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Your data rights (KVKK m.11 / GDPR Art. 15–17)

When your phone is verified on this device, you can download a JSON export of your GroundBox data or permanently erase your encrypted phone number and unlink your identity.

GroundBox — GDPR Privacy Notice & Data Protection Policy (KMZ-1, KMZ-24)

Version: gdpr-v1 (Legal review completed and approved — 10 November 2026; pilot signup consent version venue-pilot-signup-v1) Last Updated: 3 November 2026

Implementation Note: This unified GDPR Privacy Notice covers all personal data processing across GroundBox (https://groundbox.app), including Guest Check-in & Live Queue, Venue Pilot Applications, and Venue Owner / Staff & Spotify Integration, in compliance with Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR) as well as Turkish Personal Data Protection Law No. 6698 (KVKK).


1. Data Controller & Contact Information

For platform authentication, device verification, security rate-limiting, and software infrastructure operations, the Data Controller is:

  • Controller: Workouse Yazılım Ltd. Şti. (Turkish tax ID / VKN: 8141022044), operator of GroundBox
  • Company Website: https://workouse.com
  • Privacy Contact: privacy@workouse.com / kvkk@workouse.com
  • Service Website: https://groundbox.app

(Note: Individual hospitality venues using GroundBox are independently responsible for in-venue cash/POS voucher sales, local receipt issuance, and on-premise queue moderation decisions.)


GroundBox follows strict data minimization and privacy by design:

Data Subject Category Personal Data Processed Purpose of Processing GDPR Legal Basis (Art. 6)
1. Venue Guests Identity & Verification: Mobile phone number (+90), stored exclusively as a keyed lookup digest (HMAC-SHA256) and authenticated ciphertext (AES-256-GCM) — never stored in plaintext; 6-digit SMS OTP challenge metadata; optional display nickname (defaults to Guest #<random>).
Device & Security Metadata: 30-day signed HttpOnly verification cookie; truncated IP subnet (/24 IPv4 or /48 IPv6) and keyed rate-limit hashes; Cloudflare Turnstile bot-verification token.
Location Proximity Check: Ephemeral browser GPS check verifying the guest is within $\le 100\text{ metres}$ of the venue at check-in and once every hour while checked in (raw GPS coordinates are never stored in the database).
Service & Ledger Activity: Redeemed 5-character venue voucher codes, song requests/boosts, and temporary night moderation status (banned_until).
- Verify guest identity via SMS OTP and remember verified devices for 30 days without repeated SMS
- Confirm physical presence at the venue during active check-in sessions
- Manage the live song queue, venue-scoped credits, and refunds (Skip & Refund)
- Prevent SMS pumping, bot abuse, and voucher brute-forcing
- Art. 6(1)(b) (Contract / Service Delivery): Phone verification, venue-scoped credit accounting, and song queue management
- Art. 6(1)(f) (Legitimate Interests): Fraud prevention, SMS/voucher rate-limiting, Turnstile verification, and abuse moderation
- Art. 6(1)(a) (Explicit Consent): Hourly browser location proximity verification while checked in (withdrawable at any time by checking out)
2. Venue Pilot Applicants (venue-pilot-signup-v1) Application & Contact Data: Venue name, contact person’s full name, city, mobile phone number (AES-256-GCM encrypted at rest), preferred language (tr/en), Turnstile verification, and consent version/timestamp. - Evaluate pilot venue applications
- Contact the venue representative for onboarding and setup
- Art. 6(1)(b) (Pre-contractual Steps): Evaluating and responding to a venue’s request to join the pilot
- Art. 6(1)(a) (Consent): Explicit consent recorded with version and timestamp at submission
3. Venue Owners & Staff (owner, bartender) Account & Role Data: Full/display name, mobile phone number (AES-256-GCM encrypted at rest), staff role (owner, bartender), optional venue tax ID (VKN/TCKN), venue address and coordinates.
Operational & Integration Data: Shift logs, voucher issuance/void records, queue moderation actions (audit_log), and venue-connected Spotify OAuth 2.0 PKCE refresh token (AES-256-GCM encrypted at rest).
- Authenticate staff and enforce role-based access (owner vs. bartender)
- Sync the venue’s live queue with its connected Spotify account
- Maintain an immutable audit trail for shift and voucher accountability
- Art. 6(1)(b) (Contract): Performing the B2B SaaS agreement with the venue
- Art. 6(1)(c) & 6(1)(f) (Legal Obligation & Legitimate Interests): Financial/voucher auditability and prevention of staff self-redemption or skimming

