Personal Data Notice (KVKK)

This text is a draft; it must be reviewed by a lawyer before publication.

This text explains, pursuant to Art. 10 of the Turkish Personal Data Protection Law No. 6698 (KVKK), how your personal data is processed when you use the Firas app. A detailed explanation is in the "Privacy policy". Reading this text is not an approval; it is information only.

1. Data controller

• Name: [VERİ SORUMLUSU ADI]
• Address: [ADRES]
• Email: info@getfiras.com
• KEP: [KEP adresi varsa]

2. Personal data processed

Firas does not ask you to create an account; it does not collect your name, contact details or identity. The app does not connect to the internet: the data controller does not access any of your personal data through the app.

The following are processed only on your phone and never reach the data controller: your photo and camera image (not stored), face and hand measurement ratios, your reading history, the dream text you wrote, your birth date, time and place, your settings, and the record of your acceptance of the terms and of your photo consent (text version and moment). These stay on your device, and the saved ones are encrypted.

The calculation of face or hand ratios from the photo is done on the device; the ratios are turned into labels such as "wide" or "medium", are not used for identification and are not transferred to the data controller as biometric data. Your explicit consent is asked on a separate screen before this processing.

3. Purposes of processing

• To do the face or hand reading on your phone (only with your explicit consent).
• To record on your device, with the text version and moment, that you accepted the terms of use, read this notice and gave your photo consent.

4. Legal grounds

• Calculating ratios from the photo on the device: your explicit consent (KVKK Art. 5/1; Art. 6 in case it is considered special category personal data). Consent is not a condition of the service: if you do not consent, you continue without a photo by describing yourself; you can withdraw your consent at any time in Profile → "Photo consent".
• Acceptance and consent records: being directly related to the conclusion or performance of a contract (KVKK Art. 5/2-c) and proof of consent.

5. Method of collection

The app sends no data to the data controller. The photo is processed on your phone, automatically, only when you open the camera and after you have given your consent; the acceptance and consent records are created on your phone when you tick the boxes and tap the button.

6. Transfer

• Abroad (KVKK Art. 9): There is no transfer abroad at the moment. If the AI interpretation is turned on, the summary of the reading will be transferred to Anthropic, PBC (the AI provider), based in the USA; you will be told before it is turned on and asked for your approval.
• Server: Country where the server is hosted: Türkiye. The app does not connect to this server; the server only publishes the website.
• Within Türkiye: There is no transfer to any other person or institution.

7. Retention period

• Photo: never stored.
• The data on your device (reading history, settings, acceptance and consent records): only on your device, until you delete it or uninstall the app.
• With the data controller: no personal data is stored.

8. Your rights under KVKK Art. 11

By applying to the data controller, you can exercise the following rights:

• to learn whether your personal data is being processed,
• to request information about it if it has been processed,
• to learn the purpose of processing and whether it is used in line with that purpose,
• to know the third parties in Türkiye or abroad to whom it has been transferred,
• to request its correction if it has been processed incompletely or incorrectly,
• to request its erasure or destruction within the framework of the conditions in KVKK Art. 7,
• to request that the correction, erasure and destruction be notified to the third parties to whom it has been transferred,
• to object to an outcome against you that arises from analysis exclusively by automated systems,
• to request compensation for damage if you suffer damage due to unlawful processing.

Right to erasure: All the data on your device is deleted instantly and irreversibly with Profile → "Delete all my data" (readings, characters, couplets, birth details, encryption key, settings, onboarding consent, acceptance of the texts, photo consent). Since the data controller holds no record of yours, this action fulfils the right to erasure. To withdraw your photo consent: Profile → "Photo consent".

9. How to apply

You can submit your requests in Turkish, in accordance with the Communiqué on the Procedures and Principles for Applications to the Data Controller:

• in writing to [ADRES],
• by registered electronic mail (KEP) to [KEP adresi varsa],
• or to info@getfiras.com.

Your application will be concluded free of charge within 30 days at the latest. Since the app does not know who you are, for requests about the data on your device it is enough to explain which data you are asking us about; we cannot match your identity with a record on the device. If your application is rejected, if you find the answer insufficient, or if no answer is given in time, you can file a complaint with the Personal Data Protection Board (KVKK Board).