Why this is a separate document
The privacy policy explains what we do with data. This notice is the disclosure that Article 10 of Turkish Law No. 6698 on the Protection of Personal Data (KVKK) requires: the law fixes which headings must be stated, and in what terms. Both describe the same reality: one is written to be read, the other to satisfy the frame the law demands.
An English version is provided for readers who need it. The Turkish text is the operative one for anyone resident in Turkey.
This document is a draft and has not been reviewed by a lawyer.
Data controller
[FULL NAME] Address: [ADDRESS] Tax office / number: [TAX OFFICE / NUMBER] Contact: destek@shipaiengineer.com
Categories of personal data processed
- Identity: name
- Contact: email address
- Transaction security: password derivation, session token hash, IP address, session records
- Customer transaction: package purchased, transaction date, payment provider reference
- Other: lesson progress, quiz and exercise answers, capstone submissions, mentor conversations
Purposes of processing
Creating and managing membership · providing the purchased service and verifying access · recording and displaying learning progress · providing the mentor feature (when it is on) · preventing abuse and maintaining information security · finance and accounting · meeting legal obligations · handling requests and complaints.
Legal grounds (KVKK Art. 5)
- Art. 5/2-c: directly related to the conclusion or performance of a contract: account, access, progress, mentor.
- Art. 5/2-ç: compliance with a legal obligation: invoices and accounting records.
- Art. 5/2-f: legitimate interest: security, rate limiting, abuse detection.
- Art. 5/1: explicit consent: newsletter and marketing messages only.
Method of collection
Data is collected electronically, through the registration form, in-product interactions and automatic server logs.
Transfers
Personal data may be transferred to the payment service provider (Polar), to the hosting and network provider (Cloudflare), to the database provider (Neon; data is held in Frankfurt, Germany), and to competent public authorities where legally required.
⚠️ The AI mentor is currently switched off, and while it is off no data is transferred to any language model provider. When it is on, the text of your mentor messages is transferred to the language model provider in order to generate a reply, and the provider is named in this notice before the mentor opens. Do not enter personal data, third-party data or confidential information into the mentor.
All providers are located abroad, so those transfers fall under KVKK Art. 9; the basis for each transfer will be written into this notice after legal review.
Retention
Data is kept for as long as the processing purpose requires and for any mandatory retention period set by law. Deleting your account removes your learning data, submissions and mentor conversations in a single operation; financial records we are required to retain are the exception.
Your rights (KVKK Art. 11)
You have the right to learn whether your personal data is processed; to request information if it is; to learn the purpose of processing and whether it is used accordingly; to know the third parties, domestic or abroad, to whom it is transferred; to request correction if it is incomplete or inaccurate; to request erasure or destruction; to request that such correction or erasure be notified to third parties; to object to a result reached solely through automated analysis that works against you; and to claim compensation for damage caused by unlawful processing.
Access and erasure can be exercised immediately from the account settings page, with no application needed. For anything else, write to destek@shipaiengineer.com or send a written application to [ADDRESS]. Applications are answered within 30 days.