3. Technical & Cryptographic Safeguards (Privacy by Design)

  1. Application-Layer Encryption at Rest: Phone numbers and Spotify OAuth refresh tokens are encrypted before database storage using AES-256-GCM with unique per-record authenticated context (guest:<id>:phone, staff:<id>:phone, venue_signup:<id>:phone, venue:<id>:spotify) and versioned keys supporting rotation. Equality lookups use a separate secret pepper with HMAC-SHA256.
  2. Zero Raw Location History: Browser geolocation coordinates are evaluated in memory solely to confirm that the guest is within 100 metres of the venue’s coordinates. Raw guest latitude/longitude pairs are discarded immediately after verification and are never written to D1 or logs.
  3. Zero Marketing SMS: Phone numbers are used strictly for one-time verification codes (OTP) or requested pilot onboarding contact—never for promotional messages, third-party advertising, or profiling.
  4. Strictly Necessary Cookies Only: GroundBox uses only first-party, signed, HttpOnly, SameSite=Lax, Secure session cookies (a 30-day verified-guest cookie, an active check-in cookie, and a staff session cookie). No third-party advertising or cross-site tracking cookies are used.

4. Recipients, Sub-Processors & International Data Transfers

GroundBox does not sell or rent personal data. Data is shared only with essential infrastructure sub-processors under Data Processing Agreements (DPAs) and Standard Contractual Clauses (SCCs) where applicable under GDPR Chapter V:

Sub-Processor Role & Scope Data Shared Safeguards
Cloudflare, Inc. Edge compute (Workers), encrypted database (D1), live queue state (Durable Objects), bot protection (Turnstile), transactional email (Email Sending) Encrypted database records, request headers/IP for bot & rate-limit protection, PII-minimized pilot signup notification emails Application-layer AES-256-GCM encryption for PII; EU/Global DPA & SCCs
Twilio Inc. Transactional SMS OTP delivery Recipient mobile phone number (+90...) and 6-digit verification code during OTP send HTTPS TLS in transit; 5-minute OTP validity; Twilio DPA & Binding Corporate Rules / SCCs
Spotify AB Venue playback queue synchronization (POST /v1/me/player/queue) Venue owner’s OAuth token and track URIs only (no guest phone numbers or identities are ever sent to Spotify) OAuth 2.0 with PKCE; encrypted refresh token at rest
Functional Software, Inc. (Sentry) Operational error tracking and alerting Sanitized application error traces (phone numbers, OTP codes, and credentials are scrubbed before transmission) PII scrubbing at source; DPA & SCCs

5. Data Retention & Erasure Schedule (KMZ-24)

Data Category Retention Period Disposal / Anonymization Action
SMS OTP Challenges & Rate-Limit Windows 30 days Automatically purged via scheduled Worker Cron Trigger (DELETE).
Turnstile Token Claims & Signup Attempt Buckets 15 minutes – 30 days Automatically purged via scheduled Worker Cron Trigger.
Remembered Guest Device Cookie 30 days Expires automatically in the guest’s browser (or immediately upon revocation).
Active Check-in & Hourly Proximity State Duration of visit (1-hour TTL per check, revoked immediately on checkout or QR rotation) Raw GPS is never stored; check-in metadata is cleaned up after 30 days.
Encrypted Guest Phone (guests.phone_encrypted) 1 year from last venue activity, or immediately upon an erasure request phone_encrypted is overwritten (erased) and phone_hash is rotated/anonymized while preserving non-identifiable ledger totals.
Venue Pilot Applications (venue_signups) Up to 1 year from submission (or until onboarded/erased) Encrypted phone ciphertext is erased upon request or expiry.
Credit Ledger (credit_ledger) & Audit Log (audit_log) 5 – 10 years (statutory commercial & tax retention) Retained in append-only form with guest phone PII severed/anonymized.

6. Your Rights Under the GDPR (Articles 15–22)

Subject to applicable law, you have the right to:

  • Access (Art. 15) & Portability (Art. 20): Request a copy of the personal data we hold about you in a structured, machine-readable format.
  • Rectification (Art. 16): Update or correct inaccurate information (such as your display nickname or contact details).
  • Erasure / “Right to be Forgotten” (Art. 17): Request immediate deletion of your encrypted phone number and unlink your identity from historical song requests and credit ledger entries.
  • Restriction (Art. 18) & Objection (Art. 21): Object to processing based on legitimate interests or request restricted processing.
  • Withdraw Consent (Art. 7(3)): Withdraw location verification consent at any time simply by tapping “Check out” (Çıkış yap) on the venue page or revoking browser location permissions.
  • Supervisory Authority Complaint (Art. 77): Lodge a complaint with your local EU Data Protection Authority or the Turkish Personal Data Protection Authority (KVKK Kurumu).

To exercise any of these rights, contact privacy@workouse.com or use the in-app data export and deletion controls on /en/privacy (or inside the venue check-in privacy dialog). We respond to all verified requests within 30 days.