FROM HOMELAND

Privacy Notice (KVKK)

Under Turkey’s Personal Data Protection Law No. 6698 (KVKK), this notice explains which personal data we process on the From Homeland platform, for what purposes and on what legal grounds.

This text is a draft. It must be completed and approved by a lawyer before publication. Fields in square brackets are still to be filled in.

Data controller

Your personal data is processed by the following company as data controller:

  • Company name: [company name]
  • Address: [address]
  • MERSIS no.: [MERSIS number]
  • Email: [email]

Personal data we process

Account data:

  • Name, email address and, optionally, mobile phone number
  • Your password, stored only as a one-way hash; the password itself is never stored

For developer accounts, also:

  • Company name, legal name, tax number and city
  • Verification documents (private files)

Contact and appointment form:

  • Name, mobile phone number, optional email address and your message
  • Your appointment preference
  • Consent records: when you accepted this privacy notice, and your optional consent to commercial messages

Problem reports:

  • Your message and optional email address

Security data:

  • Your IP address is processed for bot protection and rate limiting. Rate-limit records do not store your IP address, only an irreversible keyed hash derived from it.
  • Security logs (audit log) of account actions store the IP address and browser information.

Visit statistics:

  • No cookies are used and IP addresses are not stored. An anonymous code that changes every day is used instead. Records are deleted after 400 days.

Cookies:

  • Only strictly necessary cookies are used: a session cookie and a language preference cookie.

Purposes of processing

We process your personal data to:

  • Create and manage your account
  • Forward your contact and appointment requests to the developer of the project you choose
  • Verify developers
  • Keep the platform secure and prevent abuse and fraud
  • Meet our legal obligations
  • Produce anonymous statistics to improve the service
  • Send commercial electronic messages, only if you have given consent

Legal grounds

We process your data on the following legal grounds under Article 5(2) of the KVKK:

  • (c) Processing is directly related to the establishment or performance of a contract: account management, developer verification and forwarding your requests to developers
  • (ç) Processing is necessary to comply with a legal obligation
  • (f) Processing is necessary for our legitimate interests, provided it does not harm your fundamental rights and freedoms: platform security, abuse prevention and anonymous statistics

Commercial electronic messages are sent only on the basis of your explicit consent. You can withdraw this consent at any time.

Recipients and transfers

We share your data only with:

  • The developer of the project you select: information sent through the contact and appointment form is forwarded only to that project’s developer. Problem reports are not shared with the developer.
  • Service providers: the providers we use for hosting, database, bot protection and email delivery [service provider names]. Some of them may be located abroad.
  • Competent public authorities: where required by law.

Transfers abroad are made in line with the conditions of Article 9 of the KVKK [transfer mechanism to be confirmed by a lawyer].

Retention periods

We keep your data only as long as the purpose requires:

  • Account data: as long as your account exists, and afterwards for the statutory limitation periods
  • Contact and appointment requests: [period]
  • Anonymous visit statistics: 400 days
  • Security logs: [period]

When the period ends, the data is deleted, destroyed or anonymised.

Your rights under the KVKK

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

  • Learn whether your personal data is processed
  • Request information about it if it has been processed
  • Learn the purpose of the processing and whether the data is used for that purpose
  • Know the third parties, in Turkey or abroad, to whom your data is transferred
  • Request correction if your data is incomplete or inaccurate
  • Request deletion or destruction of your data under the conditions of Article 7 of the KVKK
  • Request that corrections, deletions or destructions be notified to the third parties to whom your data was transferred
  • Object to a result against you that arises solely from automated analysis of your data
  • Claim compensation if you suffer damage because your data was processed unlawfully

How to apply

To exercise your rights, you can send a written application to [address] or email us at [email].

We will respond within 30 days at the latest. No fee is charged unless handling your request involves an additional cost.

If you are not satisfied with our response, you can lodge a complaint with the Turkish Personal Data Protection Board (KVK Kurulu).