Privacy Notice under Turkish Personal Data Protection Law (KVKK)
This notice is prepared by Cvisioner in its capacity as data controller, pursuant to Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK").
1. Data Controller
Cvisioner Kızılırmak Mah. Dumlupınar Bulvarı Next Level No:3 A Kat:4 D.No:11 PK:06520 Çankaya, Ankara Email: support@cvisioner.com
2. Personal Data We Process
| Category | Scope |
|---|---|
| Identity | First name, last name, date of birth |
| Contact | Email address, phone number, postal address |
| Professional Profile | Work experience, education, skills, certifications included in your CV |
| Visual Records | Photo included in your CV |
| Transaction Security | IP address, login/logout logs, browser information, cookie records |
| Customer Transaction | Subscription details, payment reference number, invoice information |
3. Purposes of Processing
- Creating and managing your membership account
- Providing AI-powered CV analysis and career management services
- Processing payments, invoicing, and accounting
- Planning, auditing, and executing information security processes
- Managing requests and complaints and providing after-sales support
- Fulfilling legal obligations arising from applicable legislation
4. Transfer of Personal Data
Your personal data may be transferred to the following parties with appropriate safeguards under KVKK Articles 8 and 9:
- Infrastructure and AI API providers (Google Gemini API, cloud storage): For service delivery, under Google's Data Processing Addendum (DPA) applicable to paid API usage; Google does not use this data to train its models
- Payment processor (PayTR): For verification and completion of payment transactions
- Email and communication service providers: For notifications and support correspondence
- Competent public authorities and judicial bodies: As required by law
5. Method of Collection and Legal Basis
Your personal data is collected through our website and application channels, fully or partially by automated means.
| Processing Activity | Legal Basis |
|---|---|
| Account creation and service delivery | KVKK Art. 5/2-(c) — Establishment or performance of a contract |
| Payment and invoicing records | KVKK Art. 5/2-(ç) — Compliance with a legal obligation |
| Security logs and fraud prevention | KVKK Art. 5/2-(f) — Legitimate interest |
| AI processing of CV for analysis | KVKK Art. 5/1 — Explicit consent |
| Marketing communications | KVKK Art. 5/1 — Explicit consent |
6. Retention Periods
| Data Category | Retention Period |
|---|---|
| Account and profile data | 3 years after account closure |
| Payment and invoice records | 10 years (Turkish Commercial Code Art. 82) |
| Transaction security logs | 2 years (Law No. 5651) |
| Marketing preferences | Until consent is withdrawn |
Upon expiry of the retention period or cessation of the processing purpose, your personal data will be deleted, destroyed, or anonymized.
7. Your Rights as a Data Subject
Under KVKK Article 11, you have the right to:
- Learn whether your personal data is being processed
- Request information if your personal data has been processed
- Learn the purpose of processing and whether data is used in accordance with that purpose
- Know the third parties to whom your personal data has been transferred, domestically or abroad
- Request correction of incomplete or inaccurate personal data
- Request deletion or destruction of personal data under the conditions set out in KVKK
- Request that third parties to whom data has been transferred be notified of corrections or deletions
- Object to a result that arises to your detriment through automated analysis of your data
- Claim compensation for damages caused by unlawful processing of your personal data
8. How to Submit a Request
You may submit your requests to exercise the above rights through the following channel:
Email: support@cvisioner.com (from your registered email address)
Requests are responded to within 30 days. If your request is rejected or insufficiently addressed, you have the right to file a complaint with the Personal Data Protection Authority (KVKK Kurulu).