KVKK Notice & Explicit Consent
Draft text — legal review required before launch.
1. Data Controller
Pursuant to Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Principles and Procedures for the Fulfilment of the Obligation to Inform, your personal data is processed by ProfileLab (the "Company") as data controller within the scope described below.
2. Categories of Personal Data
Contact: email address. Visual records: uploaded profile photos. Customer transaction: bio text, dating goal, payment status, order reference, consent records. Transaction security: IP address, browser information and system logs. The Company does not perform biometric identification on photos; photos are therefore not processed as biometric data under Article 6 KVKK.
3. Purposes
Providing the Service and analyzing profile presentation with artificial intelligence; generating the free preview; collecting the one-time payment; generating and emailing the full report and story image; sending a reminder with a discount code where a purchase is not completed; operating information security processes; use as evidence in legal disputes; and fulfilling legal obligations.
4. Legal Grounds
Explicit consent under Art. 5/1 (AI analysis, international transfer, reminder message); necessity for the establishment or performance of a contract under Art. 5/2-c (delivery of the report); compliance with a legal obligation under Art. 5/2-ç (accounting and tax records); establishment, exercise or protection of a right under Art. 5/2-e; and the Company's legitimate interest under Art. 5/2-f (Service security), provided your fundamental rights are not harmed.
5. Method of Collection
Personal data is collected electronically, by wholly or partly automated means, through the website forms, upload area and consent checkboxes.
6. Recipients and International Transfer
Personal data may be transferred, limited to the purposes above, to cloud hosting and storage providers, the AI analysis provider, the payment provider and the email delivery provider, and to competent public authorities upon request. As these providers' servers may be located abroad, data is transferred abroad under Article 9 KVKK on the basis of your explicit consent and/or appropriate safeguards provided by law.
7. Retention and Destruction
Photos: permanently deleted as soon as the report is emailed, or within 15 minutes of upload if no purchase is made. Bio and preview results: deleted together with photos. Full report: not stored, only emailed. Email and consent records: for the applicable limitation periods after the relationship ends. Transaction and invoice records: 10 years under the Tax Procedure Law and Turkish Commercial Code. Expired data is destroyed by deletion, destruction or anonymization.
8. Your Rights (Art. 11 KVKK)
To learn whether your data is processed; request information; learn the purpose and whether data is used accordingly; know third parties to whom data is transferred domestically or abroad; request rectification; request erasure or destruction under Art. 7; request notification of such operations to third parties; object to an adverse outcome arising exclusively from automated analysis; and claim compensation for damages arising from unlawful processing.
9. How to Apply
You may submit requests in writing, with information identifying you, to the email address stated on our website in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. Requests are concluded free of charge within thirty (30) days at the latest; where the process entails an additional cost, the fee set by the Board may be charged. You retain the right to complain to the Personal Data Protection Board.
10. Explicit Consent Statement
I declare that I have read and understood this Notice and that I freely give specific and informed explicit consent to: (i) my profile photos and bio being sent to an AI service provider for evaluation; (ii) my personal data being transferred to the foreign countries where the above providers' servers are located; and (iii) receiving a single message containing a discount code if I do not make a purchase. I understand that I may withdraw my consent at any time, that withdrawal has no retroactive effect, and that withdrawing consent to AI analysis means the Service cannot be provided.