Maandishi ya Ufafanuzi wa KVKK
sasisho la mwisho: [GG.AA.YYYY] · Uhalali: [GG.AA.YYYY]
Prepared by [Company Legal Name] in its capacity as data controller pursuant to Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK").
1. Personal Data Processed
- Identity/Contact: name-surname/title, email, phone, address.
- Invoice/Finance: tax number/TCKN-VKN, invoice details, payment transaction records (via PayTR; card data is not stored by the Service Provider).
- Account/Usage: gateway keys (hashed), model usage/token counters, audit records, IP and log data.
- Content: prompt/response data submitted to the Service (processed according to the selected model and local embedding configuration).
2. Purposes of Processing
- Provision of the Service, authentication, invoicing and collection.
- Security, prevention of abuse, quota/limit enforcement, auditing.
- Fulfilment of legal obligations (tax, e-invoice, commercial records).
- Request/complaint management and service improvement.
3. Legal Grounds (KVKK Art. 5/6)
Establishment/performance of a contract (Art. 5/2-c), legal obligation (Art. 5/2-ç), legitimate interest (Art. 5/2-f), and explicit consent where required. As a principle, no special categories of data are processed.
4. Transfers
Data may be shared on a purpose-limited basis with the payment institution (PayTR), the e-invoice integrator, hosting/infrastructure providers, authorized public authorities and the selected upstream model providers. Where cross-border transfer occurs, the conditions of KVKK Art. 9 are complied with (e.g. if a foreign LLM provider is selected). With local embedding (bge-m3), content can be processed without leaving the host.
5. Retention Periods
Data is retained for the periods prescribed by the relevant legislation (e.g. [10 years] for commercial/tax records) and for as long as the processing purpose requires; at the end of the period it is deleted/anonymized.
6. Rights of the Data Subject (KVKK Art. 11)
You have the right to learn whether your data is processed, to request information, to learn whether it is used in line with its purpose, to request rectification/erasure/destruction, to learn the third parties to whom it has been transferred, to object to automated analysis, and to claim compensation for damages. Applications: [iletisim@alanadi.com] or [KEP/adres].