EU डिजिटल सर्विसेज़ एक्ट

1. Who we are

1.1. TakeTurn is provided by the provider named in Section 1.1 of our Terms of Service (RETROBOND TEKNOLOJİ BİLİŞİM LİMİTED ŞİRKETİ, a limited liability company established in Turkey, Cumhuriyet Mah. Fatih Sultan Mehmet Blv. Cadde 224 No: 41 A/A, Nilüfer, Bursa, Türkiye) ("TakeTurn", "we" or "us"). TakeTurn is an online platform under the DSA: users send photos ("Takes") to friends they choose. There is no public feed.

1.2. This page should be read with our Terms of Service, Community Guidelines, Privacy Policy, Safety Center and Child Safety Standards.

2. Single point of contact for authorities (Article 11)

2.1. Member State authorities, the European Commission and the European Board for Digital Services can contact us by email at the address in Section 14. Please put "DSA: Authority" in the subject line and include your name, role, the authority you represent and a reply address on an official domain.

2.2. Languages. You can write to us in English or in any language the app is available in.

2.3. Orders. Orders to act against illegal content (Article 9) and orders to provide information (Article 10) can be sent to the same contact. We confirm receipt and tell the issuing authority, without undue delay, what we did and when. Requests from law enforcement under other laws are covered in our Law Enforcement Guidelines.

3. Single point of contact for users (Article 12)

3.1. Users can reach us directly and quickly through Settings > Report an issue in the app, the form at taketurn.co/support, or by email (Section 14). A person, not only an automated tool, handles your message.

3.2. You can write to us in English or in any language the app is available in.

4. Providers not established in the EU (Article 13)

4.1. TakeTurn is not established in the EU. Member State authorities, the European Commission, the European Board for Digital Services and users can contact us directly about every matter related to the DSA: by email at support@taketurn.co (Sections 2 and 3) or by post to the provider named in Section 1.1. If we appoint a legal representative in the EU, we will name them on this page.

5. Our rules and how we moderate (Article 14)

5.1. Our rules are in our Terms of Service (Sections 9 to 11) and Community Guidelines. They explain what is not allowed and what we may do if rules are broken.

5.2. How we moderate. A small team of human moderators reviews reports using an internal moderation tool. Every report is reviewed by a person. When enough different verified users report the same account within a short time (fewer for child-safety reports), the account is automatically limited until a person reviews it. No suspension, removal or ban is decided by automated means alone. We do not scan Takes automatically. If we ever use automated tools to detect known illegal content, such as child sexual abuse material, we will say so in our Terms and Privacy Policy before we start, and a person will review any match.

5.3. Recommendations (Article 27). TakeTurn has no feed. The only recommendation feature is "People you may know". Its main parameters are, in order: (1) the friend network: people connected to you through your friends and their friends, closer people and more friends in common first; (2) only when the network gives few suggestions: people in the same country (or nearby countries; the country is estimated from the IP address and never shown) who joined recently ("New on TakeTurn") or, to fill "People you may know", are very active (opened TakeTurn in the last 3 days, those with the most catches first), then other recent joiners. Activity is used only to choose and order these suggestions and is never shown. There is no switch for these suggestions in the app; you can object at any time by writing to us in the app, through taketurn.co/support, or at support@taketurn.co, and we then stop suggesting you to others (so your country and activity are no longer used to suggest you) and stop using your country for your suggestions (so you no longer get the country and activity suggestions). See Terms, Section 5.9, and the Privacy Policy, Section 7.4.

5.4. No advertising. TakeTurn shows no ads and does not profile users for advertising.

5.5. Minors (Article 28). TakeTurn is only for people aged 18 or older. We remove accounts that belong to minors. See our Child Safety Standards.

6. Reporting illegal content (Article 16)

6.1. Anyone can report, with or without an account:

• in the app: press and hold a card in Chats, or open a profile and tap Report and block; or go to Settings > Report an issue;
• on the web: at taketurn.co/support; or
• by email: to the address in Section 14.

