Terms of Use

Last updated: 02.04.2026 · Version: 1.1

This document governs the legal relationship between the user and the operator regarding use of the WIN mobile application and related services. You are advised to read it carefully before accepting it. For ease of reading, short summaries appear at the start of sections; these summaries do not replace the full text.

Section 1: Introduction and Acceptance

1.1 Subject Matter and Parties

WIN is the operator of the mobile application and related online services (“Services”) offered for social matching purposes. The Services include in‑app features, web areas, and other functions WIN provides under these Terms. In this contract, the terms “operator”, “we”, or “WIN” refer to that operator’s legal entity. The operator of the Services is WIN TECH Bilişim Organizasyon ve Ticaret A.Ş. (Trade Registry No: 1128235, MERSIS No: 0811159971200001), whose official website is https://www.whoisnextapp.com/ (opens in a new tab). The operator’s title, trade registry, and contact details appear in the Contact section and in the app.

User is a natural person who registers for or uses WIN Services (“you”, “member”). These Terms of Use are the core text of the contract between you and WIN and govern your access to and use of the Services.

The Services are provided within the countries and store regions where WIN is offered (e.g. Turkey and other regions where the app is listed in app stores). When accessing from abroad, these Terms and the applicable law in Section 15 apply, subject to mandatory local consumer rights and public policy rules.

1.2 Related Documents

The following documents should be read together with these Terms of Use and apply together with use of the Services:

• Privacy Policy
• KVKK Privacy Notice
• Community Guidelines
• Safety Tips
• Subscription and Purchase Terms
• Cookie Policy
• Accessibility Statement
• Vulnerability Disclosure Policy

WIN may also provide special terms for certain features, campaigns, or purchases. Such additional terms apply to the extent they are offered to you and you accept them.

1.3 Acceptance and Entry into Force

These Terms of Use apply from the moment you access or use the Services, regardless of whether you have an account and whether you use the Services free of charge or for a fee.

These Terms of Use enter into force for you when you give electronic acceptance while creating an account or on first access to the Services. Representing that you are aged 18 or over confirms that you have read and accepted these Terms.

1.4 Changes and Updates

WIN reserves the right to update these Terms unilaterally. Changes are announced by email, in‑app notification, or publication on the site; it is your responsibility to check this page regularly to see the current text. Continued use of the Services after a change means you accept the updated Terms. For material changes relating to liability limits, dispute resolution, arbitration, or consumer rights, the app may request renewed express consent; if you do not accept, you must stop using the Service.

1.5 Information in Electronic Form and Access to the Contract

Within the scope of Law No. 6563 on the Regulation of Electronic Commerce (ETK) and Law No. 6502 on the Protection of Consumers, WIN aims to provide information relating to contracts concluded electronically and access to the contract text. In this context:

• The current version of the Terms may be published on the Site and displayed in the app.
• For transactions such as account creation or purchase, steps relating to formation of the contract and required confirmations/explanations may be provided in the app.
• Technical means to detect and correct data entry errors are provided to the extent allowed by the app’s interface.

Section 2: Terminology and Definitions

2.1 Platform Terminology

2.2 Content Categories

• Your Content: All content you upload or share, including profile information, photos, messages, and selfie verification images.
• Member Content: Content shared by other members.
• Our Content: Software, logos, interface, and brand elements belonging to WIN.

2.3 Paid Service Terms

• WIN Premium: A paid subscription package; features are defined in the Subscription and Purchase Terms.
• Package: The selected subscription period or feature set.
• Virtual items: Credits or similar items purchasable in the app; summarised in Section 9.

Section 3: Account Creation and Eligibility

3.1 Age and Capacity

WIN Services are offered only to persons who have reached the age of 18. No service is provided to minors.

In this respect:

• If there is reason to suspect you are under 18, WIN may request additional information/documents for age verification or may temporarily restrict your account.
• If it is determined that you are under 18 or age verification cannot reasonably be completed, your account may be suspended or closed.
• Misrepresentation of age is a breach of these Terms.

3.2 Registration Methods and Identity Verification Steps

Access to the account may be provided via Google Sign‑In (OAuth) or sign‑in with phone number (SMS/OTP‑based authentication). Data transferred through these routes is processed under the Privacy Policy and KVKK Privacy Notice.

Phone sign‑in: After the first identity step, email verification and phone number verification (OTP, etc.) are completed during profile creation, separately from the registration screen. Until these steps are completed, relevant parts of the service may be restricted.

Google sign‑in: The email address shared via your Google account is generally treated as already verified under Google’s processes. After profile creation, you may be directed in the app to phone number verification to give likes and similar interactions on the deck; this verification is mandatory.

By your sign‑in method you accept that:

• You are authorised to use the relevant account (Google account or phone line),
• If you use Google, taking security measures for your account (password, device security, two‑step verification, etc.) is your responsibility,
• Contract and KVKK texts may be shown during sign‑in and profile setup, and separate consent/explicit consent options may be offered for certain actions.

