Privacy Notice under Türkiye’s Data Protection Law (KVKK)
This English text is provided for convenience only. The Turkish version is the legally binding text and prevails in case of any discrepancy.
This notice has been prepared under Article 10 of Türkiye’s Law No. 6698 on the Protection of Personal Data ("KVKK") and the Communiqué on the Procedures and Principles of Fulfilling the Obligation to Inform, and concerns the processing of personal data of visitors to the HU1.AI website (www.hu1.site).
1. Data Controller and Scope
The data controller for the personal data covered by this notice is the HU1.AI venture (the "Data Controller"), reachable at info@hu1.site.
HU1.AI is not yet incorporated; the incorporation process is under way. Once the company is established in Türkiye, the data controller’s registered name, address and other identifying details will be added to this notice and it will be updated with a new version number.
This notice concerns only the personal data of visitors to the HU1.AI website. Data to be processed inside the HU1.AI product is outside its scope and is addressed in Section 7.
2. Personal Data Processed and How It Is Collected
The site has no membership, no accounts and no forms, and sets no cookies. The personal data processed is limited to three groups:
- Transaction security data: IP address, date and time of access, the requested page, and standard request information about your browser and device type. This data arises fully automatically as the site is served.
- Momentary technical data for usage measurement: standard technical information accompanying each request is processed fully automatically to measure aggregate use of the site; the output of that measurement is aggregated statistics not linked to your identity.
- Contact and identity data: your name, e-mail address, phone number and any other information you volunteer, only if you choose to reach us by phone, WhatsApp or e-mail, and obtained directly from you.
3. Purposes and Legal Bases
Your personal data is processed for the purposes and on the legal bases shown below (collection method and legal basis are presented together, as Article 10/1-ç pairs them):
| Data category | Purpose | Legal basis (KVKK Art. 5) | Method |
|---|---|---|---|
| Transaction security data | Serving, operating and securing the site | Art. 5/2-f: legitimate interest | Fully automatic |
| Momentary technical data for usage measurement | Measuring and improving aggregate use of the site | Art. 5/2-f: legitimate interest | Fully automatic |
| Contact and identity data | Responding to your request; carrying out pre-contractual steps toward a pilot call at your request | Art. 5/2-c: directly related to the formation of a contract | Through your contact, directly from you |
| All categories above | Meeting lawful requests of authorized public institutions | Art. 5/2-ç: compliance with a legal obligation | Method of the relevant category |
4. Recipients and Cross-Border Transfers
Your personal data may be transferred to our hosting service provider Vercel Inc. for hosting the site; to Meta Platforms, Inc. if you choose to reach us via WhatsApp; to Google LLC, which provides our e-mail infrastructure (Google Workspace), if you e-mail us; and, limited to lawful requests, to authorized public institutions.
Our website is hosted by Vercel Inc. (USA), whose server infrastructure is located abroad. The server records generated as the site operates (including IP addresses) and aggregated usage data are therefore processed abroad (in the United States) for the purpose of receiving hosting and infrastructure services. If you choose to reach us via WhatsApp or e-mail, the information you send is also processed on the foreign servers of the companies providing those services (Meta Platforms, Inc., USA; Google LLC, USA). These transfers are conducted in accordance with the conditions set out in Article 9 of the KVKK.
5. Retention
The Data Controller keeps no independent record of site visits. Server access records are held on the hosting provider’s infrastructure within the provider’s standard retention periods.
Your contact data is retained for the period necessary to conclude your request and to meet any legal requirements arising from it, and in any case for no more than two years after your request is concluded.
In all cases, personal data whose purpose of processing has ceased is deleted, destroyed or anonymized in accordance with Article 7 of the KVKK.
6. Your Rights as a Data Subject and How to Apply
Under Article 11 of the KVKK, you have the right to:
- Learn whether your personal data is processed,
- Request information if it has been processed,
- Learn the purpose of processing and whether the data is used in line with it,
- Know the third parties to whom it is transferred, in Türkiye or abroad,
- Request correction if it is incomplete or inaccurate,
- Request its deletion or destruction within the framework of Article 7,
- Request that corrections, deletions and destructions be notified to third parties to whom the data has been transferred,
- Object to a result arising against you from analysis exclusively by automated systems,
- Claim compensation if you suffer damage due to unlawful processing.
You may submit requests concerning these rights, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, to the e-mail address info@hu1.site. Information verifying your identity may be requested to establish that the application is yours.
Your application is concluded free of charge as soon as possible and within thirty days at the latest; if the operation additionally requires a cost, the fee in the tariff set by the Personal Data Protection Board may be charged.
Under Article 14 of the KVKK, if your application is rejected, you find the response insufficient, or no response is given in time, you may lodge a complaint with the Personal Data Protection Board within thirty days of learning of the response and in any case within sixty days of the application date.
7. Note on Data in the HU1.AI Product
The HU1.AI product is designed on a contractual arrangement under which, for student data, the school will be the data controller and HU1.AI the data processor. The agreements to be concluded with schools within the pilot will contain provisions on fulfilling the obligation to inform, on the conditions of processing, and on the parties’ obligations.
This notice does not cover data inside the product. Please direct product-related requests first to your school and, if you wish, to info@hu1.site.
8. Changes and Effect
Changes to this notice are published on this page with a new version number and update date.
The Turkish text of this notice prevails; the English version is provided for information only.