KVKK

KVKK Clarification Text

Last Updated: July 28, 2026

This Clarification Text is prepared by Aloha Dijital Bilişim Eğitim ve Danışmanlık A.Ş. (the "Company" or "Data Controller") in capacity of Data Controller in accordance with Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") to inform our Customers and their End Users regarding the processing of personal data.

1. Identity of the Data Controller

Under the KVKK, the Data Controller is:

Aloha Dijital Bilişim Eğitim ve Danışmanlık A.Ş.
Marmara University Teknopark, Başıbüyük Dist.
Süreyya Paşa Başıbüyük St. 4/1 No:1
Maltepe, Istanbul 34854, Turkey
Phone: 0850-757-9427
Email: info@appvibezz.com

2. Processed Personal Data and Purposes of Processing

We process personal data for both our direct Customers (SaaS users) and End Users (app users whose data is collected via the AppVibezz SDK).

A. Direct Customers (SaaS Platform Users)

For our direct Customers, we process:

  • Identity & Contact Data: Name, surname, company name, email address, phone number.
  • Customer Transaction Data: Subscription tier details, invoice address, billing info, account activity history.
  • Log Data: Dashboard access records, IP addresses, login timestamps.

Purposes: Execution of subscription contracts, processing payments, executing support and communication, compliance with financial laws (taxation, invoicing), and ensuring security of the SaaS panel.

B. End Users (Data Processed via SDK on Behalf of Customers)

For End Users, we process pseudonymized telemetry data through our SDK:

  • Device & Network Info: Device manufacturer, OS version, locale, network carrier, country (derived from IP address).
  • Identifiers: Unique installation tokens, vendor ID (IDFV), and advertising ID (IDFA/GAID) where consent is given.
  • In-App Purchase Events: Transaction details, product identifiers, subscription purchase timestamps, renewals, cancellations.
  • Usage Events: App launches, user sign-up events, custom events (milestones, feature interactions) defined by the Customer.

Purposes: Providing mobile application analytics and intelligence dashboard, identifying failed billing/charge cycles, detecting and blocking refund fraud, and generating product signal insight metrics for the Customer.

3. Method and Legal Grounds of Personal Data Collection

Personal data is collected automatically through electronic means, such as cookies, our web panel forms, API requests, and SDK network payloads.

Under Article 5 of the KVKK, the legal grounds for processing are:

  • Contract Establishment/Performance (Article 5/2-c): Processing is necessary for the performance of the SaaS service contract with our Customers.
  • Legal Obligation (Article 5/2-ç): Processing is necessary for compliance with tax, corporate, and electronic communication laws in Turkey.
  • Legitimate Interests (Article 5/2-f): Processing is necessary for the legitimate interests of the Data Controller, provided it does not harm the fundamental rights and freedoms of the data subjects (e.g., maintaining platform security, identifying API abuse, fraud prevention).
  • Explicit Consent (Article 5/1): Required for collecting tracking telemetry (such as advertising IDs) from End Users, obtained by the Data Controller Customer via their app consent modals.

4. Transfer of Personal Data and Recipient Groups

Your personal data is not shared with third parties for advertising or profiling. Personal data is transferred to the following groups only:

  • Authorized Services & Sub-processors: Server hosting providers, payment gateways, and email dispatch tools to ensure system functionality.
  • Public Institutions: Tax authorities, law enforcement agencies, or courts in Turkey in accordance with legal directives.

5. Rights of Data Subjects under Article 11 of the KVKK

Under Article 11 of the KVKK, you have the right to:

  • Learn whether your personal data is being processed or not.
  • Request information if your personal data has been processed.
  • Learn the purpose of processing and whether data is used in accordance with its purpose.
  • Know the third parties to whom your personal data is transferred domestically or abroad.
  • Request correction of personal data if it is incomplete or incorrectly processed.
  • Request erasure or destruction of personal data under KVKK conditions.
  • Request notification of correction/erasure requests to third parties to whom data has been transferred.
  • Object to any negative result arising from analysis of data exclusively through automated systems.
  • Claim compensation for damage in case of unlawful processing of personal data.

6. Application Procedure for Data Subjects

If you are a direct Customer and wish to exercise your rights under Article 11, you may submit your written application to our company via:

  • A signed letter sent to: Marmara University Teknopark, Başıbüyük Dist. Süreyya Paşa Başıbüyük St. 4/1 No:1 Maltepe, Istanbul, Turkey (with ID verification documents).
  • An email sent from your registered email address (KEP) or from the email registered in our system to: info@appvibezz.com.

Applications will be concluded free of charge as soon as possible and within thirty (30) days at the latest.

Important Note for End Users: Since AppVibezz processes End User telemetry data as a Data Processor on behalf of the mobile app publisher (Data Controller), End Users must direct their KVKK applications to the relevant app publisher directly.