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Secret Community Privacy Notice
Explains what personal data Picom processes for Secret Communities, why it is processed, and that data is not reused for unrelated advertising without a separate lawful basis.
This text is a draft for counsel review. Screens alone do not make Picom “KVKK compliant” or “GDPR certified”.
Controller information
This notice cannot be published as active until required controller fields are configured. Missing: legalName, registeredAddress, tradeRegistry
- Legal name
- —
- Registered address
- —
- Trade registry
- —
- General contact
- info@picom.gg
- KVKK contact
- info@picom.gg
- GDPR contact
- info@picom.gg
- DPO
- —
- EU representative
- —
- TR representative
- —
Summary
- Picom processes limited personal data to provide and protect Secret Communities.
- Data may include account identifiers, verification status, membership and invitation records, moderation and security logs, and internal risk indicators.
- Purposes include operating communities, verifying users, preventing abuse, enforcing rules, supporting users, and meeting legal obligations.
- Personal data is not reused for unrelated advertising, behavioural targeting, or sale without a separate lawful basis and required notice or consent.
- This notice is information only — it is not a request for consent. Optional consents are collected separately where required.
- You may exercise applicable data-subject rights by contacting the Picom data controller (see Controller information).
Full notice
Who is responsible
The Picom data controller (see Controller information) determines the purposes and means of processing personal data for Secret Community features described in this notice.
What data may be processed
Depending on how you use Secret Communities, processed data may include the categories listed below. Only data that is reasonably necessary for the stated purposes may be collected.
- Picom account identifier
- Username and profile information
- Verified telephone number status
- Telephone verification records
- Voice-call verification result
- Community membership records
- Invitation sender and recipient identifiers
- Invitation creation, expiration and usage records
- Rule and security-notice acceptance records
- Community roles and permissions
- Reports and moderation records
- Security and abuse-prevention logs
- Session, device and network security indicators
- Community Trust Score inputs and history
- Support and legal-request records
Why we process this data
Picom processes this data for the following purposes:
- Creating and operating Secret Communities
- Verifying community creators and invited members
- Restricting invitations to intended recipients
- Preventing spam, fraud, impersonation and unauthorised access
- Enforcing community rules and platform policies
- Investigating reports and security incidents
- Protecting users, communities and the Picom service
- Fulfilling legal obligations
- Establishing, exercising or defending legal claims
- Maintaining immutable security and moderation audit records
- Providing user support
- Calculating internal risk indicators and Community Trust Scores
Advertising and secondary use
Personal data processed for Secret Communities must not be reused for unrelated advertising, behavioural targeting or sale to third parties without a separate lawful basis and the required notice or consent.
Notice is not consent
This Privacy Notice is presented for transparency. Presentation and acknowledgement that you have seen this notice are not the same as consent. Where processing requires consent, Picom requests that consent through a separate, specific and optional control.
Your rights
Depending on applicable law (including KVKK and GDPR where they apply), you may have rights of access, correction, deletion, restriction, objection, portability, consent withdrawal, and related remedies. Contact details appear in Controller information. You may also have the right to lodge a complaint with a competent supervisory authority.