3.3 Eligibility Commitments

By using the Services you warrant that:

• Single account: A person may create only one WIN account.
• Personal use: Your account is personal; you may not assign, sell, lend, or jointly use it with third parties.
• Previously removed accounts: If your account was suspended or closed, you may not create a new account without WIN’s express permission.
• Accurate information: Your registration and profile information is accurate and up to date.
• Lawful use: You comply with local laws and general legal rules in countries where WIN provides the service; there is no legal bar to your use; you do not use the Services in breach of applicable law (including privacy, intellectual property, and commercial communication rules).
• Current version: You are advised to use the most current version of the Application and Site where possible; older versions may pose security and compliance risks.
• No use of another user’s account: You undertake not to use another user’s account.
• Ponzi schemes / fraud: You undertake not to use the Services in connection with pyramid schemes, fraud, or similar illegal practices.
• No implication of WIN approval: You undertake not to imply that your statements or content are approved by WIN.
• Confidential / proprietary information: You undertake not to disclose private or proprietary information you are not entitled to disclose (trade secrets, information under confidentiality agreements, etc.).
• No hiding sources: You undertake not to manipulate headers or identifiers to hide the source of transmitted information.
• Framing / embedding: You undertake not to present the Services on another site by framing or embedding without WIN’s prior written permission.
• Third‑party applications (including AI/ML): You undertake not to use or develop third‑party applications that interact with the Services or Member Content without WIN’s written permission (including artificial intelligence, machine learning, or similar automation).
• API use: You undertake not to access, use, or publish WIN’s application programming interface (API) without WIN’s written permission.
• Vulnerability research: You undertake not to research, scan, or test vulnerabilities of the Services or WIN systems without permission; for vulnerability reporting the Vulnerability Disclosure Policy applies.

At this stage WIN does not conduct official criminal record (background) checks or offence‑type screening for members. For operational difficulty of such checks, user‑safety risk management is carried out through reporting and moderation mechanisms. However, optional declaration screens (e.g. criminal or conviction history) may be offered by the app; in that case you are responsible for the accuracy of the information you provide. Such declarations are user declarations and may not mean WIN has run an official registry query.

3.4 Account Security

Keeping your sign‑in credentials confidential (including OAuth and phone‑based sign‑in) and preventing unauthorised access is your responsibility. Unless proven otherwise by law, actions taken through your account may be treated as having been performed by you.

In this respect:

• You must keep your device, account tied to your sign‑in method (Google or phone‑based session), and app access secure; you must notify WIN without delay of suspicious activity.
• For account security and prevention of abuse, WIN may temporarily restrict your account and request additional verification (e.g. selfie verification) when it detects suspicious sign‑ins or transactions.

Section 4: Provision and Use of the Services

4.1 Purpose of the Services

WIN is a platform used for social dating and matching. It does not provide marriage counselling, matchmaking services, or professional matching services.

4.2 Free and Paid Features

Features such as basic matching and messaging may be offered free of charge. Advanced features (e.g. extra visibility, advanced filters, statistics) are within WIN Premium.

The Subscription and Purchase Terms apply to paid features, trial periods, auto‑renewal, pricing, and cancellation/refund processes. To the extent permitted by law, WIN may change the scope of paid packages and feature availability over time.

4.3 Profile Creation Rules

Certain fields may be mandatory when creating a profile. For example:

• Name / profile name: With Google sign‑in the name may be taken from Google; in the phone flow you may set it during profile creation. In both cases you may change the name in the app. The profile name does not have to be your real name; however it must comply with the Community Guidelines (no insults, misleading information, etc.).
• Gender, date of birth (age)
• At least one profile photo (a clear view of the face may be required)

The app may also ask for fields such as occupation, height, smoking/alcohol frequency, zodiac sign, profile note (free text), various preference/importance questions, and photo uploads (e.g. multiple photo slots) to enrich your profile and improve matching/filtering.

4.4 Photo Verification and Blue/Green Checkmark

For account and profile security WIN performs photo‑based selfie (liveness) verification using Google Gemini 2.5 Flash. In this process:

• For your profile to appear actively in the discovery feed, at least one (1) photo must be verified.
• Verification confirms that the person in the uploaded profile photo is the same as the person in the live selfie taken at that moment. Verification with photos belonging to someone else is not possible.
• A green checkmark (or similar verification indicator) appears only on verified photos.
• Your profile may include photos taken with others; however verification is only performed on photos that belong to “you” and show your face clearly.
• Until the verification step is completed, certain parts of the service (e.g. appearing on the deck) may be restricted.

4.5 Location‑Based Features

Matching suggestions and nearby experience may rely on location information. The app may show distance on cards (e.g. “5 km away”).

WIN does not keep location history; location data is obtained in real time when the app opens via GPS or network signals and is used in distance calculations and the matching algorithm. If you turn off location permission, location‑based features may work in a limited way or not at all. Details on processing of location data are in the Privacy Policy and KVKK texts.

4.6 Onboarding: Contracts, KVKK, and Explicit Consent Layer

During onboarding, Terms of Use and data protection texts may be displayed and separate explicit consent options may be offered for certain actions. For example:

• Processing of location data
• Processing of selfie / facial verification data
• Processing of matching preferences
• Transfer of data abroad
• Campaign & notification permission

For details in this respect, see the KVKK Privacy Notice and Explicit Consent Texts.

