Personal Data Notice (KVKK)

Data controller: Legal operator details are being updated (natural person;Sinetolya platform operator).

Address: Details are being updated · Phone: Details are being updated · Email: Details are being updated

• Identity: full name,
• Contact: email, phone, address (if provided),
• Customer transactions: membership type, subscription status and term, Paddle customer and subscription identifiers, requests, quotes,
• Visual records: photos and videos you upload,
• Transaction security: IP address, session and error logs,
• Professional information: industry listing, company details, signature and logo.

We do not process payment card details; payments are collected by Paddle. When the payment screen opens, only your email address and the user ID used to match your account are sent to Paddle.

• Managing membership and account operations,
• Providing Pro subscription benefits,
• Providing location, listing, document, budget and quote services,
• Sending notifications and communications,
• Ensuring information security and preventing misuse,
• Fulfilling legal obligations.

• Membership, Pro subscriptions, location/listing/document/budget/quote services and notifications: entering into and performing a contract (KVKK Art.5/2-c),
• Invoicing, tax and official request procedures: fulfilling a legal obligation (Art.5/2-ç),
• Protecting rights in disputes: establishing, exercising or protecting a right (Art.5/2-e),
• Information security, error logs and prevention of misuse: legitimate interests, provided your fundamental rights and freedoms are not harmed (Art.5/2-f).

Where none of these grounds apply, your personal data is processed only on the basis of your explicit consent (Art.5/1).

Data is collected electronically through forms on the website and app, account operations and subscription notifications from the payment provider.

Your personal data may be transferred to the following parties solely for the purposes listed above:

• Hosting, database, file storage and authentication service providers,
• Email and push notification service providers for notification emails and browser/phone notifications,
• The relevant sign-in provider if you choose to sign in with Google or Apple,
• The AI service provider for suggested petition/contract wording, assistant responses and suitability checks on uploaded photos (only the text or photo you provide when using the relevant feature),
• Paddle for subscription, payment, billing and refund operations,
• Legal/accounting advisers and competent public bodies and authorities upon request.

As some of these service providers are based abroad, personal data may be transferred abroad. Under KVKK Art.9, international transfers are made subject to; an adequacy decision issued by the Board for the destination country or sector, or, failing that, an appropriate safeguard such as a standard contract published by the Board, binding corporate rules or a written undertaking approved by the Board, or, where none of these are available, one of the exceptions for occasional transfers listed in Art.9/6. If a standard contract is used, the Authority is notified of the contract within five business days of signing.

Data is retained for as long as required for the processing purpose and for the retention periods specified by applicable law; it is then deleted, destroyed or anonymized.

• Learning whether your personal data is processed and requesting information,
• Learning the purpose of processing and whether your data is used in line with that purpose,
• Knowing the third parties to whom your data is transferred domestically or abroad,
• Requesting correction of incomplete or incorrectly processed data,
• Requesting deletion or destruction when the conditions are met and requesting that recipients of your data be notified of these actions,
• Objecting to an adverse outcome resulting from analysis by automated systems,
• Requesting compensation for damage caused by unlawful processing.

In accordance with the Communiqué on the Procedures and Principles for Applications to the Data Controller, you may submit your requests Details are being updated or in writing to Details are being updated . Requests are resolved free of charge within 30 days at the latest, depending on their nature. If processing incurs additional costs, the fee schedule set by the Board may apply. If a request is rejected, the response is inadequate or no response is provided on time, you may lodge a complaint with the Personal Data Protection Board under KVKK Article 14.