hangisi?TR

⚠️ Draft — legal review required

This text has not been reviewed by a lawyer yet and is not in effect. Fields in square brackets are to be filled in. The Turkish version prevails.

KVKK Information Notice

Last updated: 26 October 2026 (draft v0.1)

Under article 10 of the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and the related Communiqué on the obligation to inform, we inform you about the personal data processed in the Hangisi app and on hangisi.me.

1. Data controller

[Company name] (“Hangisi”, “we”), registered at [address], MERSIS no. [MERSIS no]. Contact: [contact email] · KEP: [KEP address]

2. Personal data processed

  • Identity and contact: username, display name, email address, sign-in provider account ID.
  • Demographics: date of birth, (optional) gender and city.
  • User content and activity: posts, photos, comments, likes, saved posts, follow and block relationships, reports.
  • Vote data: which option was chosen on which poll, and the age range, gender and city at the time of the vote.
  • Transaction security: IP address, device push token, app version, platform, logs and error records.
  • Customer transactions: subscription and purchase status.
  • Marketing/analytics (only with permission): in-app usage events.
  • Consent records: document type, version and date accepted.

Special categories of personal data: depending on the poll's topic, votes may indirectly reveal political, religious, philosophical or other special-category data. Storing your votes linked to your account is therefore based on your explicit consent under KVKK art. 6 (see Explicit Consent).

3. Purposes

  • Concluding and performing the membership contract; creating and managing your account
  • Providing polls, votes, comments, follows and notifications
  • Ensuring each user casts only one vote per poll
  • Producing anonymous aggregate statistics
  • Personalising Explore and suggestions
  • Enforcing the minimum age of 13
  • Information security, preventing abuse and spam, content moderation
  • Running subscription and purchase processes
  • Detecting and fixing errors; (with permission) product analytics
  • Fulfilling legal obligations and responding to competent authorities

4. Legal bases and collection method

Your personal data is collected electronically through the app and website, by automated means and as provided by you. Legal bases:

  • KVKK art. 5/2-c: necessary for concluding or performing a contract (account, content, votes, notifications, subscriptions)
  • KVKK art. 5/2-ç: compliance with a legal obligation (security logs, authority requests)
  • KVKK art. 5/2-e: establishing, exercising or protecting a right (report and moderation records)
  • KVKK art. 5/2-f: legitimate interest, provided it does not harm your fundamental rights (security, spam prevention, personalisation)
  • KVKK art. 5/1 and art. 6/2: explicit consent (storing votes linked to your account, usage analytics)

5. Transfers

Limited to the purposes above, your personal data may be transferred to our providers for hosting (Railway, EU), authentication and notifications (Google Firebase), file storage (Cloudflare), error tracking (Sentry), analytics (PostHog EU cloud, with permission) and purchases (RevenueCat, Apple, Google), and to legally competent public authorities.

As some of these providers are located or operate outside Türkiye, transfers are made with the safeguards set out in KVKK art. 9 (adequacy decision, standard contractual clauses or other appropriate safeguards).

[Review: confirm the art. 9 transfer mechanism for each provider and the standard contract notification to the Board.]

6. Retention and destruction

Your personal data is kept for as long as the purpose requires and for legally mandated retention periods. When you delete your account your profile, posts and comments are deleted, and votes are anonymised by removing the user link. Details are in our [Personal Data Retention and Destruction Policy].

7. Your rights under KVKK art. 11

  • Learn whether your personal data is processed
  • Request information if it has been processed
  • Learn the purpose of processing and whether it is used accordingly
  • Know the third parties in Türkiye or abroad to whom it is transferred
  • Request correction if it is incomplete or inaccurate
  • Request deletion or destruction under the conditions of KVKK art. 7
  • Request that corrections, deletions and destructions be notified to third parties it was transferred to
  • Object to an adverse outcome resulting solely from automated analysis
  • Claim compensation for damage arising from unlawful processing

You can send requests, in line with the Communiqué on Application Procedures to the Data Controller, to [contact email] from your registered email address, to our KEP address, or in writing to our address above. Requests are concluded free of charge within 30 days at the latest. Data export requests are handled through the same channel.

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