Privacy Policy

Last updated: September 2026

The gurgura.com website and Gurgura mobile app (together, the “Service”), offered under the Gurgura brand, cover restaurant ordering, real estate/car/job listings, events and guide content. Digital structure, software and publication rights belong to Monclave. RED TEAM SOLUTIONS LTD. is the contractor Monclave engages solely for food fulfilment. This Privacy Policy (the “Policy”) explains in detail what data we collect, the legal bases and purposes on which we process it, with whom and why we share it, how long we keep it, how we protect it, and the rights you have. This Policy forms an integral part of the Terms of Use. By using the Service you acknowledge that you have read and understood the practices described here. If you do not agree with this Policy, please do not use the Service.

1. Data Controller, Service Relationship and Contact

Monclave is the principal that provides Platform software and digital publication and that operates accounts, listings, news and SMS. RED TEAM SOLUTIONS LTD. (MŞ27207) is an independent contractor engaged by Monclave solely for food fulfilment in Northern Cyprus (restaurant relations, order coordination, delivery support). It is not the publisher of listings, news or listing SMS.
Processing of personal data on accounts, listings and digital surfaces is carried out by Monclave. RED TEAM SOLUTIONS LTD. may process only the limited data needed to fulfil food orders (delivery address, phone, order contents).
In order or listing transactions, the restaurant, business or listing owner may act as an independent controller for the data they process. For food orders the addressee is the restaurant.
To delete your own record from the Platform, sign in with your phone and use “Delete account” in Account Settings; you can remove listings under “My listings” or stop notifications via the opt-out link in the message. If you cannot sign in, write to info@gurgura.com.
All user requests: info@gurgura.com.

2. Definitions

“Personal Data”: any information relating to an identified or identifiable natural person.
“Processing”: any operation performed on personal data, including collection, recording, storage, alteration, disclosure, transfer and deletion.
“User”: a natural person who registers for or uses the Service; “Business”/“Restaurant”: a party that publishes a menu or receives orders on the Platform; “Listing Owner”: a User who publishes a real estate/car/job listing.
“Infrastructure Provider”: third-party technology providers that process data on our behalf and on our instructions to enable the Service.

3. Scope of This Policy

This Policy applies to personal data collected through the gurgura.com website, the Gurgura mobile app, and all related digital surfaces operated by gurgura.
This Policy does not apply to third-party websites, apps or services not controlled by gurgura (e.g. the platforms of restaurants, listing owners, or third parties you interact with at delivery); those parties' own privacy policies apply.
We recommend reviewing this Policy and the Terms of Use carefully before using the Service.

4. Personal Data We Collect

Account and identity data: full name, email address, phone number, password (stored only in encrypted/hashed form), profile photo (if any) and language preference.
Order and delivery data: delivery address, address notes, order contents, order notes, order and payment status, delivery preferences and order history.
Location data: coarse or precise location (only with your device permission) used to show nearby businesses, compute distance/delivery eligibility and verify your delivery address.
User content: real estate, car and job listing text and images; restaurant/product reviews, ratings and comments; listing reports; support/contact messages and files you attach.
Age statement: a one-time 18+ confirmation required to order from alcohol-selling businesses (stored on the device; we do not collect date of birth) (see section 11).
Communication and notification data: push notification tokens, notification preferences, and order and promotional notifications sent by email/SMS.
Campaign and loyalty data: coupon usage, tier/reward points, invite/referral records and related usage statistics.
Transaction and interaction data: favorites, search and filter preferences, viewed content, approvals you give (e.g. the date you accepted the terms) and their time/session details.
Technical data: device model and identifiers, operating system and version, app version, browser information, language/time zone, IP address, session data and crash/error logs.
Security and fraud-prevention data: login attempts, suspicious-activity signals, account suspension/restriction records and limited logs needed to detect abuse.
Payment information: payments are collected in cash or by card on delivery; when online card payment is offered, it is processed on the bank's 3D Secure payment page. We do not store or process sensitive card details (card number, CVV, etc.) on our servers. We only keep information needed for the order record, such as payment method type, amount and transaction result.
We do not intend to collect special-category data; please do not enter such data into free-text fields (support requests, listings). If you do, we will use it only to handle your request.

5. How We Collect Data

Directly from you: through information you enter when creating an account, editing your profile/addresses, placing an order, or submitting a listing/review/rating or support message.
Automatically: through technical data, log records, cookies and similar technologies collected from your device, browser and app while using the Service.
From third parties: through basic profile information (name, email) you allow to be shared when signing in with Google or Apple, and the authentication result.
From partners: real estate, car and job listings and business catalogues may include content uploaded by users as well as information shared by partners or publicly available commercial details.
From other users: through limited information about an interaction when you contact a listing or report a listing/review.

