This text is compiled from the Turkish KVKK Disclosure Communiqué, the KVKK Cookie Guide and GDPR Art. 13. It is not binding until the data controller’s identity/contact details and final legal approval are completed (draft).
1. Data Controller
This notice is provided under Article 10 of Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) and Article 13 of the GDPR.
Data controller: Saints Atlas (pilot). Legal name, address, registered e-mail and, where applicable, representative/contact details will be added to this section before launch.
Security/logs: IP address, browser (user-agent), session and cookie data.
3. Purposes of Processing
Membership and account management, authentication and authorisation.
Providing and personalising the service (visits/routes, language/theme preferences).
Information security, abuse prevention and compliance with legal obligations.
4. Legal Bases
KVKK Art. 5 / GDPR Art. 6: formation/performance of a contract (account), the controller’s legitimate interest (security), legal obligation.
Non-essential (analytics/marketing) cookies and related processing only with EXPLICIT CONSENT (opt-in).
5. Transfers
Data may be processed via service providers (hosting/CDN/maps); recipient categories and, where applicable, the legal basis for international transfers (KVKK Art. 9 / GDPR Chapter V) will be specified before launch.
6. Retention
Personal data is retained for as long as required by the purpose of processing and by law; at the end of that period it is deleted, destroyed or anonymised.
7. Your Rights (KVKK Art. 11 / GDPR Arts. 15–22)
Access and information; rectification; erasure/destruction; objection to processing; data portability; objection to automated decisions.
Requests are handled via the account (download/delete data) and through the application channel to be opened before launch.
The right to lodge a complaint with the Turkish Personal Data Protection Board (KVKK) / the competent supervisory authority (GDPR) is reserved.
8. Cookie Policy
Essential cookies: technically necessary for session/security; no consent is required (legitimate interest/contract).
Functional cookies: remember preferences such as language/theme.
Analytics/performance and marketing cookies: only with EXPLICIT CONSENT; OFF by default (opt-in).
Non-essential cookies/tracking are not loaded until consent is given. The consent record (date, choice) is stored and can be withdrawn at any time.