4.7 Notifications and Communication Preferences

WIN may send in‑app notifications on security, account management, and service updates. Separate permission is obtained for marketing/announcement notifications, and that permission may be withdrawn.

Notification privacy: To protect user privacy, push notifications may not show a preview of message content (e.g. on the lock screen); notifications may only include the sender’s name and a subtitle such as “New Message”. Applicable law and the Explicit Consent Texts apply to commercial electronic communications.

4.8 Discovery Feed (Deck), Dual Picking, and the “Picked You” List

WIN’s core discovery experience works as follows:

• Dual Picking: Two different profile cards are shown. You choose one by liking it. A new candidate opens next to the profile you chose and you are asked to choose again.
• You Picked: At the end of this flow, the last person you liked is added to your list as “You Picked”.
• Picked You: Users who chose you as “You Picked” appear on this list.
• Messaging restriction: To start a chat with a user, that person must have liked you and appear on your “Picked You” list.
• List updates: Users with whom you start a chat are removed from the “Picked You” list and moved to your messages list.

The following may be shown on cards and in profile detail:

• Basic information: name, age, profile photos (including verification status), approximate distance, and online (last seen) status (visible only to Premium members).
• Parameters: height, job/occupation, zodiac sign, habits, and scores.

Premium benefits: Premium members may request: (i) the right to view 20 decks per day (Standard: 5 decks/day), (ii) x2 greater visibility advantage on decks, (iii) the ability to filter decks, (iv) hide profile, (v) viewing read receipts in messages, (vi) seeing other members’ online/offline status, and (vii) viewing their own scores and scores users gave to you/others (Intelligence, Politeness, Fun).

Section 5: User Obligations and Prohibited Conduct

5.1 General Obligations

• Comply with applicable law and the Community Guidelines,
• Read and heed the Safety Tips,
• Use other users’ content only for communication and meetings consistent with the purpose of the Service; do not use it for copying, commercial use, harassment, or unlawful threats,
• Keep your profile and contact information accurate and up to date,
• Respect others’ rights; avoid risky conduct such as harassment, abuse, or fraud,
• Not attempt to circumvent WIN’s security and anti‑abuse measures (e.g. verification, suspicious transaction checks).

5.2 Prohibited Content

The following content is prohibited. These prohibitions are assessed, for example, in light of provisions on obscenity (TCC Art. 226), threat (Art. 106), blackmail (Art. 107), insult (Art. 125), fraud (Art. 157), and privacy of communications and private life (Arts. 132–140) of Law No. 5237 Turkish Penal Code, Law No. 5651, Law No. 6698 (KVKK), and intellectual property legislation (FSEK/SMK).

5.3 Prohibited Acts

• Misleading statements on identity, age, marital status, location, etc.; opening an account on behalf of someone else; impersonation
• Opening multiple accounts, assigning/selling accounts; attempting to circumvent suspension/ban decisions (e.g. new accounts, evading restrictions, using VPN to avoid sanctions)
• Automated tools (bots), scraping, unauthorised API use; artificially inflating/deflating interactions; manipulating systems
• Reverse engineering, decompile, weakening app security; uploading viruses/malware; phishing with suspicious links
• Harassment, bullying, persistent stalking, hate speech; threat, blackmail, defamation/insult; threat of physical or sexual violence
• Requesting money/gifts/payment instruments; debt/aid/donation requests; financial redirects such as “investment opportunities”; trying to pull users to other platforms
• Illegal goods/services or brokering gambling, prostitution, human trafficking, drugs/smuggled goods, weapons, etc.
• Collecting or disclosing others’ personal data; unauthorised screenshots/message sharing; distributing intimate images without consent or threatening to do so
• Making bad‑faith/baseless reports or using reporting tools for harassment

5.4 Profile and Communication Rules

WIN aims to protect user safety and reduce fraud risk. The following rules therefore apply to profile and messaging areas:

• Sharing personal contact information (phone, email, social media account, open address, etc.) is prohibited.
• Bank details, credit card numbers, or P2P payment usernames (e.g. money transfer app username) may not be displayed or shared on the profile or in messages.
• Sharing third parties’ personal data (someone else’s phone, address, identity information, private images, message content, etc.) without permission is prohibited.
• Images where children appear alone in profile photos/bios and content that could endanger children are prohibited.
• Excessive filters/manipulation that obscure identity or create a false impression (visual alteration, hiding the face, etc.) may be prohibited or restricted.
• Commercial posts such as referral links, advertising, “sales”, or “job offers” on profiles and in content are prohibited.

Section 6: Content and Intellectual Property

6.1 Responsibility for Your Content

You alone are responsible for content you upload or share. You warrant that your content complies with applicable law and these Terms, does not infringe third‑party rights, and that you have necessary permissions.

In particular, you are responsible for:

• Obtaining explicit consent and necessary usage permissions for persons appearing in photos/videos and similar content
• Not using third‑party copyrighted works, trademarks, logos, or trade marks without permission
• Not infringing others’ personality rights, privacy rights, or personal data

The indemnity provisions in Section 12 apply to claims against WIN or third parties arising from your content.

