Intellectual Property Policy

Last updated: 19.02.2026 · Version: 1.0

This policy contains detailed explanations regarding the intellectual property rights approach for content available on the WIN platform ("Platform") and the WIN brand, including how infringement claims are reported (notice-and-takedown), objection/counter-notice processes, and the repeat infringer approach.

This policy applies together with the Terms of Use and the In-App License Agreement (EULA).

Related documents

Section 1: Purpose, scope, and legal basis

1.1 Purpose

The purposes of this policy are:

• protecting Platform Content and the WIN brand,
• addressing infringements quickly and fairly for users and rights holders,
• preventing incorrect/unfounded notices and abuse,
• providing transparency and objection mechanisms to the extent appropriate.

1.2 Scope (which channels and content)

This policy covers the following channels and content:

• WIN mobile application (iOS/Android),
• WIN web domains (e.g. whoisnextapp.com (opens in a new tab)),
• User Content shared by users through the Platform,
• Platform Content owned by WIN or licensed by WIN,
• the documentation portal related to the Platform and texts published there.

1.3 Applicable legislation (general reference)

WIN's intellectual property approach is designed particularly with the following regulations in mind:

• Law No. 5846 on Intellectual and Artistic Works (FSEK) - copyright and work protection (including software, text, visual content, and content that may qualify as databases/compilations).
• Industrial Property Law No. 6769 (SMK) - protection of trademarks, designs, patents, and other industrial rights.
• Digital Millennium Copyright Act (DMCA - U.S.) - the "notice-and-takedown" approach, accepted as a global standard especially regarding copyright infringement notice procedures under U.S. law.

Note: This policy does not eliminate the mandatory provisions of applicable law; different procedures may apply in the relevant jurisdiction.

Section 2: Definitions

Section 3: Platform Content and WIN brand

3.1 Ownership of rights over Platform Content

Software, interface, design elements, texts, visuals, logos, database structures, and similar elements of the WIN application are protected under applicable legislation, primarily FSEK and SMK.

The following unauthorized actions regarding this content are prohibited:

• copying/reproducing,
• modifying,
• distributing,
• communicating to the public,
• using for commercial purposes,
• using to develop derivative products/services.

3.2 Limited right of use granted to the user

The user is granted a limited right to use Platform Content solely to use the Services as intended. The EULA additionally applies for licensing of application software and technical restrictions.

The WIN name, logo, distinctive signs, and (if any) product names are within the scope of WIN trademark rights. Registration processes for the WIN brand are ongoing, and unless otherwise stated in writing, all rights belong to WIN.

Use of the trademark is strictly prohibited without WIN's prior explicit written permission. In this context, in particular:

• You may not use the trademark or a similar mark in a way that creates unfair competition,
• You may not use the trademark for commercial purposes or in a manner that creates a false impression of "partnership/endorsement,"
• You may not misuse the trademark or use other signs that may be confused with the WIN brand.
• For use by press, business partners, or influencers, written approval from WIN must be obtained, and the scope of use and (if any) visual standards must be specified.

If there is a use authorized by WIN, the scope of use (where, for how long, in what format) and required statements/labels (e.g. "used with permission" statement) are also specified in the permission letter.

Section 4: User Content and respect for third-party rights

4.1 User Content, as a rule, belongs to the user

Your rights over User Content and the usage licenses you grant to WIN are regulated in the Terms of Use. This policy focuses particularly on the procedure for reporting and processing infringements.

4.2 User commitments (ownership and permissions)

By uploading content to the Platform, you represent that you have the necessary rights over the content and that you do not infringe third parties' copyright/trademark/design/patent rights, personality rights, privacy rights, or other rights.

Examples of infringement (non-exhaustive):

• Using someone else's photo as a profile picture without permission,
• Sharing copyrighted visual/illustration/music works without permission,
• Using a trademark logo in a profile in a way that gives the impression of an "official account,"
• Unauthorized use of third-party trademarks when advertising products/services.

4.3 Possible sanctions in case of infringement

Depending on the nature of the infringement, WIN may, to the extent permitted by applicable law:

• remove content / restrict access,
• warn / temporarily suspend / close the account,
• (where appropriate) contact relevant persons/institutions,
• take action in line with requests from official authorities.