6. Why We Process Your Data

To create, verify and manage your account and store your preferences; to provide authentication and session security.
To send your orders and listing requests to the relevant restaurant, business or listing owner and enable the fulfilment of the contract between you.
To operate the delivery process and send order-status and important account notifications.
To take an 18+ statement before ordering from alcohol-selling businesses.
To moderate user content (listings, reviews, ratings) for compliance with platform rules, review reported content and prevent abuse.
To provide features that improve your experience (coupons, loyalty/rewards, referral programs) and to prevent their misuse.
To measure service quality, detect and fix errors, keep the Platform secure and stable, and improve it.
To detect, prevent and investigate fraud, fake orders/listings/reviews, security breaches and other misuse.
To communicate with you, respond to support requests and resolve disputes.
To comply with our legal obligations, respond to lawful requests and to establish, exercise or defend our rights.
Your data is processed only in a manner that is relevant, limited and proportionate to the above purposes and is not used for incompatible purposes.

7. Legal Bases for Processing

Performance of a contract: processing is necessary to manage your account and provide ordering/listing services.
Legal obligation: compliance with law in cases such as age verification, financial/accounting records and responding to authorities.
Legitimate interests: interests such as Platform security, fraud prevention, service improvement and protecting our rights, balanced against your fundamental rights and freedoms.
Consent: where consent is legally required (e.g. certain marketing messages or optional location access), only within the scope of the explicit consent you provide; you may withdraw your consent at any time.
If a legal basis ceases to apply and the processing is not based on another basis, it is stopped and the data is deleted, destroyed or anonymized in line with section 13.

8. Cookies and Similar Technologies

On the website we use essential cookies for language preference, session management and security; these cannot be disabled as they are required for the Service to function.
We collect anonymous/aggregated first-party analytics data (Vercel Analytics) that does not individually track you, to understand site traffic.
We use Sentry (crash logs and limited session replay) and Microsoft Clarity (heatmaps / session replay) for debugging and product quality. These are third-party scripts, not advertising or cross-site targeting. We do not sell your data for those purposes.
The mobile app uses local device storage (session/language preference) and device identifiers for the same purposes instead of cookies.
You can manage cookies through your browser settings; however, blocking essential cookies may cause parts of the Service to stop working.

9. Sharing and Transferring Your Data

With restaurants/businesses: your order details (name, phone, delivery address, order contents and notes) are shared only with the restaurant or business preparing/delivering the order, for the purpose of fulfilling it.
With users who contact your listing: in real estate/car/job listings, the contact details you choose to share are visible to interested users to the extent you included them in the listing.
With infrastructure providers: hosting, database, authentication, file storage, error/crash tracking and push notification providers process data solely on our behalf to deliver the Service (see section 10).
With authorities: your data may be shared with competent authorities where required by law, a court order or a lawful request; it may also be disclosed where necessary to protect our rights, safety or third parties.
In a business transfer: if all or part of gurgura is involved in a merger, acquisition or similar transaction, your data may be transferred to the acquiring party to continue being processed in accordance with this Policy.
We do not sell or rent your data to third parties for marketing purposes.

10. Infrastructure Providers and Cross-Border Transfers

The digital structure and software are provided by Monclave. We use Supabase for our database, authentication and file storage; Vercel for hosting and on-site analytics; Sentry for crash/error tracking and session replay; Microsoft Clarity for heatmaps / session replay; Adenon for SMS delivery; and Apple (APNs) for push notifications.
These providers' servers may be located outside Cyprus (e.g. in EU or US regions); in that case your data is transferred across borders.
For cross-border transfers we enter into data-processing agreements with providers and apply reasonable technical/organizational safeguards to ensure an adequate level of protection.
Data is shared with these providers only to the extent necessary to deliver the Service; their contracts prohibit any use for their own purposes.

11. Children's Privacy

The Service is designed for users 18 and older; we do not knowingly collect personal data from individuals under 18.
A one-time 18+ statement is required before ordering from alcohol-selling businesses; users who state they are under 18 are blocked from that flow. We do not collect date of birth.
If we become aware that a user under 18 has provided us with data, we will delete it within a reasonable time and, where necessary, close the account.
If you believe a child has provided us with data, please contact us at info@gurgura.com.

12. Automated Decision-Making and Profiling

We do not carry out decision-making based solely on automated means that produces legal or similarly significant effects on you.
To prevent fraud and abuse, certain automated checks (e.g. suspicious-activity signals) may be applied; if such checks affect your account, you have the right to object and request human review.
Personalization we perform to improve your experience (e.g. showing nearby restaurants) does not constitute profiling with significant legal effects on you.