6.2 Licence Granted to WIN (UGC)

For WIN to provide the Services, you grant WIN the following licence to Your Content. This licence applies to the extent permitted by law according to the nature of your content sharing.

6.3 Intellectual Property Infringement Notice (Notice‑and‑Takedown)

WIN takes copyright and trademark infringement claims seriously under Law No. 5846 (FSEK) and Law No. 6769 (SMK). Where a notice of infringement is submitted, content removal or access restriction may be performed according to file content and legislation. The notice should include:

The notice must be signed (physically or electronically) by the rights holder or authorised representative; you are deemed to represent that the information in the notice is accurate. Notices missing mandatory information above may not be processed. False or bad‑faith notices may have legal consequences and sanctions. The Intellectual Property (Copyright) Infringement Form may be used for notices; see the Intellectual Property Policy for details and contact channels (email/address).

6.4 Platform Content and Application Licence

Software, interface, design, database, logos, marks, and other content belonging to WIN (“Platform Content”) is owned by or licensed to WIN.

You are granted a limited right to use Platform Content personally, non‑commercially, non‑assignable, non‑sublicensable, and revocably solely to use the Services. If you breach these Terms, this licence and your right to access the Service terminate automatically.

The End User Licence Agreement (EULA) also applies to the licence to the application software and technical restrictions.

6.5 Marks and Promotional Elements

The WIN name, logo, and distinctive signs are within WIN’s trademark rights. Without WIN’s written permission you may not use the WIN mark or similar for commercial purposes, in a misleading way, or in a way that suggests affiliation with WIN.

6.6 Feedback Licence

You accept that suggestions, ideas, or feedback you send WIN for product development, security, or user experience may be used, developed, and shared by WIN without payment.

6.7 FSEK and SMK References

Copyright is protected by Law No. 5846 on Intellectual and Artistic Works (FSEK); trademarks and trade dress by Law No. 6769 on Industrial Property (SMK). Detailed rules are in the Intellectual Property Policy.

Section 7: Content Moderation, Complaints, and Enforcement

7.1 Moderation Authority

WIN applies moderation to ensure user safety, reduce unlawful content, and maintain compliance with the Community Guidelines.

Under Law No. 5651 WIN may qualify as a hosting provider. In this respect:

• A hosting provider has no obligation to monitor content it hosts in advance or to investigate unlawful activity (5651 Art. 5/1).
• However, when informed of unlawful content, an obligation to remove that content from publication may arise (5651 Art. 5/2).

WIN has no obligation to pre‑screen or review user content; however it reserves the right at its discretion to remove content, edit, restrict access, or take action on accounts.

WIN conducts moderation through user reports, automated systems, and human moderator review.

Messaging and privacy: Messaging on the platform is not end‑to‑end encrypted. Moderation teams and system administrators may review message contents in case of complaint, security signals, or suspicion of unlawfulness. Moderation may target both unlawful content and conduct that breaches the Terms/Community Guidelines.

User ratings (Intelligence, Politeness, Fun): During chat, when a certain interaction limit is reached (e.g. 10 sentences), a button may appear suggesting you rate the other user on characteristic traits (Intelligence, Politeness, Fun, etc.). These ratings are anonymised to build profile score averages and are used for a trustworthy community experience.

7.2 Complaint Mechanism

Breach reports can be made through the in‑app “Report” or reporting feature. In some cases WIN may contact you to request additional information.

7.2.1 What should be reported?

The following situations should be reported, for example:

• Harassment, threat, stalking, hate speech, bullying
• Requests for money/gift/payment information, suspected fraud, fake profile
• Non‑consensual sexual content or obscene content
• Content/suspicion relating to minors
• Unauthorised sharing of third parties’ personal data

Situations such as not receiving replies to messages, likes not being returned, or differences of opinion or identity are not generally treated as “breaches”.

7.2.2 How to report?

Where a written record or formal application is required, the Content Infringement Form may be used for content infringement notices, and the Complaint and Notification Form for general complaints/notifications.

7.2.3 Bad‑faith/baseless reports

Deliberate abuse of the reporting system (baseless, misleading, or harassing complaints) may be a breach of the Terms and subject to sanctions.

7.3 Suspension / Account Closure

Where a breach is detected WIN may take the following measures depending on the nature of the breach:

• content removal / restricted visibility
• warning
• restriction of certain features (messaging, content upload, etc.)
• temporary suspension
• permanent account closure

Repeated breaches may result in account termination. In security and abuse cases where action may be required without prior notice, WIN may act quickly.

7.3.1 Notice

Where content is removed or account restrictions are applied, you are informed in‑app and/or by email of the reason and appeal route where reasonably possible. However, not all details may be shared in every case due to other users’ safety/privacy or legal duties.

7.3.2 Appeal

An opportunity to appeal moderation decisions or a decision not to act on a report is provided.

• Method: Appeals are currently accepted via support email. You may submit your appeal by following the instructions in the decision notification. Where a written structured application is required, the Appeal Form may be used.
• Time (SLA): Appeals submitted are reviewed and concluded within 30 days at the latest. In extraordinary circumstances or operational congestion this period may exceptionally be extended; the applicant is informed in that case.
• Time limit for application: Appeals should be made within 6 months of the decision notification at the latest.

