Privacy Policy

WinnerInvoice — Mobile Invoicing & Estimates

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

1. Who We Are

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

Disclaimer: WinnerInvoice is a mobile invoicing tool for field professionals and small businesses. It is not a full accounting system, tax advisory service, or official financial reporting tool. Users are responsible for ensuring their invoices comply with applicable tax and business regulations in their jurisdiction.

2. Scope — Two Data Categories

WinnerInvoice processes two distinct categories of personal data, and our role differs for each.

Category A — User Data (your personal data)

Data you provide when creating an account, configuring your business profile, or using the app. We are the data controller for this data.

Category B — End-Client Data (your customers' personal data)

Personal data about your customers that you enter into the app when creating invoices, estimates, and client records — such as customer names, contact details, addresses, and tax IDs. You are the data controller for this data; we act as a data processor on your behalf.

Your responsibility as data controller: When you enter your customers' personal data into WinnerInvoice, you must ensure you have a lawful basis to process that data (e.g. performance of a contract, legitimate interest) and that you comply with applicable data protection laws in your jurisdiction. We process end-client data only as instructed by you to provide the Service.

3. Data We Collect

3.1 Account Information (Category A)

If you create an account:

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

3.2 Business Profile Data (Category A)

• Trading name, business address, tax or VAT number
• Logo and brand colours (used on your PDF documents)
• Preferred language and currency

3.3 Invoice and Document Data (Category A + B)

• Invoice and estimate content: line items, descriptions, quantities, prices, tax rates
• Document status (draft, sent, paid)
• Your own data: document reference numbers, notes, payment terms
• Customer data you enter: customer name, company name, contact details, address, tax ID

3.4 Customer Records (Category B — you are the data controller)

• Customer names, company names
• Phone numbers and email addresses
• Billing addresses
• Tax / VAT identification numbers
• Job history and transaction records

3.5 Subscription and Purchase Data (Category A)

• Subscription tier and status (free, active, expired, cancelled)
• Purchase date, renewal date, transaction ID
• Platform of purchase (App Store or Google Play)

We never receive your payment card details. All payment processing is handled by Apple or Google.

3.6 App Usage Data (Category A)

• Aggregate feature usage statistics (anonymized)
• Session timestamps, app version
• Offline draft queue activity

3.7 Device and Technical Data (Category A)

• Device type and model, OS version, app version
• IP address (truncated where possible), time zone
• Crash logs and error reports

3.8 Push Notification Data (Category A)

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

3.9 Communications Data (Category A)

• Email address and message content from support contacts

4. Demo Mode

WinnerInvoice offers a try-before-you-signup demo mode. In demo mode:

• No account is required
• All data (including any customer data you enter for testing) is stored locally on your device only
• No personal data is transmitted to our servers
• Demo data is cleared when you uninstall the app or create a full account (depending on your choice)

5. How We Collect Your Data

6. Legal Bases for Processing

7. How We Use Your Data

Core App Functionality

• Creating and managing your account and business profile
• Enabling invoice and estimate creation, PDF generation, and document management
• Syncing your data between devices via cloud backup
• Managing your customer ledger and job history
• Enabling offline draft creation and later sync
• Tracking payment status and generating simple reports
• Managing your subscription and unlocking plan features

App Quality

• Diagnosing crashes, fixing bugs, improving performance

Communications

• Transactional messages (subscription receipts, updates)
• Feature notifications and reminders (with your permission)
• Marketing messages (with your explicit consent only)

8. What We Do Not Do

• We do not sell your personal data or your customers' data to any third party.
• We do not use your customers' data for our own marketing, profiling, or advertising purposes.
• We do not share invoice or customer data with advertising networks.
• We do not use advertising identifiers (IDFA on iOS, GAID on Android).
• We do not access your invoices for any purpose other than providing the Service to you.
• We do not knowingly collect data from children under 18.

9. WhatsApp and Email Sharing

When you share a PDF invoice or estimate via WhatsApp or email:

• The PDF is generated on your device and shared through your device's native share mechanism.
• Sharing via WhatsApp is subject to WhatsApp's Privacy Policy (https://www.whatsapp.com/legal/privacy-policy).
• Sharing via email is subject to your email provider's terms and policies.
• Once a PDF leaves the app via sharing, it is outside our control.
• The PDF may contain your customers' personal data (name, address, contact details) — you are responsible for ensuring you have the right to share this information with the intended recipient.

10. Subscriptions and Billing

WinnerInvoice offers a free tier with core features and paid subscription plans for advanced features. All billing is managed directly by:

• Apple (App Store, iOS)
• Google (Google Play, Android)

We never receive or store your payment card details. All payment processing is handled by Apple or Google.

To manage or cancel your subscription:

• iOS: Settings → [your name] → Subscriptions → WinnerInvoice
• Android: Google Play → Profile → Payments & subscriptions → Subscriptions → WinnerInvoice

11. Third-Party Services

We do not integrate advertising SDKs or third-party behavioural analytics platforms into WinnerInvoice.

12. Data Sharing and Disclosure

We do not share invoice content, customer data, or business financial data with advertising networks.

13. International Data Transfers

ICI Tech Teknoloji A.Ş. is based in Turkey. Some infrastructure providers operate internationally. All international transfers are subject to appropriate safeguards per KVKK Article 9, including standard contractual clauses.

14. Data Retention

Account deletion: We delete or irreversibly anonymize your data within 30 days, except where a longer period is required by law.

Note on financial records: Invoice data may be subject to longer retention obligations under applicable tax and commercial law in your jurisdiction. You are responsible for maintaining your own compliant records independently of our platform.

15. Security

• TLS 1.2+ encryption for all data in transit
• Encryption at rest for all server-stored data
• Cloud sync uses encrypted connections
• Access controls restrict who can access invoice and customer data
• Regular security assessments
• Data breach response plan in place; breach notifications per KVKK requirements

16. Push Notifications

Manage in Settings → Notifications or your device settings.

17. Children's Privacy

WinnerInvoice is a business tool intended for users aged 18 and older. We do not knowingly collect data from minors. Contact app@icitech.com.tr if you believe a child has submitted data.

18. Your Privacy Rights

We respond within 30 days, free of charge.

19. Cookies and Tracking

Our website uses cookies. A consent banner is shown on first visit.

The WinnerInvoice app does not use advertising identifiers.

20. EEA and UK Users

If you are in the EEA or UK, the GDPR applies. Please read our full GDPR Privacy Notice which covers GDPR Article 28 data processing obligations, Standard Contractual Clauses, EU Representative status, supervisory authority contacts, data portability, and 72-hour breach notification rights.

21. Changes to This Policy

For material changes, we notify you at least 14 days in advance. Current version always at /en/privacy.

22. Contact Us

We acknowledge enquiries within 5 business days.

23. Governing Law

This Policy is governed by the laws of the Republic of Turkey, including KVKK No. 6698. Disputes are subject to Turkish court jurisdiction.