Section 5: Infringement notice (notice-and-takedown) - General rules

5.1 Who can submit a notice?

As a rule, a notice must be submitted only by:

• the relevant rights holder or
• an authorized representative acting on behalf of the rights holder (e.g. attorney, trademark attorney)

When necessary, documents verifying representation authority (power of attorney/authorization document, etc.) may be requested.

5.2 For which infringement types?

The single and official channel for copyright/trademark and other intellectual property infringement notices is announced in the in-app "Legal" section and on whoisnextapp.com (opens in a new tab). For now, notices are accepted via support@whoisnextapp.com. The Intellectual Property (Copyright) Infringement Form may be used for structured notices.

5.4 Notices that are incomplete or contain abuse

WIN reserves the right not to process notices or to request additional information for notices that:

• do not contain mandatory elements,
• are not sufficiently specific (content location cannot be identified),
• are clearly malicious/unfounded,
• are assessed to have the sole purpose of harassing the user.

Clearly unfounded notices may also lead to sanctions for the notifying user (see Terms of Use).

Section 6: Copyright infringement notice (FSEK / DMCA approach)

6.1 Required information for submitting a copyright infringement notice

In your copyright infringement notice, you should provide as much of the following information as possible:

Subject: Copyright Infringement Notice (Notice-and-Takedown) - WIN

1) Rights holder / representative details
- Name-Surname / Title:
- Company/institution (if any):
- Representation authority (if you are a representative): [power of attorney/authorization document attached]

2) Work / rights ownership
- Title/description of the work:
- Date of first publication of the work (if any):
- Link/evidence showing rights ownership (if any):

3) Infringing content (location on Platform)
- Username / profile:
- Content type (photo/video/text/other):
- Content location/ID/URL:
- Screenshot / attachments:

4) Statements
- Good-faith statement: I believe in good faith that the complained-of use is not authorized by the rights holder/representative/law.
- Accuracy and authority statement: I declare that the information in this notice is accurate and that I am authorized to act on behalf of the rights holder.

5) Contact
- E-mail:
- Phone:
- Mailing address (if any):

Signature:
Date:

Subject: Counter-Notice / Objection - Content removed due to copyright notice

1) Identity and contact
- Name-Surname:
- Username / account identifier:
- E-mail:
- Phone (if any):

2) Removed content
- Content type:
- Content location/ID/URL:
- Date/ID of removal notice (if any):

3) Grounds for objection
- Grounds that the content belongs to me / is licensed / is authorized use / is a misidentification:
- Supporting documents (if any):

4) Statement
- I declare that the information I provided in this objection is accurate.

Signature:
Date:

6.2 WIN review and action flow (general)

When evaluating copyright infringement claims, WIN typically follows the steps below:

6.3 Counter-notice / objection (claim of erroneous removal)

If you believe removal is erroneous on grounds such as:

• the content belongs to you,
• there is a license/permission for use,
• it falls under a legal exception such as "fair use / quotation / parody,"
• it was removed due to incorrect content matching,

you may submit an objection/counter-notice.

Counter-notices are, as a rule, accepted via e-mail (support@whoisnextapp.com). WIN performs the initial review within 5 business days at the latest from receipt of the counter-notice. In later periods, it is planned to manage objection processes directly through in-app screens.

As a rule, the following elements are expected in a counter-notice:

• your identity and contact details,
• a clear description of the removed content and its location on the Platform,
• statement and grounds that removal was due to error/misidentification,
• (where applicable) undertaking as to the accuracy of the statement and signature.

6.4 Repeat infringer approach

As in the DMCA approach, WIN may suspend or terminate accounts of users assessed to have committed repeated infringement, under appropriate conditions and reasonable criteria.

In the assessment, the following elements may be considered (without limitation):

• severity and frequency of infringement,
• repeated infringements in the same content type,
• consistency of notices and evidentiary strength,
• user's good-faith cooperation and corrective behavior.