If an appeal is accepted, restrictions may be lifted. Republication of content may not always be possible due to whether content was stored and data retention periods; in that case you may be allowed to upload the content again.

For users in the EU, additional complaint/appeal channels and DSA processes are explained on the DSA Compliance Page.

7.3.3 Ban sharing with group companies

At this stage WIN does not share “banned user lists” with other apps or affiliates. However, WIN reserves the right to share breach data with group companies or business partners (in compliance with law) and to apply multi‑platform bans in the future to increase platform security.

7.4 Law No. 5651

The hosting provider liability framework under Law No. 5651 on Regulation of Publications on the Internet applies. Notices relating to unlawful content (including warning methods) are assessed and processed in compliance with the Law; retention of traffic data is also subject to the periods in this Law.

Requests from public authorities (police, prosecution, etc.) are assessed only within valid and procedurally compliant requests. Public authorities may submit illegal content notices through the Illegal Content Notification Form. See the Law Enforcement Guide and Transparency Reports for periodic reports.

Section 8: Algorithm and Automated Decision‑Making

8.1 Matching and Recommendation Systems

WIN may use recommendation systems to make the Services more useful. These systems may rank profiles shown to you, recommend them, or make certain profiles less visible.

Recommendation systems may jointly evaluate some of the following data and signals:

• Your preferences and filters (e.g. age range, distance, basic matching preferences)
• Location information (to the extent you permit) and location‑related matching signals
• Interaction history (e.g. like/pass behaviour, messaging interactions)
• Security signals (e.g. block/report relationships, verification status)
• Signals relating to profile quality/consistency (e.g. missing fields, repeated behaviour patterns)

These assessments are a predictive mechanism to increase matching likelihood; no particular match or outcome is guaranteed.

Visibility and cooldown: For profiles that appear in the discovery feed (Deck) but that you do not choose, a cooldown period may apply. During that period the same profile is not shown to you again, to encourage interaction with more users.

8.2 Profiling and Automated Assessment

WIN may perform profiling and certain automated assessments to provide personalised recommendations. Inferences may be produced about your preferences, behaviour, and how you use the Services.

Details on the scope of these processes, data categories used, legal bases, and user rights are explained in:

• KVKK Privacy Notice
• Privacy Policy

8.3 AI Use

WIN may use AI‑assisted tools for security and abuse prevention (e.g. detection of fake profiles, fraud, harassment). AI may also be used in some optional features within provision of the Services.

AI use aims to improve user behaviour and safety; it does not always produce definitive results. Signals produced by AI‑assisted mechanisms may be assessed together with human review where necessary.

Misleadingly presenting yourself or your intentions with AI‑generated content may be a breach of the Terms and Community Guidelines. See the AI Use Policy for detailed principles, data use, and appeal rights.

8.4 Automated Decisions (Security and Fraud Prevention)

WIN may apply automated decisions in some cases for service security and fraud prevention. For example:

• temporary restriction of certain features in suspicious behaviour patterns,
• blocking transactions in suspicious payment/transaction attempts,
• triggering account security steps when bot/spam behaviour is detected.

If such an automated decision has significant effects for you, information is provided where reasonably possible and a channel is offered for appeal/review requests.

8.5 Controls and Transparency

Transparency is aimed at how recommendation systems work, basic parameters they may use, and configurable options where available. As a user you may:

• change preferences and filters in settings,
• manage location permission in device settings (Privacy Policy — location data),
• block or report unwanted users,

and expect these preferences to feed into recommendation systems.

For users in the EU, reporting and transparency obligations under the DSA are additionally explained on the DSA Compliance Page.

Section 9: Payment, Subscription, and Virtual Items

9.1 General

Payment and subscription terms are set out in the following documents:

• Subscription and Purchase Terms
• Pre‑Information Form
• Distance Sales Contract
• Subscription and Purchase Terms — Section 4 (purchase process and formation of the contract)

9.2 Summary Information

• Subscriptions may auto‑renew; cancellation is performed through the Apple/Google store account where the purchase was made (WIN may provide guidance/easy access in the app). Under the Regulation on Subscription Contracts cancellation can be performed through the same channel with equal ease.
• Exceptions to the right of withdrawal under Law No. 6502 on the Protection of Consumers and the Distance Contracts Regulation may apply to digital content and services.

9.3 Virtual Items

At this stage WIN only sells Premium membership / subscription. Package prices may vary according to market conditions; current prices are always shown on in‑app purchase screens. Virtual currency, credits, or spendable items purchasable in the app are of a licence nature; they are non‑assignable and not redeemable for cash. If such virtual items are added in the future, refund and use terms will be additionally stated in the Subscription and Purchase Terms.

Section 9A: Advertisements and Third‑Party Content

The Services may include advertisements, promotions, sponsored content (banners, video, etc.) provided by third parties, or links to external websites/resources. AdMob (Google) infrastructure may be used for in‑app advertising services.

WIN does not endorse such advertisements or third‑party content; it is not responsible for the availability, accuracy, or content of third‑party sites, resources, or products/services they offer. Your interaction with such content is subject to the third party’s own terms of use and privacy policies. No guarantee is given that advertisements will always be shown or in a particular format; WIN reserves the right to change advertising models at any time.

