In accordance with the Law No. 6698 on the Protection of Personal Data ("KVKK"), your personal data will be processed by Soltudo Teknoloji Anonim Sirketi (the "Company") as the data controller, in a manner that ensures your security within the framework of the procedures and principles set out below. This disclosure text has been prepared by the Company acting as the data controller under the scope of the Law No. 6698 on the Protection of Personal Data ("KVKK") and the European Union General Data Protection Regulation ("GDPR").
Data Controller: Soltudo Teknoloji Anonim Sirketi (MERSIS NO: 0773089353800001)
Address: Kalaba Mahallesi Kutukcu Alibey Caddesi No: 2/B Ic Kapi No:106 Kecioren/ANKARA
Data Controller Email Address: [Email address to be specified]
This text has been prepared to explain the purposes for which your personal data specified below will be processed, the legal grounds, and the circumstances under which they may be transferred, by the Company (Soltudo Teknoloji Anonim Sirketi) acting as the data controller under the Law No. 6698 on the Protection of Personal Data ("KVKK"), when you use the digital platform named Person Eye (the "Application").
The Application (Person Eye) is a system that enables users to assess their mental performance and fatigue levels through gamified tests. Your personal data is processed in order to provide you with more accurate feedback based on your test results and usage behaviour within the application, and to determine your performance level.
During this process, your personal data is processed for the following purposes:
The personal data collected within the scope of the Application are as follows:
Your personal data is processed based on the following legal grounds:
Your collected personal data is analysed within the application and visualised results regarding your performance are presented to corporate customers (e.g., your employer). This transfer is based on your explicit consent and is made solely for the purpose of providing performance awareness.
Corporate users, when using the application for the evaluation of their employees, are obligated to obtain the necessary explicit consents from employees and fulfil their disclosure obligations under the Law No. 6698 on the Protection of Personal Data.
Your personal data is obtained through fully automated electronic means through the application during your use of Person Eye; your data may be transferred abroad based on your explicit consent pursuant to Article 9 of KVKK, within the scope of tools such as Airtable, Google Forms, website hosting services, email and IT servers.
Your data will in no way be transferred to third parties for advertising, commercial promotion, or direct marketing purposes.
Corporate users, when using the Application (Person Eye) for the evaluation of their own employees, are obligated to obtain explicit consent from the relevant employees and properly fulfil the disclosure obligation under the Law No. 6698 on the Protection of Personal Data.
All administrative, legal, and criminal liability that may arise from the violation of these obligations belongs entirely to the relevant corporate user. The Company (Soltudo Teknoloji Anonim Sirketi) cannot be held responsible in any way for any damage, administrative sanction, or dispute that may arise in this context.
Person Eye has been developed solely for the purpose of individual awareness, mental performance tracking, and supporting personal development. The test results provided through this application do not substitute for scientific diagnosis, medical assessment, or clinical evaluation.
The use of outputs obtained by corporate users as grounds for:
or similar proceedings arising from labour law or employment contracts is legally and contractually prohibited.
In this regard, all legal, administrative, and criminal liability arising from the use of data provided through the application for purposes other than intended belongs exclusively to the corporate user.
Your personal data may be shared with:
for the purposes of providing the application's technical and commercial infrastructure, operating the system, improving user experience, and providing access to the application, based on the legal ground of KVKK Article 5/2-f (legitimate interest of the data controller) and limited to the stated purposes only.
Your data will be retained for the duration required by the processing purpose, after which it will be deleted, destroyed, or anonymised. This period is determined in accordance with legal obligations and internal policies.
Personal data is retained for the duration required by the processing purpose and limited to the periods prescribed in the relevant legislation. Upon expiration of these periods, data is deleted, destroyed, or anonymised ex officio or upon the request of the data subject.
The Company takes appropriate technical and administrative measures to ensure the security of personal data and implements the necessary protective measures to prevent unauthorised access, disclosure, and loss of data.
The Company (Soltudo Teknoloji Anonim Sirketi) takes all necessary technical and administrative measures to prevent the unlawful processing and access of personal data and to ensure the preservation of data. The security of user passwords is exclusively the responsibility of the user.
Users have the following rights under Article 11 of KVKK and GDPR:
Related requests can be made through the application owner company's [email address] and will be concluded free of charge within 30 business days.
You may submit your requests regarding your rights under Article 11 of the Law No. 6698 on the Protection of Personal Data, in accordance with the provisions of the "Communique on the Application Procedures and Principles to the Data Controller":
you may submit your application.
Your applications will be concluded free of charge within 30 (thirty) days at the latest, depending on the nature of the request. However, if the process requires additional cost, the fee determined by the Personal Data Protection Board's tariff may be charged.
Personal data is retained for the duration required by the processing purpose and limited to the periods prescribed in the relevant legislation. Upon expiration of these periods, data is deleted, destroyed, or anonymised ex officio or upon the request of the data subject.
The Company (Soltudo Teknoloji Anonim Sirketi) takes all necessary technical and administrative measures to prevent the unlawful processing and access of personal data and to ensure the preservation of data. The security of user passwords is exclusively the responsibility of the user.
The data subject may submit their requests regarding their rights under KVKK in writing or through methods determined by the Company. Applications are evaluated and concluded within 30 (thirty) business days at the latest.
Before you start using the Application, you must give separate explicit consent to the following matters:
I give my explicit consent.
By approving this agreement, you are deemed to have declared your explicit consent to the data processing activities listed above.