KVKK Aydınlatma Metni (Clarification Text)

1. Purpose

This text explains, under Article 10 of Law No. 6698 on the Protection of Personal Data, how Hublinkly Ai Software Technology Ltd. processes personal data.

2. Categories of data processed

Identity, contact, customer transaction, finance, transaction security, audit and marketing data, and — where the employer enables the Clock application — attendance and location data of that employer’s staff.

3. Purposes of processing

Delivering the subscription service, account management, billing and legal record-keeping, security and fraud prevention, support, and — with consent — marketing communications.

4. Legal grounds (Articles 5 and 6)

• Necessary for the performance of a contract
• Necessary for compliance with a legal obligation
• Necessary for our legitimate interests, without prejudice to your fundamental rights
• Explicit consent, where relied on — marketing, and [cross-border transfer, if that is the chosen mechanism]

5. Transfers

The recipients are the sub-processors listed on the Sub-processor List. The transfer mechanism relied on under Article 9 is to be confirmed.

6. Method of collection

Electronically, through the website, the applications, email and support channels.

7. Your rights under Article 11

This detail will be published before paid subscriptions open. The statutory list under Article 11, and the application procedure under the Communiqué on Application Procedures, are reproduced in full in the Turkish text, which is the operative version of this document.

8. Application

Written application to our registered address, or through our KEP address — both to be confirmed — or from the email address held in our systems.