Section 10: Privacy and Data Protection

10.1 Reference

Privacy and personal data processing rules are explained in the following documents. By using the Service you are deemed to have accepted these policies:

• Privacy Policy
• KVKK Privacy Notice
• KVKK Application Form — Form and directions for exercising your personal data rights.
• Complaint and Notification Form — Written application form for Community Guidelines breaches or user conduct complaints.
• Content Infringement Form — Written application form for reporting content that breaches platform rules (moderation).
• Illegal Content Notification Form — Form used by public authorities for illegal content notifications under 5651/DSA.

10.2 Summary

WIN is the data controller under Law No. 6698 on the Protection of Personal Data (KVKK). Your data is processed for purposes including service provision, security, analytics, and legal obligations; privacy notices compliant with the KVKK Privacy Notice Communiqué are provided. To exercise your rights under KVKK Art. 11 (information, rectification, erasure, objection, etc.) you may download the form from the KVKK Application Form page and submit your application. A Cookie Preference Panel (CMP) is provided on our web areas and you may update your preferences at any time. Where there is transfer abroad, this is stated under the Privacy Policy and the Regulation on Transfer of Personal Data Abroad.

You accept that in cases such as legal obligation, enforcement of these Terms, protection of third‑party or WIN rights, or investigation of suspected crime/fraud WIN may access, retain, or disclose your account information (including content); details are in the Privacy Policy.

Section 11: Disclaimer and Limitation of Liability

11.1 “As Is” Statement

The Services are provided “as is” and “as available”. No guarantee of uninterrupted or error‑free operation is given. No undertaking is given as to compatibility of matches or relationships.

To the extent permitted by applicable law, WIN gives no warranty in respect of:

• the Services always being accessible/working, being secure, or operating without errors
• errors always being corrected or the Services delivering a particular performance/outcome
• in‑app content (including user content) being complete, accurate, up to date, or fit for your purpose
• a certain number of active users at a given time, or users contacting or meeting you
• no interruption or failure arising from your internet service provider, device, operating system, or third‑party services (Apple/Google stores, payment infrastructure, etc.)

11.2 User Interactions

In all interactions with users, including messaging, content sharing, or in‑person meetings, assessment of risk and decisions are yours. Although WIN may take technical and operational measures to prevent harm if you share personal information with another user or leave the app, it cannot control every outcome. WIN cannot be held liable for technical damage from security breaches, viruses, errors, interruptions, network failures, or third‑party services.

11.3 Liability Cap

In accordance with Law No. 6098 Turkish Code of Obligations (TBK) and Law No. 6502 on the Protection of Consumers, WIN’s total contractual liability (subject to mandatory consumer rights) may be limited to the total subscription fees paid in the last 24 months or a fixed amount. This limit does not eliminate mandatory statutory consumer rights.

To the extent permitted by applicable law WIN cannot be held liable for loss of profit, reputational loss, data loss, business interruption, indirect/consequential damages, or similar items.

The limitations in this section do not apply or apply only to the extent permitted with respect to:

• damages caused intentionally or with gross negligence,
• consumer rights and liability situations that cannot be limited by law, and
• provisions that may be deemed unfair terms under Law No. 6502.

The liability limitations in this section remain valid even if remedies available are unsuccessful in achieving their purpose.

Section 12: Indemnity

12.1 User Indemnity Obligation

You agree to indemnify WIN, its managers, employees, and business partners for damages, costs, and reasonable attorneys’ fees they suffer due to third‑party claims (including lawsuits, damages, and administrative sanction claims) arising from breach of these Terms or applicable law, Your Content, or use of your account, to the extent permitted by applicable law.

Your indemnity obligation may arise in particular where:

• Your Content or conduct infringes third parties’ personality rights, intellectual property rights, or privacy rights
• Conduct such as fraud, fake profile, harassment, threat, unauthorised data sharing
• Claims arising from unlawful use directed at third parties or WIN

WIN will endeavour to inform you reasonably of a claim falling within indemnity. You are expected to provide necessary information and documents, support the defence reasonably, and cooperate to prevent aggravation of damage.

This clause does not eliminate WIN’s liability for damages arising from WIN’s own fault and does not limit mandatory consumer law provisions.

Section 13: Account Termination and Cancellation

13.1 Termination by User

Termination relating to your account may take two forms: (i) deactivating the profile (turning off visibility) and (ii) deleting the account (permanent closure). In‑app steps and legal consequences are detailed below (in particular 13.1.2 Deleting the account).

13.1.1 Deactivating the profile (turning off visibility)

If you wish, you may deactivate your profile temporarily without deleting your account and make it invisible to other users. When the profile is deactivated:

• Your profile is not visible to other users.
• This does not automatically eliminate data retention and retention periods for legal obligations (see Privacy Policy for details).
• After you deactivate your profile, if you reactivate your account within a certain period, your profile and data linked to your account may be restored (to the extent permitted by law). After that period, full deletion of the account may occur.

