does WIN use?
This section explains the cookies/tracking technologies used on a "category" basis. For each category, purpose, sample use, and preference/consent logic are stated.
3.1 Mandatory (strictly necessary) cookies/trackers
This category is necessary for the secure operation of the Platform and the provision of the service you request. Example purposes:
- Session and authentication,
- Security and abuse prevention (spam/fraud),
- Load balancing and keeping the service available,
- Remembering your privacy/cookie preference record (may be necessary for preference management).
Since cookies/trackers in this category are mandatory for the operation of the Platform, they may not be switchable to "off" on the web side; on mobile, technical components required for core functionality may not be disabled.
3.2 Preference / functionality cookies
This category includes cookies/trackers that make the Platform more functional and remember your preferences. Example:
- Remembering language/theme preferences,
- Convenience features like "remember me",
- Preserving certain screen/feature settings.
3.3 Performance / analytics cookies and measurement technologies
This category may be used to measure and improve Platform performance. Example:
- Understanding which pages/features are used more,
- Error/crash analysis and performance monitoring,
- Measuring campaign sources (referral) and attribution analysis.
Analytics/measurement technologies may perform aggregated (aggregate) or more detailed user/device-based measurement depending on the tool and configuration used. Therefore, preference/consent requirements may vary by technology.
3.4 Advertising / marketing cookies and trackers
In mobile applications, ad-related tracking generally operates via advertising identifiers such as IDFA/GAID and is subject to device/OS-level settings. WIN may provide personalized ads within the application through AdMob.
3.5 Social media and third-party integrations
If integrations such as social login (e.g., "Sign in with Google", "Sign in with Apple") or social sharing are available, these third parties may use their own cookie/tracking mechanisms. For data processing roles and details of such integrations, the third parties' own policies may also apply.
Section 4: For which purposes do we use cookies/trackers?
This section lists the purposes we target with cookie/tracking technologies, independent of category basis.
WIN may use cookies/trackers (depending on the channel and feature used) for the following purposes:
- Service delivery and continuity: Operating the Platform, loading pages/screens correctly, managing sessions.
- Security: Reducing risks of unauthorized access, account takeover, bot/spam activities, and fraud.
- Remembering preferences: Storing user preferences such as language/theme and personalizing experience.
- Performance measurement and improvement: Error reports, performance metrics, analysis of user flows.
- Product development: Testing new features, A/B tests, understanding usage patterns.
- Marketing/communication measurement: Measuring campaign performance, ad frequency control, analyzing marketing conversions.
Section 5: What data may be processed in this scope?
This section provides examples of data types that may be processed through cookies/tracking technologies.
Through cookies and similar tracking technologies (depending on the channel used), the following types of data may be processed:
| Data type | Examples | Where may it appear? |
|---|---|---|
| Technical identifiers | Cookie ID, session ID, device ID, advertising ID (IDFA/GAID) | Web and/or mobile app |
| Device and browser information | IP address, operating system version, device model, browser type, app version | Web and/or mobile app |
| Usage and interaction data | Visited pages/screens, clicks, view durations, in-app actions | Web and/or mobile app |
| Error and performance data | Crash logs, error codes, response times | Web and/or mobile app |
| Preference data | Language/theme, cookie preferences, personalization settings | Web and/or mobile app |
Note: It is aimed not to store direct identity details such as full name inside cookies; however, since cookie/device identifiers may become suitable to identify you when matched with other information, they are considered personal data in most cases.
Section 6: Legal basis and consent/preference management
This section explains the legal basis approach for mandatory and non-mandatory cookie/tracking activities and how consent is managed.
6.1 General approach under KVKK
Where personal data processing through cookie/tracking technologies is concerned, WIN aims to act in compliance with the processing conditions under KVKK.
- Mandatory (strictly necessary) cookies/trackers: To the extent necessary for the secure operation of the Platform and the provision of the requested service, may rely on conditions under KVKK Art. 5/2 (e.g., necessity for establishment/performance of contract, legitimate interest of the data controller, establishment/exercise/protection of a right, etc.).
- Non-mandatory categories (preference/functionality, analytics, advertising/marketing): Depending on the technology used and scope, explicit consent of the data subject may be required (KVKK Art. 5/1). Especially in scenarios involving third-party advertising/marketing trackers and overseas transfer, the explicit consent approach is fundamental.
6.2 Transfer abroad
In case cookie/tracking providers are located abroad or data may be transferred abroad, conditions under KVKK Art. 9 and the Regulation on the Transfer of Personal Data Abroad are considered. In such cases, where required, consent for overseas transfer is obtained (see Explicit Consent Texts).
6.4 Withdrawal of consent and changing preferences
For non-mandatory cookies/trackers, your consent/preferences:
- via cookie banner / cookie preferences screen on web domains,
- via Settings > Privacy / Ads / Tracking Preferences in the mobile app,
- via privacy settings of your device or browser
can always be changed. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
Cookie/tracking preferences (e.g., analytics or advertising/marketing trackers) do not replace consent for commercial electronic communication under ETK (SMS/e-mail/push). Topics such as marketing communication consents and overseas transfer may be managed with separate consent texts (see Explicit Consent Texts).
