Previous version: October 5, 2024. This version is updated for the passwordless sign-in, payment, push notification, AI assistant, data export and account deletion features of the new Kaynac platform.
At KAYNAC, we value the privacy and security of our users' ("Users") personal data on the KAYNAC platform ("Platform"). This Privacy Policy is designed to explain how KAYNAC collects, uses, stores, and shares your personal data in compliance with the Turkish Personal Data Protection Law ("KVKK") and the General Data Protection Regulation ("GDPR").
By using our Platform, you agree to the terms of this Privacy Policy.
1. Data We Collect
KAYNAC collects various personal data to ensure the effective use of the Platform. The types of data collected include:
- Identity Information: Name, surname, date of birth, and, where necessary under KVKK, Turkish ID number.
- Contact Information: Email address, phone number, and mailing address.
- Financial Information: Payment history and billing details. For card payments on the web, the card number goes directly to the payment provider iyzico; KAYNAC does not store card numbers and keeps only the last 4 digits for receipts. For in-app purchases, payment details are handled by the App Store or Google Play; KAYNAC receives only the store's transaction record to verify the purchase.
- Account Information: Sign-in methods (email address, phone number, Google or Apple account identifier), transaction history, and wallet activity. The Platform does not use or store passwords; session keys are stored hashed.
- AI Conversations: The messages you write to the Kaynac AI assistant, its answers, and the screen the conversation took place on.
- Device and Notification Information: The notification token of devices on which you allowed push notifications, and your notification preferences.
- Technical Data: IP address, device information, browser type, and usage data collected through cookies and other tracking technologies.
2. Purpose of Processing Personal Data
KAYNAC processes your personal data for the following purposes:
- To ensure the proper functioning of the Platform and provide services tailored to your needs.
- To process payment transactions and ensure financial security.
- To provide customer service and technical support.
- To let the Kaynac AI assistant produce request drafts, category suggestions, offer summaries and help answers when the user asks for them.
- To send account, request, offer and credit updates by email, in-app and push notifications.
- To comply with legal obligations and regulatory requirements.
- To detect and prevent fraud and other illegal activities.
- To enhance user experience and improve the functionality of the Platform.
- To send users marketing campaigns, promotions, and service announcements.
3. Legal Basis for Processing Personal Data
KAYNAC processes personal data based on the following legal grounds under KVKK and GDPR:
- Performance of a Contract: Necessary data to provide Platform services.
- Legal Obligation: Compliance with legal and regulatory requirements.
- Legitimate Interest: To improve user experience and ensure Platform security.
- Explicit Consent: In cases where there is no other legal basis, personal data will be processed with the user's explicit consent.
Consent and Consent Management
KAYNAC will obtain your explicit consent where necessary, such as for marketing, advertising, analytics, and profiling activities. You have the right to withdraw your consent at any time. Consent withdrawal requests can be submitted via support@kaynac.com. You can change the push notification permission in your device settings, and your email and push preferences in the app under Settings > Notifications, at any time.
4. Sharing of Personal Data with Third Parties
KAYNAC may share personal data with third parties under the following circumstances:
- Service Providers: Third-party providers for payment processing, technical support, and analytics services. These include:
- iyzico: card payments on the web.
- Apple (App Store) and Google (Google Play): in-app purchases, and sign-in with Apple and Google.
- Google Firebase Cloud Messaging (FCM): delivering push notifications to your device. The notification content and the device notification token are sent to this service.
- OpenAI: the Kaynac AI assistant. The messages you write to the assistant and the context needed to answer (the screen you are on, the related request, offer or credit details) are sent to OpenAI. Conversations are stored per user in KAYNAC's systems.
- Email and SMS delivery providers: sign-in links, verification codes and notifications.
- Legal Requirements: If required by law, court orders, or regulatory authorities.
- Suppliers and Partners: To ensure the functionality of the Platform and meet user requests in a limited capacity.
5. International Data Transfers
KAYNAC transfers personal data to countries with adequate data protection levels as required by GDPR and KVKK. If personal data is transferred outside the European Union, appropriate security measures will be put in place to ensure the protection of your data.
Of the service providers listed above, OpenAI, Google (Firebase Cloud Messaging, Google Play, sign-in with Google) and Apple (App Store, sign-in with Apple) may process data on servers outside Türkiye. These transfers take place only as far as needed to provide the service concerned and with the safeguards required by law.
6. Data Retention
KAYNAC retains personal data for as long as necessary to fulfill the purposes outlined in this policy or as required by law.
- Identity and Contact Information: Retained as long as the user's account is active, and after account closure for compliance with legal obligations.
- Financial Information: Retained in compliance with legal and tax requirements. For this reason the credit ledger is kept even after an account is deleted.
- AI Conversations: Stored with your account and included in your data export file.
- Technical Data: Retained for the duration of the user's interaction with the Platform and as required for security purposes.
7. User Rights
Under GDPR and KVKK, users have the following rights regarding their personal data:
- Right of Access: You can request access to your personal data.
- Right to Rectification: You can request correction of inaccurate or incomplete data.
- Right to Erasure (Right to be Forgotten): You can request the deletion of your personal data.
- Right to Object: You can object to the processing of your personal data.
- Right to Data Portability: You can request your personal data in a structured format and have it transferred to another data controller.
- Right to Restriction of Processing: You can request that the processing of your personal data be restricted.
Data Export and Account Deletion in the App
- Data export: You can request a data export in Settings. Your data is prepared as JSON and the download link is valid for 7 days.
- Account deletion: You can delete your account completely in the app under Settings > Account > "Delete account". Your sign-in methods, contact details and sessions are removed; financial records (the credit ledger) are kept because of legal obligations.
Data Portability Right
Users have the right to request the transfer of their personal data to another data controller. Requests for data portability can be submitted via support@kaynac.com. Requests will be processed within 30 days in compliance with GDPR.
8. Cookies and Tracking Technologies
KAYNAC uses cookies and other tracking technologies to enhance the user experience and optimize services. Cookies help remember user preferences and improve the performance of the Platform.
- Users can disable or restrict cookies through their browser settings.
- Disabling cookies may affect the functionality of some services on the Platform.
9. Data Security
KAYNAC takes the necessary technical and administrative measures to protect users' personal data:
- Encryption and firewalls,
- Access control mechanisms,
- Regular security audits are conducted.
While KAYNAC takes all reasonable precautions, it cannot guarantee complete security of data transmitted over the internet.
10. Third-Party Websites
The KAYNAC Platform may contain links to third-party websites. KAYNAC is not responsible for the content or privacy practices of these external websites. Users are advised to review the privacy policies of third-party websites before using them.
11. Changes to the Privacy Policy
KAYNAC reserves the right to modify this Privacy Policy from time to time. Any changes will be published on the Platform, and users will be informed accordingly.
We encourage users to regularly review this page to stay informed about changes to our Privacy Policy.
12. Contact Information
For any questions or requests related to your personal data, please contact us at support@kaynac.com.
By accepting this Privacy Policy, you consent to the processing of your personal data as outlined in this document while using the KAYNAC platform.