Section 7: Trademark infringement notice (SMK)

7.1 Required information for trademark infringement notice

In a trademark infringement notice, you should provide as much of the following information as possible:

• the trademark/sign you claim is infringed (word mark, logo, slogan, etc.),
• trademark owner and (if any) registration details (country/authority, class, registration number, etc.),
• which goods/services the trademark is used for,
• the location of infringing use on the Platform (username, profile/listing, screenshot, date/time),
• grounds for likelihood of confusion or misuse,
• good-faith and accuracy statement, contact details, and signature.

Subject: Trademark Infringement Notice - WIN

1) Trademark/sign information
- Trademark/sign (word mark, logo, slogan, etc.):
- Trademark owner:
- Registration details (if any): [country/authority, reg. no, class, scope]
- Goods/services where the trademark is used:

2) Infringement claim (location on Platform)
- Infringing username / profile:
- Content type (profile name, logo usage, visual, text, etc.):
- Content location/ID/URL:
- Screenshot / attachments:

3) Grounds
- Explanation of likelihood of confusion / misleading representation / imitation appearance:

4) Statements
- Good-faith statement: I believe in good faith that the use subject to this notice is not authorized by the trademark owner/representative/law.
- Accuracy and authority statement: I declare that the information in this notice is accurate and that I am authorized to act on behalf of the trademark owner.

5) Contact
- E-mail:
- Phone:
- Mailing address (if any):

Signature:
Date:

7.2 Review and possible actions

In trademark infringement claims, WIN may evaluate likelihood of confusion, misleading representation, imitation appearance, and similar elements and apply content removal/access restriction or account sanctions.

7.3 Objection

If the user sharing the content claims to have the right to use the trademark (license, authority, legitimate use, etc.), they may object with supporting documents. WIN may request additional information and documents.

Section 8: Other intellectual property claims (design, patent, trade secret, etc.)

8.1 Design/patent claims

In design or patent claims, the following information may be requested:

• design/patent details (country/registration, number, scope),
• description of the feature/product subject to infringement,
• location and evidence of infringing content on the Platform,
• requested action (removal/access restriction, etc.).

8.2 Trade secret/know-how claims

Trade secret claims often involve confidentiality sensitivity. In such notices, WIN may request:

• more controlled communication channels,
• limited-access review,
• additional verification.

Section 9: Infringements outside the Platform (unauthorized use of User Content outside WIN)

If you believe your User Content has been taken outside the Platform and used without authorization:

• collect links/evidence of where the infringement occurred,
• use the relevant platform's own takedown mechanisms,
• and also notify WIN.

Under the Terms of Use, WIN may, where it deems appropriate and without obligation, assist you regarding your notice against unauthorized uses outside the Platform. This defines an authority for WIN and cannot be interpreted as an obligation.

Section 10: Personal data, evidence retention, and transparency

10.1 Evidence Retention and Data Minimization

Intellectual property notices, decision records, and evidence are retained as follows pursuant to the KVKK principle of "retention for the period necessary for the purpose for which they are processed":

• IP and Traffic Records (Logs): retained for 2 years pursuant to our hosting provider obligations under Law No. 5651.
• Decision Records and Infringement Evidence: user complaints, infringement notices, and sanction records are retained for 2 years following the process pursuant to right of defense and legitimate interest.
• Contractual and Commercial Evidence: Terms of Use approval and financial transaction records are retained for 10 years pursuant to Turkish Code of Obligations Art. 146.

10.2 EU/DSA bridge

If services are provided in the EU, some content qualifying as intellectual property infringement may be handled within the scope of "illegal content." In this case, provisions of the DSA Compliance Page are additionally taken into account for notice/objection and statement-of-reasons processes.

Section 11: Changes

WIN may update this policy due to legislative changes, security requirements, product developments, or operational needs. The current text is published in the in-app "Legal" section and on whoisnextapp.com (opens in a new tab).

The official communication channel for intellectual property notices (support@whoisnextapp.com) is published in the in-app "Legal" section and on whoisnextapp.com (opens in a new tab). The Intellectual Property (Copyright) Infringement Form page may be used to submit a notice. For general communication details, the "Communication" section in the Terms of Use also applies.