13.1.2 Deleting the account (permanent closure)

You may delete your account by following Settings > Account > Delete Account (or similar) in the app. Account deletion is generally irreversible and may have the following consequences:

• Your profile and visible areas linked to your account are closed to other users.
• Temporary freeze (deactivation): With your deletion request your account is frozen for 14 days. During that period if you sign in to the app again, you may cancel deletion and continue or manually complete the permanent deletion process. After the 14‑day period your data is permanently deleted.
• In‑app access to matches, messages, and similar records linked to your account may end.
• In‑app virtual items/benefits and promotion definitions may end with the account and refund/payment may not be available (mandatory legal rights reserved).

13.1.3 Removing the app from the device

Removing the app from your phone does not by itself delete your account. If you wish to close your account you must follow the relevant steps in the app.

13.1.4 Subscription cancellation (independent of account deletion)

Subscription cancellation is a separate action from deleting the account. Cancelling the subscription does not automatically remove your profile; likewise deleting your account may not automatically stop auto‑renewal on the store side if the subscription was started through the store.

• If you started the subscription through Apple App Store or Google Play, cancellation/renewal management is done through the relevant store account.
• When you cancel the subscription, unless otherwise stated subscription benefits may continue to be used until the end of the period.
• See the Subscription and Purchase Terms for subscription and purchase details.

Information on termination of subscription contracts and consequences is provided under Law No. 6502 and the Regulation on Subscription Contracts.

13.2 Termination by WIN

WIN may terminate your account with a warning, by restricting certain features, by temporary suspension, or by permanent closure in cases such as breach of these Terms, the Community Guidelines, or applicable law, abuse, security risk, suspected fraud, multiple accounts, suspicion of being a minor, infringement of third‑party rights, unlawful content, conduct endangering system security, or requests from public authorities.

Where the account is closed or suspended by WIN, refunds of amounts paid are possible only under mandatory consumer law and the refund policies of the purchase channel (Apple/Google, etc.). Important: Where the account is closed due to breach of the Community Guidelines or Terms of Use (ban), no fee refund is made for the current period for amounts already paid.

For the purpose of preventing security and abuse, minimum data necessary to prevent users whose accounts were closed from opening new accounts may be retained in compliance with law under the Privacy Policy.

13.3 Deletion of Passive (Inactive) Accounts

WIN may delete accounts that have been inactive for a long time for data minimisation and security. Whether an account has been inactive for a long time may be assessed by indicators such as not using the app for a long time and/or the app not connecting to servers for a long time.

For example, accounts that have been inactive for 2 years may be treated as passive. For deletions in this scope, advance notice is sent to your registered email address where reasonably possible. If you reactivate your account/sign in to the app during the notice period, deletion may be stopped. After deletion, recovery of the account may not be possible.

13.4 After Termination (Consequences and Data Retention)

After the account is deleted or closed:

• Your profile and visible areas linked to your account are closed within the app.
• Digital benefits and virtual items linked to your account may end; in that case no additional compensation is generally paid (mandatory legal rights reserved).
• Retention and erasure of personal data are carried out under the Privacy Policy and Law No. 6698 (KVKK). Under KVKK, where processing grounds cease, data is erased/destroyed/anonymised; retention provisions in other laws remain reserved.
• Under Law No. 5651, hosting providers may have an obligation to retain traffic data relating to the service for certain periods. In this respect traffic data may be retained for the periods provided by law (5651 Art. 5/3: not less than one year and not more than two years).

13.5 Survival

Termination of the account does not eliminate provisions that must continue to apply by their nature after they end. In particular provisions on intellectual property/licence, liability limits, indemnity, dispute resolution, applicable law, and jurisdiction remain in force.

Section 14: Dispute Resolution and Arbitration

14.1 Pre‑Discussion

For serious disputes the parties agree to hold written discussions (pre‑discussion) for at least 60 days before litigation or arbitration. The parties agree to negotiate in good faith to resolve the dispute. Notice is given via registered email or to WIN’s official support/legal email stated in the app/Site or Contact (opens in a new tab). The notice must include at least: (1) your first and last name, (2) information identifying your account (e.g. registered email, username), (3) a short summary of the dispute, the outcome you seek, and if applicable calculation of damages you claim. Offers, promises, or conduct by the parties during pre‑discussion may not be adduced as evidence in subsequent legal proceedings (litigation or arbitration); this rule is subject to legal mandatory rules.

14.2 Application in Türkiye

14.3 EU / UK Users

For users resident in the EU or the United Kingdom, the ODR (Online Dispute Resolution) platform and restrictions on mandatory arbitration apply under relevant law.

Section 15: Applicable Law and Jurisdiction

15.1 Applicable Law

These Terms of Use and disputes relating to the Services are governed by the laws of the Republic of Türkiye. In particular the following legislation applies:

• Law No. 6502 on the Protection of Consumers – consumer transactions, unfair terms (Art. 5), Consumer Arbitration Committee (Arts. 66–72) and consumer courts (Art. 73), and jurisdiction in consumer claims (Art. 73/5: consumer court at consumer’s place of residence or under general jurisdiction rules).
• Law No. 6563 on the Regulation of Electronic Commerce (ETK) – contracts concluded electronically, duty to provide information (Art. 3), and information on alternative dispute resolution mechanisms where applicable.
• Law No. 6100 on Civil Procedure (HMK) – consumer court cases are conducted under Part Six of the HMK (Law No. 6502 Art. 73/4).
• Distance Contracts Regulation – based on Arts. 48 and 84 of Law No. 6502; pre‑information and contract terms in distance sales and digital content contracts.

