Personal Data Protection and Privacy Policy

1. Identity of the Data Controller

Data Controller: Soltudo Teknoloji Anonim Sirketi (MERSIS NO: 0773089353800001)

Address: Kalaba Mahallesi Kutukcu Alibey Caddesi No: 2/B Ic Kapi No:106 Kecioren/ANKARA

As Soltudo Teknoloji Anonim Sirketi (the "Company"), the privacy and security of your personal data is among our top priorities. In this regard, we would like to inform you about your personal data processed through the Person Eye application and website, in order to fulfil our obligation to inform under Article 10 of the Law No. 6698 on the Protection of Personal Data ("KVKK").

This text has been prepared to meet the privacy policy requirements of the App Store and Google Play platforms. Personal data refers to any information that identifies or makes you identifiable.

2. Processed Personal Data

The data processed includes the name, surname, age, email address, mobile number, employer information, application usage data, test results, IP address, device and browser information of the Person Eye application user.

Personal data is processed in a limited manner for the purposes of creating and managing user accounts, analysing test results, personalising the in-app experience, ensuring application security, and fulfilling legal obligations.

Personal data is processed based on the user's explicit consent or the legal grounds specified in Article 5 of KVKK. In particular, data may be processed to fulfil legal obligations arising from relevant legislation, primarily the Law No. 6563 on the Regulation of Electronic Commerce, the Turkish Criminal Code No. 5237, and Law No. 6698.

3. Data Processing Purposes

Your personal data is processed for the provision of services necessary for the operation of the Person Eye application, including conducting gamified tests and evaluating their results, creating and managing user accounts, performing statistical analyses, and enabling corporate users to analyse employee performance.

Personal data may be shared with domestic business partners, service providers, and official institutions when necessary, in compliance with KVKK, limited to the purposes stated above. Transfer of data abroad is possible upon acceptance of this disclosure text.

4. Transfer of Personal Data

Your personal data may be transferred, limited to the purposes stated above:

Domestically: To business partners, infrastructure providers, consulting firms, and authorised public institutions from which services are received.

Abroad: Only based on your explicit consent, due to cloud services or system infrastructure being hosted abroad.

The transfer of your data abroad is subject to the consent you provide through the in-app explicit consent screen. Personal data collected within the scope of the application is processed, interpreted, and presented to corporate users benefiting from the application service in the form of visualised reports.

Although the anonymisation of personal data is intended during data analysis, the relevant data may be directly or indirectly attributable to the user.

4.1. Corporate User Obligations

Corporate users using the Application (Person Eye) for the evaluation of their employees are obligated to obtain explicit consent from employees under KVKK and GDPR, fulfil their disclosure obligations, and be responsible for the accuracy, currency, and legality of the data they share.

All responsibility regarding the legality, accuracy, and currency of personal data collected in this framework belongs to the corporate user.

Any damages, litigation costs, administrative fines, and all direct/indirect losses that the Company may incur due to the violation of these obligations shall be compensated by the corporate user.

5. Disclaimer

The Application (Person Eye) is intended solely for individual awareness and assessment purposes and cannot be used for any professional diagnosis, analysis, or official evaluation purpose. Corporate users cannot use the results obtained from the application as grounds for employment contract termination, performance evaluation, or similar administrative/criminal proceedings and sanctions.

In the event of such situations, Soltudo Teknoloji Anonim Sirketi cannot be held responsible for any damages the user may incur. The Company expressly declares its non-liability for all damages arising from the use of such results.

6. Data Collection Method and Personal Data Retention Obligation

Your personal data is collected electronically through the mobile application by automatic means. Taking into account the periods and legal obligations specified in the relevant legislation, personal data will be retained for the duration required by the processing purposes.

Upon expiration of the period, the relevant data will be deleted, destroyed, or anonymised.

8. Your Rights

Your rights under Article 11 of KVKK:

  • Learning whether your personal data is being processed
  • Requesting information if it has been processed
  • Learning the purpose of processing and whether it is being used in accordance with its purpose
  • Knowing the third parties to whom it has been transferred domestically or abroad
  • Requesting correction if it has been processed incompletely or incorrectly
  • Requesting deletion or destruction if processed in violation of KVKK

When the user wishes to exercise these rights, they may apply in writing or through the methods provided within the application. Applications are concluded within 30 (thirty) business days at the latest, excluding force majeure.

9. Data Retention and Deletion

Your personal data is retained only for the necessary period in accordance with the processing purposes, and is then deleted, destroyed, or anonymised in compliance with KVKK and GDPR.

10. User Rights

You have the following rights under KVKK Art. 11 and GDPR:

  • Learning whether your personal data is being processed
  • Requesting information if processed
  • Learning the purpose of processing and whether it is being used accordingly
  • Learning about domestic/international data transfers
  • Requesting correction of incomplete or incorrect data
  • Requesting deletion or destruction of data
  • Objecting to results against you when processing is done by automated systems
  • Claiming compensation in case of damage
  • Data portability to a different service provider (GDPR)
  • Withdrawing explicit consent (processing done until withdrawal is not affected)

You may submit your requests regarding these rights through the application form or contact address within the application.

14. Application Method

Users may submit their requests regarding personal data to the data controller in writing or through the application methods provided within the application. Applications regarding this matter will be concluded within 30 business days at the latest.

This Disclosure Text may be updated when necessary, and updates will come into effect upon announcement within the application.

15. App Store Policies

This privacy policy is published visibly in the application store in compliance with App Store and Google Play requirements, and is consistent with the "Data Safety" and "Privacy Label" information in the store forms in terms of data processing, security measures, and user rights.