6.2. What to include. To help us act quickly, your notice should include:

1. why you believe the content is illegal;
2. where it is: the username of the account, and the date and time it was sent or shown;
3. your name and email address (not needed if the content may involve child sexual abuse or exploitation); and
4. a statement that you believe in good faith that the information in your notice is accurate and complete.

6.3. What happens next. We confirm receipt, review the notice in a timely, careful, non-arbitrary and objective way, and tell you what we decided and how you can challenge it. If we use automated means to process or decide on your notice, we tell you.

6.4. Takes disappear quickly. We keep a safety copy of received Takes for up to 24 hours. Please report as soon as you can.

6.5. Suspected criminal offenses (Article 18). If we become aware of information that gives rise to a suspicion that a criminal offense involving a threat to someone's life or safety has occurred, is occurring or is likely to occur, we promptly inform the law enforcement or judicial authorities of the Member State concerned (or Europol, if it is not clear which Member State).

7. Statement of reasons (Article 17)

7.1. When we remove or restrict content, or limit, suspend, remove or permanently ban an account, we send the affected user a clear statement of reasons in the TakeTurn chat in the app, unless the law stops us or it would put someone at risk. It explains:

• what we did, its scope and how long it lasts;
• the facts and circumstances, including whether we acted on a report;
• whether automated means were used to detect the issue or to decide;
• the legal ground (for illegal content) or the rule in our Terms or Community Guidelines (for rule-breaking content); and
• the ways to challenge the decision (Sections 8 to 10).

8. Internal complaints (Article 20)

8.1. If we limited, suspended, removed or permanently banned your account, or removed or restricted content you shared, you can complain (appeal) free of charge, once per decision, for 6 months after we tell you about the decision: with the Appeal button on your account's status screen in the app, from the decision in the TakeTurn chat, or without signing in at taketurn.co/support (topic "Appeal a decision"). If you disagree with our decision on a report you made, use the Appeal button under the result in the TakeTurn chat, Settings > Report an issue or the same website form. A warning on its own is information only and does not restrict your account or content, so it is not open to complaint. Content removed together with a warning is open to complaint. A Take cannot be restored, because Takes are temporary, but if we reverse a removal we correct our records and lift any related action.

8.2. A person reviews every complaint, if possible someone who did not make the original decision. We decide in a timely, non-discriminatory, diligent and non-arbitrary way. If your complaint shows we were wrong, we reverse our decision without undue delay. We tell you the result and remind you of the options below.

9. Out-of-court dispute settlement (Article 21)

9.1. If you live in the EU, you can choose a dispute settlement body certified under the DSA to help resolve a dispute about our decisions, including complaints we could not resolve. The European Commission publishes a list of certified bodies. We engage in good faith with any certified body you choose. Their decisions are not binding, and using one does not affect your right to go to court.

9.2. Norway, Iceland and Liechtenstein. The DSA is being taken into the EEA Agreement. Once it applies in your country, you have the same options as EU users, including a certified dispute settlement body. Until then, you can use our free internal complaint process (Section 8) and your national courts and authorities.

10. Courts and authorities

10.1. You can always take your case to court, or complain to the Digital Services Coordinator of your Member State.

11. Misuse

11.1. If an account often sends manifestly illegal content, we suspend it for a reasonable period after a warning, or remove or ban it for severe violations. If someone often submits manifestly unfounded reports or complaints, we may, after a warning, stop processing them for a reasonable period (Article 23).

12. Average monthly active recipients (Article 24(2))

12.1. TakeTurn has not yet launched in the EU, so we have no figure to report. Once we launch, we will publish on this page the average monthly number of active recipients of TakeTurn in the EU, calculated over the previous six months, and update it at least every six months.

12.2. Current figure: not yet available (pre-launch).

13. Transparency reports

13.1. Once TakeTurn is available in the EU, we will publish reports on our content moderation on this page, including the number of notices and orders we received, the actions we took, complaints and their outcomes, and the use of any automated tools, as the DSA requires for our size.

14. Contact us

For anything (privacy, safety, legal or general), write to support@taketurn.co, use Settings > Report an issue in the app, or the form at taketurn.co/support.

Post: the provider in Section 1.1.