13. Retention, Account Deletion and Anonymization

We keep your personal data only for as long as necessary for the purposes for which it was collected and for the minimum retention periods required by applicable law.
You can delete your account and listing record from the Platform yourself: sign in with your phone (or the SMS login link) and use “Delete account” in Account Settings. You can also unpublish listings under “My listings” or stop further listing SMS via the opt-out link. These actions cannot be undone.
When your account is deleted, your profile, saved addresses, favorites, push notification tokens and support messages are permanently deleted; listings linked to you are unpublished and your number is removed from listing SMS.
Past order records remain on the platform for accounting/legal reasons and to protect the rights of businesses (restaurants, etc.); however, the link identifying you (your user ID) is removed so the record can no longer be associated with you (anonymization).
If you own a business (restaurant), deleting your account deactivates the business page and removes the ownership link.
Data subject to a statutory retention period (e.g. financial records) is kept for that period, as far as possible in a form not linked to you, and is deleted, destroyed or anonymized at the end of the period.

14. Data Security

Your data is stored in a database protected by row-level access controls (Row Level Security) and transmitted over encrypted connections (HTTPS/TLS).
Payments are currently cash or card on delivery. If online card payment is offered, it is processed on the bank's 3D Secure page; card details are not stored on Gurgura servers.
Your password is never stored in plain text; it is hashed using an industry-standard algorithm.
Access is limited to the systems and authorized personnel that need it to perform their function and is managed on a least-privilege basis.
We take reasonable technical and organizational measures (backups, updates, monitoring) on a regular basis; nonetheless, no system is 100% secure and absolute security cannot be guaranteed.
For your account security, use a strong password, do not share it with anyone, and notify us immediately if you suspect unauthorized access.

15. Data Breach Notification

If we detect that your personal data has been unlawfully accessed, we will assess the situation in accordance with applicable law and, to the extent we are required, notify the relevant individuals and competent authorities within a reasonable time.
We take the necessary technical and organizational measures to limit the impact of a breach and prevent recurrence.

16. Marketing Communications and Consent Management

We may send transactional messages such as order status and important account notices as part of providing the Service; these are not marketing messages.
We may send service messages about your account or listing (for example listing management or sign-in verification) by email or SMS. A phone number that appears on a public listing may receive SMS so the listing can be viewed or managed on the Platform. Every message includes a way to opt out; after opt-out we do not send listing SMS to that number. We do not sell your data to third parties.
Clicking the listing-management link in an SMS or email is your explicit consent to open a Gurgura account in your name, automatically transfer listings that match that number to your account, and let you view and manage them on the Platform. You may delete the account, listings and personal data at any time via “Delete account” in Account Settings, unpublish from My listings, or write to info@gurgura.com. If you do not want to click the link, use the opt-out link in the message.
We send campaign, coupon and promotional commercial messages only through channels you have permitted and, where required by law, based on your explicit consent.
You can opt out of such messages at any time, free of charge, via in-app notification preferences, the opt-out link in the SMS, or the instructions in the message.

17. Third-Party Links, Aggregated Content and Services

The Service uses third-party services such as Google/Apple sign-in, map/location services and push notifications; those services' own privacy policies and terms apply.
The Service may contain links to third-party websites not controlled by gurgura; gurgura is not responsible for the content or privacy practices of those sites.
Listings on the Platform may come from users, businesses, partners and publicly available commercial listing records. Gurgura does not present them as its own sale; the listing owner is responsible for accuracy.
If you want your content (a listing, image, contact details or similar) removed from the Platform, use the Content and Data Request form or write to info@gurgura.com. Our team will review the request.
We recommend reviewing the practices of these third parties separately.

18. Your Rights

You have the right to know whether your personal data is being processed and, if so, to request information about it and a copy.
You have the right to learn the purpose of processing and whether it is used in line with that purpose.
You have the right to request correction of your data if it is incomplete or inaccurate.
You have the right to request deletion, destruction or anonymization of data that is not subject to a statutory retention obligation (also via the in-app “Delete account” option).
You have the right to object to processing, to request restriction of processing in certain cases, and to withdraw consent for consent-based processing.
You may exercise your right to receive your data in a structured, commonly used format (portability) to the extent technically feasible.
To exercise these rights, use the Content and Data Request form or contact info@gurgura.com; we may request additional information to verify your identity and will respond within a reasonable time, free of charge (except for excessive/repetitive requests).

19. Right to Complain

If you believe a request has gone unanswered or has not been adequately addressed, please first contact us at info@gurgura.com; we will try to resolve the issue in good faith.
If no resolution is reached, you retain the right to lodge a complaint with the competent supervisory authority under applicable data protection law.
Privacy requests should be sent to info@gurgura.com.

20. Changes to This Policy

We may update this Policy from time to time. For material changes we will notify you via an in-app notice or by updating the “Last updated” date on this page.
Changes take effect when published; continued use of the Service after a change means you accept the updated Policy.
We can provide a reasonable archive of previous versions upon request.

21. Contact

For any privacy-related question, request or complaint: info@gurgura.com
Software: Monclave. RED TEAM SOLUTIONS LTD. is the food-fulfilment contractor engaged by Monclave.