Privacy Policy
Última actualización: Not yet issued
Este documento se publica en inglés. La versión en inglés es la que prevalece.
Version 1.0 · not yet issued
Who is responsible
Hublinkly Ai Software Technology Ltd., Istanbul, Türkiye, is the data controller for information about visitors to our website and people who hold a Clavix360 account. Contact: info@clavix360.app. The registered postal address is to be confirmed.
For data your company enters into the platform about its own customers, employees or suppliers, your company is the controller and we act as processor. That relationship is governed by the Data Processing Addendum.
What we collect
When you visit the site. Pages viewed, approximate location derived from IP, browser and device type, referring site. Collected through cookies and server logs.
When you register or request a demo. Name, business email, phone, company name, country, industry, and what you tell us about your needs.
When you use the platform. Login times, IP address, actions taken in the application, and the content you create. Where your plan includes the Clock application, this includes clock-in and clock-out records and, if your company enables it, location at the moment of clocking.
When you pay. Billing name, company details, tax identifiers, and the transaction record. We do not receive or store full card numbers; these go directly to our payment provider.
When you use the Academy. Course progress, assessment results, and the certificate record that supports QR verification.
Why we use it, and on what basis
| Purpose | Legal basis |
|---|---|
| Providing the service you subscribed to | Performance of a contract |
| Billing, invoicing, tax records | Legal obligation |
| Security, fraud prevention, abuse monitoring | Legitimate interest |
| Product improvement and aggregate analytics | Legitimate interest |
| Marketing email about our own products | Consent, withdrawable at any time |
| Responding to your enquiries | Legitimate interest / pre-contractual steps |
We do not sell personal data. We do not use your platform content to train AI models for other customers.
Automated processing and AI
The platform includes AI-assisted features, including offer drafting and reporting insights. The model provider, its processing region, whether it retains content and whether that content is excluded from its training are to be confirmed, and this section will be completed before paid subscriptions open. These features assist your staff; they do not make decisions with legal effect about any individual.
Where your data is held
Primarily in Frankfurt, Germany, within the European Union. Any further location will be named on the Sub-processor List as it is confirmed. Where data is transferred outside Türkiye, the mechanism we rely on under KVKK Article 9 is to be confirmed.
How long we keep it
| Data | Retention |
|---|---|
| Account and platform content | Duration of subscription + 30 days |
| Invoices and tax records | 10 years, per Turkish tax law |
| Website analytics | 14 months |
| Demo workspace data | Deleted at the end of the demo period |
| Support correspondence | 24 months |
| Certificate records | Retained indefinitely — required for QR verification |
How we protect it
Encryption in transit and at rest, access control and role separation, each customer in an isolated workspace, regular backups, and monitoring. No system is perfectly secure; we tell affected customers and the authority about a breach within the timeframes the law requires.
Your rights
Under KVKK Article 11 you may ask whether we process your data, what we hold, why, who we share it with; ask for correction or deletion; object to processing; and seek compensation for unlawful processing. Write to info@clavix360.app, or to our KEP address (to be confirmed). We respond within 30 days, free of charge in ordinary cases.
If you are in the EU or UK, equivalent rights apply under GDPR, including portability and the right to complain to your supervisory authority.
Children
The service is for business use. We do not knowingly collect data from anyone under 18.
Changes
We post changes here and notify account holders of material changes by email.