Terms of Use

1. Parties and service provider details

These Terms of Use (the "Agreement") are made between the service provider whose details appear below and the natural person who downloads, registers for and uses the 28 Social mobile application (the "App" or "28") (the "User"), in order to set out the terms on which the App may be used.

Under Article 3 of Law No. 6563 on the Regulation of Electronic Commerce and the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce, the service provider's details are as follows:

By downloading the App and registering, you declare that you have read, understood and accepted this Agreement. Its inseparable annexes are the Personal Data Processing Notice, the Explicit Consent text, the Privacy Policy, the Cookie and SDK Policy, the Commercial Electronic Message Consent and the Community Guidelines.

2. Special provisions for the closed test (TestFlight)

The App is currently in a closed test (beta) run through Apple TestFlight. At this stage the following apply:

• Participation in the test is entirely voluntary and by invitation. The User may leave the test at any time; there is no service or right they lose by doing so.
• Because the App is under development it may contain errors, interruptions and unexpected behaviour; it is provided "as is".
• During the test the database may be reset and features may be removed or changed. Some or all of the User's data may be deleted as a result, and the User accepts this in advance. This provision does not affect the User's rights under the data protection legislation or the data controller's obligations under it.
• During the test the App has no paid features and no in-app purchases. The App is provided free of charge. If paid features are added in future, the price, payment terms and information on the right of withdrawal will be presented to the User separately in advance and this Agreement will be updated.
• Feedback received from the User during the test may be used to improve the App. The User accepts that they will make no claim for any fee or right in respect of the feedback they send.

3. Age and eligibility

28 may only be used by people who have completed the age of 18. The User is responsible for the accuracy of the date of birth declared at sign-up. The service provider reserves the right to suspend or close the account of a User found to have misdeclared their age, without any notice; in that case the personal data concerned is erased without delay.

The User may report from inside the App a profile they believe belongs to someone under 18. Such reports are reviewed as a priority.

4. Creating an account and security

• The information given at sign-up must be accurate, current and complete.
• The User is responsible for the confidentiality of the account password and for every action taken through the account.
• An account may belong to only one natural person; transferring, renting or sharing an account is prohibited.
• If the User suspects unauthorised access to their account, they must change their password immediately and inform the service provider.

5. How the App works

The App offers the core functions summarised below:

• Based on the interests selected at sign-up — and where the relevant explicit consent has been given — the User is assigned a "persona", which is shown on their profile.
• At set time windows, the matching features in the "For You", "Dice", "Planned" and "Presents" sections become active; outside those windows the matching function cannot be used.
• When a match occurs, a chat room is opened automatically between the matched users.
• The User may separately attend existing or previously planned events in the relevant sections.

6. Changes to the App and updates to this Agreement

The service provider reserves the right to change the App's features, matching hours, algorithm and interface for the purpose of improving it.

Where a material change is made to this Agreement to the User's detriment (for example introducing charges, changing the liability regime or widening the scope of data processing), the User is informed by in-app notification and/or email at least thirty days before the change takes effect. Within that period the User may terminate the Agreement by stating that they do not accept the change, and delete their account. Changes are not applied retrospectively.

7. User obligations and prohibited conduct

The User agrees to refrain from the following while using the App:

• Using a false identity or false profile information; impersonating someone else.
• Harassing, threatening, insulting or otherwise disturbing another user.
• Sharing hate speech or discriminatory, obscene, violent or unlawful content.
• Carrying out unauthorised commercial promotion or advertising, or sending spam.
• Sharing another user's personal data (photograph, contact details, location) with third parties without their consent.
• Attempting to circumvent or abuse the App's security infrastructure (using bots, creating accounts automatically, scraping, reverse engineering).
• Bringing third parties into a meeting, other than the person or people they have matched with or agreed to meet, without the other side's prior knowledge and consent.
• Subjecting a user to bullying, harassment or humiliation online or offline; sending repeated unwanted messages; sharing, or threatening to share, images, screenshots or information about a user outside the App without their consent.
• Using the App for prostitution, human trafficking, supplying narcotics or committing any other offence.

Where these obligations are breached, the service provider may, depending on the gravity of the breach, issue a warning, remove the content, temporarily restrict the account or close it permanently.

8. Content, liability and the notice-and-takedown mechanism

The User who shares content through the App is responsible for its lawfulness. The service provider is not obliged to subject User content to general and continuous review before it is published.

Under Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications, where the service provider is notified of unlawful content it is obliged, so far as technically possible, to remove content established to be unlawful. In that context:

• Reports about a piece of content or a profile may be made through the in-app "Report" flow or by email to support@28istanbul.com.
• Anyone claiming that their personal rights have been infringed may request removal of the content under Article 9 of Law No. 5651; their right to apply to the criminal judgeship of peace is also reserved.
• Anyone who believes their personal data has been published unlawfully may apply to the data controller under Articles 11 and 13 of the Personal Data Protection Law.

9. Tackling bullying, harassment and inappropriate conduct

The service provider adopts a zero-tolerance principle towards every form of cyberbullying, harassment, threat and insult occurring through the App. Such conduct falls within the prohibited conduct in clause 7 and constitutes a serious breach of this Agreement.