For users with consumer status, the Consumer Arbitration Committee (mandatory application below certain monetary thresholds) and consumer courts under Law No. 6502 remain available; mandatory arbitration to the consumer’s detriment cannot be imposed.

For users resident in the European Union, European Economic Area, United Kingdom, or Switzerland: The applicable law and jurisdiction clauses in these Terms do not eliminate mandatory consumer protection rules in the relevant countries; local mandatory rights remain reserved. See Section 14.3 EU / UK Users for dispute resolution.

15.2 Courts and Enforcement Offices with Jurisdiction

For disputes arising from these Terms, the Services, or the relationship between you and WIN that do not qualify as consumer claims under Law No. 6502, the courts and enforcement offices with jurisdiction are the Istanbul Anatolian Courts and Istanbul Anatolian Enforcement Offices.

As a consumer, under Art. 73/5 of Law No. 6502 consumer claims may also be brought at the consumer court in the place where you reside; this right cannot be limited by contract.

15.3 Language

The official and principal text is Turkish. Under Art. 4 of Law No. 6502, contracts must be drafted in at least 12 point, in understandable language, clearly, simply, and legibly. Translated texts are provided for convenience only; in case of dispute the Turkish text prevails.

Section 16: Miscellaneous

16.1 Entire Agreement

Together with the Privacy Policy, KVKK Privacy Notice, Community Guidelines, and additional terms accepted at purchase, these Terms of Use constitute the full agreement between you and WIN regarding the Services. They replace prior oral or written agreements, understandings, or statements; this clause does not eliminate liability for misrepresentation where not limited by law.

Severability: If any provision of these Terms is held invalid, unlawful, or unenforceable by a competent court or administrative authority, only that provision is invalid; other provisions remain in full force unless they seriously upset the overall balance of the contract.

16.2 Waiver

WIN’s failure or delay to exercise any right, power, or privilege is not a waiver of that right. Any single or partial exercise of a right does not prevent future exercise of that or other rights. No one‑sided tolerance of breach of any provision means that provision no longer applies.

16.3 Assignment and Transfer

• User: You may not assign your rights and obligations under this contract to third parties. Your account is personal and non‑assignable; unless the law provides otherwise, rights relating to the account upon the account holder’s death are assessed under applicable inheritance law rules.
• WIN: WIN may assign its business, assets, or rights and obligations under these Terms in a merger, acquisition, or transfer, with prior notice. In that case your contract continues with the transferee.
• Contract transfer: WIN reserves the right to transfer your contract to a company it deems appropriate for good reason (e.g. fundamental change of business model, legal requirement); in that case reasonable advance written notice is given. The notice states the transferee company and the reason. You retain the right to terminate the contract during that period; if you do not terminate, the transfer takes effect on the date stated in the notice.

16.4 Contact

• Operator: WIN TECH Bilişim Organizasyon ve Ticaret A.Ş. — Trade Registry No: 1128235, MERSIS No: 0811159971200001. Address: Acıbadem Mah. Asafbey Sk. İmer Apt. No: 7 A, Kadıköy / Istanbul. Tax Office: Kadıköy Tax Office — Tax ID No: 8111599712. Official website: www.whoisnextapp.com (opens in a new tab). Email: support@whoisnextapp.com.
• Contacting WIN: For questions, complaints, or requests you may use in‑app “Help”, “Report”, or “Contact”, the contact page on whoisnextapp.com (opens in a new tab), or the email/postal address announced by WIN.
• WIN contacting you: WIN may send contractual and legal notices to your registered email address, in‑app notification, or by publication on the app/Site. For contractual purposes these methods count as written notice; exceptions under law remain reserved.
• Up‑to‑date information: You must keep your contact details (email, phone, etc.) up to date. WIN cannot be held liable if notices do not reach you due to out‑of‑date information.

16.5 No Agency, Partnership, or Representation

These Terms of Use do not create an agency, partnership, joint venture, franchise, or employer–employee relationship between you and WIN. You may not make commitments on behalf of WIN or binding statements about WIN.

16.6 Headings

Section and subheadings in this text are for readability and convenience only; they have no binding legal meaning in interpreting the contract.

16.7 Electronic Communications and Notices

By using the Service you agree to receive communications and notices from WIN electronically (email, in‑app message, push notification, etc.). Terms, notices, and disclosures WIN sends you electronically are deemed written for contractual and legal purposes unless applicable law provides otherwise.

16.8 Consumer Arbitration Committee and Litigation

Your consumer rights under Law No. 6502 on the Protection of Consumers (including Consumer Arbitration Committee and consumer court routes) remain reserved. Unless required by applicable law WIN is not obliged to participate in mandatory dispute resolution before the consumer arbitration committee; your right as a consumer to go directly to court is regulated by law.