Section 7: Third parties, service providers, and data transfer
This section explains the possibility of third-party cookies/trackers, role distinctions (processor/independent controller/joint controller), and transfer risks.
WIN works for operation, security, analytics, marketing, and similar purposes of the Platform with the following service providers and SDK/cookie-like tracking technologies they provide:
- Wix: Website infrastructure (CMS) and e-commerce components.
- Google Analytics (GA4): Web and app traffic analysis and performance measurement.
- AdMob (Google): In-app advertising and personalized ad services.
- Sentry: Software error monitoring and crash reporting (Issue tracking).
- Google Cloud / Firebase: Cloud infrastructure, Firebase Analytics, and technical SDKs.
- Google Gemini 2.5 Flash: Profile verification (selfie/liveness) technology.
- GSAP & Bootstrap: Web interface and performance/animation libraries.
- Store Vantage: CRM and customer relationship management components.
The servers and operation centers of these providers are predominantly located abroad (EU/US), and data transfer abroad may occur within the scope of use of these technologies. For details and consent management, Explicit Consent Texts should be reviewed.
Section 8: Retention periods and cookie lifetimes
This section explains the session/persistent nature of cookies and the retention period approach.
- Session cookies are stored during the browser session and may be deleted when the session ends.
- Persistent (non-mandatory) cookies/trackers are stored on your device for up to 2 years, subject to legal requirements and purpose of use.
- Consent Renewal: Your consent for non-mandatory cookies will be requested again to renew automatically after 1 year from your selection.
Section 9: How can you manage your cookie/tracking preferences?
If you completely disable cookies/tracking in your browser or device, some features of the Platform may not work, or your experience may be limited.
Step 1: Manage your preferences on web domains
When you first visit web domains (or when preference renewal is needed), a cookie banner/preferences screen may be displayed. You can make selections for non-mandatory categories; later, you can change your settings via the "Cookie Preferences" link at the bottom of the site.
Step 2: Manage your preferences in the mobile app
In the mobile app, preferences such as analytics or personalized advertising can be changed via Settings > Privacy / Ads / Tracking Preferences.
Step 3: Control via browser and device settings
You can delete/block cookies via browser settings; from mobile device settings, you can reset advertising identifiers (IDFA/GAID) or manage tracking permissions via "App Tracking Transparency" (iOS) or similar Android settings.
Step 4: "Do Not Track" (DNT) and Global Preferences
WIN aims to comply with "Do Not Track" (DNT) or similar standard privacy signals sent by your browser or operating system; where such signals are detected, it aims to restrict non-mandatory tracking activities.
You can access detailed information about cookie management from your browser's "Help" menu. Example official support pages:
- Google Chrome: Delete / manage cookies (opens in a new tab)
- Mozilla Firefox: Clear and manage cookies (opens in a new tab)
- Microsoft Edge: Privacy and browsing data (opens in a new tab)
- Apple Safari (macOS): Manage cookies (opens in a new tab)
Section 10: Your rights and application channels
This section provides a general bridge to data subject rights and application channels to WIN.
Your rights regarding processing of your personal data within the scope of cookie/tracking technologies (e.g., request information, correction, deletion, objection to processing, etc.) may be exercised under applicable legislation. For application methods and data controller contact details, the KVKK Clarification Notice should be reviewed. For questions, you can write to support@whoisnextapp.com.
WIN may update this policy according to changes in legislation, technology, or operation of the Platform. Updates may be announced through in-app notifications, publication on the web, or similar methods.
Section 12: Children's privacy and age limit
The WIN Platform is open only to individuals aged 18 and over. Therefore:
- No advertising or profiling activity directed at children (under 18) is carried out through cookie and tracking technologies.
- If it is detected that data belonging to an individual under 18 has been collected through tracking technologies, such data is deleted immediately.
Appendix: Cookie inventory and transparency standard
WIN uses the following technologies in web and mobile environments. This inventory may change depending on technical updates:
| Identifier / Tool | Provider | Category | Purpose | Retention Period | Transfer |
|---|---|---|---|---|---|
| Wix Cookies | Wix | Mandatory | Security, CSRF protection, and session management | Session / 12 Months | Abroad (Wix) |
| _ga, _gid | Analytics | User traffic analysis (GA4) | 2 Years / 24 Hours | Abroad (Google) | |
| Sentry ID | Sentry | Mandatory | Monitoring software errors and crashes | 90 Days | Abroad (Sentry) |
| Device ID / IDFA / GAID | Apple/Google | Marketing | Personalized ad delivery through AdMob | Persistent (Resettable) | Abroad (Google) |
| Firebase SDK | Mandatory / Analytics | App infrastructure and technical performance tracking | 14 Months | Abroad (Google) | |
| Store Vantage / CRM | Store Vantage | Functionality | Customer relationship and support components | Session | Abroad |
| HSTS / Security | WIN | Mandatory | SSL/TLS connection security | 1 Year | - |
| Cloud CDN | Google Cloud | Mandatory | Fast and high-performance loading of content | Session | Abroad |
You can update your preferences at any time via the Cookie Preferences Panel on our website or the Settings menu in your application.