• Users can report any profile and any chat they encounter in a single step from inside the App, using the "Block" and "Report" options; the report is taken up for review together with the chat or profile record concerned.
• The service provider reviews bullying and harassment reports it receives within 72 hours at the latest and, where it considers it necessary, temporarily restricts the account concerned.
• Where reports about a user come from more than one independent user, all features of that account may be temporarily suspended until the review is complete.
• For verified threats, harassment, hate speech or similar serious breaches, the service provider may close the account permanently, without prior warning and in a way that also prevents a new account being opened.
• Where the reported conduct constitutes an offence under the Turkish Criminal Code No. 5237 (threat, insult, sexual harassment, blackmail and similar), the victim reserves the right to apply to the official authorities. The service provider shares the relevant records it holds where a lawful request is made by the competent authorities.
• Chat records relating to a bullying or harassment report are kept for the period stated in Section 9 of the Personal Data Processing Notice, for the purposes of the review and any legal proceedings, even if the users concerned have deleted their accounts.

10. Responsibility for meeting in person

28 is a platform that makes it easier for users to match through the App and then meet physically. Meetings and events that take place between users are outside the service provider's control and supervision.

• Users are obliged to take reasonable safety precautions before meeting another user: meeting in a public place, telling someone close to them about the meeting, being cautious about sharing personal information, and so on.
• The service provider may offer in-app safety advice; offering that advice does not remove the user's own duty of care.
• Where a user brings a third party into a meeting, other than the person or people they have matched with or agreed to meet, without the other side's knowledge and consent, any damage caused by that third party is the responsibility, first and foremost, of the third party themselves and of the user who brought them into the meeting. The service provider gives no undertaking whatsoever in respect of people with whom no match has been established through the App.

11. Limitation of liability

The service provider does not undertake that the App will run uninterrupted and error-free. The App is provided "as is", particularly during the closed test stage.

The service provider's liability is limited to the maximum extent permitted by law. That said:

• Under Article 115 of the Turkish Code of Obligations, any agreement that excludes in advance and in general the service provider's liability arising from its intent or gross negligence is absolutely void. This clause does not apply where the service provider has acted with intent or gross negligence.
• For Users who qualify as consumers, exclusions of liability that are incompatible with the mandatory provisions of the Consumer Protection Law are not valid.
• This clause does not in any way limit liabilities arising under the Personal Data Protection Law or the rights of data subjects under Article 11 of that Law.

12. Intellectual property

The App's design, logo, the "28" trade mark, interface elements, software and database structure are the intellectual property of the service provider or its licensors. The User may use the App only for personal and non-commercial purposes; they may not copy, reproduce, reverse engineer or create derivative works from it.

The User retains their rights in the content they upload to the App (photographs, text, comments). The User grants the service provider a non-exclusive, royalty-free right to host, store, reproduce and display that content to other users within the App, limited to the purpose of operating the App. That right ends when the content is removed from the App or the account is deleted.

The service provider does not use User content in advertising or marketing materials without the User's separate and express approval.

13. Protection of personal data

The principles governing the processing of the User's personal data are set out in the Personal Data Processing Notice, the Explicit Consent text, the Privacy Policy and the Cookie and SDK Policy, which are inseparable annexes to this Agreement. Acceptance of those documents is obtained separately from and independently of acceptance of this Agreement; for processing that requires explicit consent, the User gives or withholds each consent separately.

The User agrees not to share, record or process other users' personal data outside the App. If that obligation is breached, the User may themselves qualify as a data controller under the Personal Data Protection Law and the resulting legal responsibility is theirs.

14. Ending the account

• The User may delete their account at any time and without giving a reason, from "Settings → Delete My Account". When the account is deleted, personal data is erased or anonymised, subject to the exceptions and periods stated in Section 9 of the Personal Data Processing Notice.
• The service provider may suspend or terminate an account in the event of a breach of this Agreement, unlawful use or a concrete risk to user safety. Except for serious breaches, the User is notified before termination and given the opportunity to object.
• A User whose account has been terminated may object to the decision by writing to support@28istanbul.com. The objection is assessed within thirty days at the latest and the outcome notified to the User.

15. Force majeure

Circumstances beyond the parties' control — natural disaster, epidemic, war, acts of terrorism, mobilisation, cyberattack, interruptions originating from infrastructure and internet service providers, the cloud service provider suspending its service, and decisions of administrative authorities — are deemed force majeure. For the duration of the force majeure event the parties' obligations are suspended and the provisions on default do not apply.

16. Governing law, dispute resolution and jurisdiction

This Agreement and any dispute arising from it are governed by the law of the Republic of Türkiye.

• For Users who qualify as consumers: under Consumer Protection Law No. 6502, the Provincial or District Consumer Arbitration Committees and the Consumer Courts at the User's place of residence or at the place where the transaction was carried out have jurisdiction, depending on the monetary value of the dispute. No provision limiting jurisdiction to the User's detriment is valid.
• For Users who do not qualify as consumers: the Courts and Enforcement Offices of have jurisdiction.
• For requests concerning the protection of personal data, it is possible to apply first to the data controller under Article 13 of the Personal Data Protection Law and, if no result is obtained, to complain to the Personal Data Protection Board under Article 14.

17. Miscellaneous

• Severability: if any provision of the Agreement is invalid or unenforceable, that does not affect the validity of the remaining provisions.
• Assignment: the User may not assign their rights and obligations under the Agreement to third parties.
• Notices: notices to the User are made to their registered email address or by in-app notification. The User is obliged to keep their contact details up to date.
• Evidential agreement: in disputes between the parties, the service provider's electronic records constitute evidence within the meaning of Article 193 of the Code of Civil Procedure. This provision does not remove the User's right to prove the contrary.
• Entry into force: this Agreement enters into force for an indefinite term when the User gives their approval at sign-up and ends when the account is deleted. Last updated: 10 September 2026 · Effective date: