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KVKK - Personal Data Protection Law Information

Last Updated: November 14, 2024

Note: This document provides information in English regarding compliance with Turkey's Personal Data Protection Law (KVKK - Kişisel Verilerin Korunması Kanunu). This information is provided for Turkish users of ResumePolish AI.

Roxy Apps, LLC ("we," "our," or "us") operates the ResumePolish AI mobile application (the "Service"). This document explains how we process personal data in accordance with Turkey's Personal Data Protection Law No. 6698 (KVKK).

Important Notice: ResumePolish AI helps you create professional resumes and cover letters. The AI-generated content is provided as a tool to assist with resume enhancement and should be reviewed and customized by you before use.

1. Data Controller

In accordance with KVKK, the data controller is:

Roxy Apps, LLC
131 Continental Dr, Suite 305
Newark, DE 19713
United States
Email: admin+resumepolish@roxyapps.net

2. Personal Data We Process

2.1 Identity Information

Apple ID information (for authentication purposes)
Email address (optional, if provided by the user)
User account identifiers

2.2 User Content

Resume content and text
AI-generated resume enhancements and formatting
Cover letters and related data
Chat conversations with the AI career assistant
User preferences and settings

2.3 Technical Data

Device information (device type, operating system, unique device identifiers)
IP address and network information
Usage analytics and interaction data
Application logs and error reports

2.4 Transaction Data

In-app purchase information
Subscription status and history
Payment transaction identifiers (processed through Apple App Store)

3. Purposes of Processing Personal Data

We process your personal data for the following purposes in accordance with KVKK Article 5 and Article 6:

Service Provision: To provide and maintain the ResumePolish AI service, including AI-powered resume enhancement and cover letter generation
User Authentication: To authenticate your identity using Apple ID and manage your user account
AI Processing: To process your resume content using artificial intelligence technology to generate enhancements and formatted resumes
Service Improvement: To analyze usage patterns and improve the quality and functionality of our Service
Communication: To send push notifications and communicate with you about the Service (with your consent)
Transaction Processing: To process in-app purchases and manage subscriptions
Legal Compliance: To comply with legal obligations and respond to legal requests
Security: To ensure the security and integrity of the Service and prevent fraud or abuse

4. Legal Basis for Processing

We process your personal data based on the following legal grounds under KVKK:

Explicit Consent (KVKK Art. 5/2-a): For certain processing activities where we have obtained your explicit consent
Performance of Contract (KVKK Art. 5/2-c): To fulfill our contractual obligations in providing the Service
Legal Obligation (KVKK Art. 5/2-e): To comply with legal obligations applicable to us
Legitimate Interest (KVKK Art. 5/2-f): For service improvement, security, and fraud prevention, provided such interests do not override your fundamental rights and freedoms

5. Transfer of Personal Data

5.1 Third-Party Service Providers

We may transfer your personal data to the following third-party service providers who assist us in operating the Service:

PostHog: Analytics and product analytics services (data transferred to servers in the United States and European Union)
OneSignal: Push notification services (data transferred to servers in the United States)
Supabase: Authentication and backend services (data transferred to servers in the United States and European Union)
Firebase (Google): AI processing and cloud services (data transferred to servers in the United States)
RevenueCat: In-app purchase and subscription management (data transferred to servers in the United States)
Apple: App Store services and Apple ID authentication (data processed in accordance with Apple's privacy policy)

5.2 International Data Transfers

Your personal data may be transferred to and processed in countries outside of Turkey, including the United States and countries within the European Union. These transfers are necessary for the provision of our Service.

We ensure that appropriate safeguards are in place for international data transfers, including:

Standard contractual clauses approved by relevant data protection authorities
Compliance with applicable data protection laws
Contractual obligations requiring third parties to protect your personal data

6. Your Rights Under KVKK

As a data subject under KVKK, you have the following rights regarding your personal data:

6.1 Right to Learn Whether Personal Data is Processed (KVKK Art. 11/1-a)

You have the right to learn whether your personal data is being processed.

6.2 Right to Request Information (KVKK Art. 11/1-b)

If your personal data has been processed, you have the right to request information about such processing.

6.3 Right to Learn the Purpose of Processing (KVKK Art. 11/1-c)

You have the right to learn the purpose of processing your personal data and whether it is used in accordance with its purpose.

6.4 Right to Know Third Parties (KVKK Art. 11/1-d)

You have the right to know the third parties to whom your personal data is transferred, both domestically and abroad.

6.5 Right to Request Correction (KVKK Art. 11/1-e)

If your personal data is processed incompletely or inaccurately, you have the right to request correction.

6.6 Right to Request Deletion or Destruction (KVKK Art. 11/1-f)

You have the right to request deletion or destruction of your personal data under the conditions set forth in KVKK Article 7.

6.7 Right to Request Notification (KVKK Art. 11/1-g)

You have the right to request notification of the operations made pursuant to subparagraphs (e) and (f) to third parties to whom your personal data has been transferred.

6.8 Right to Object (KVKK Art. 11/1-h)

You have the right to object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems.

6.9 Right to Claim Compensation (KVKK Art. 11/1-i)

You have the right to claim compensation for damages arising from the unlawful processing of your personal data.

7. How to Exercise Your Rights

To exercise your rights under KVKK, you may submit a written request to us using one of the following methods:

Email: admin+resumepolish@roxyapps.net
Mail: Roxy Apps, LLC, 131 Continental Dr, Suite 305, Newark, DE 19713, United States

Your request should include:

Your identity and contact information
A clear description of the right you wish to exercise
Any relevant details to help us process your request

We will respond to your request within 30 days in accordance with KVKK Article 13. If your request is rejected, we will provide the reason for rejection in writing or electronically.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration, in accordance with KVKK Article 12. These measures include:

Encryption of data in transit and at rest
Access controls and authentication mechanisms
Regular security assessments and audits
Employee training on data protection
Secure data storage and backup procedures

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this document, unless a longer retention period is required or permitted by law.

When personal data is no longer needed, we will delete, destroy, or anonymize it in accordance with KVKK requirements.

Specific retention periods:

Account Data: Retained for the duration of your account and for a reasonable period after account deletion for legal and security purposes
Resume Content: Retained until you delete it or delete your account
Transaction Data: Retained as required by applicable tax and commercial laws
Analytics Data: Retained in anonymized form for service improvement purposes

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and store information about your use of the Service. For detailed information about our use of cookies and tracking technologies, please refer to our Privacy Policy.

11. Children's Personal Data

Our Service is not intended for children under the age of 13. We do not knowingly collect personal data from children under 13. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately. If we become aware that we have collected personal data from a child under 13, we will take steps to delete such data in accordance with KVKK requirements.

12. Changes to This KVKK Information

We may update this KVKK information document from time to time to reflect changes in our data processing practices or legal requirements. We will notify you of any material changes by posting the updated document on this page and updating the "Last Updated" date.

We encourage you to review this document periodically to stay informed about how we protect your personal data.

13. Complaints

If you believe that your personal data has been processed in violation of KVKK, you have the right to file a complaint with the Turkish Personal Data Protection Authority (KVKK - Kişisel Verileri Koruma Kurumu).

Turkish Personal Data Protection Authority
Nasuh Akar Mah. 1407. Sok. No:4
06520 Balgat/Çankaya/Ankara, Turkey
Website: www.kvkk.gov.tr
Phone: +90 312 216 50 00

14. Contact Information

For any questions, requests, or concerns regarding the processing of your personal data under KVKK, please contact us:

Roxy Apps, LLC
131 Continental Dr, Suite 305
Newark, DE 19713
United States
Email: admin+resumepolish@roxyapps.net

Important: This document is provided in English for informational purposes. For official Turkish language information, please contact us directly. This document should be read in conjunction with our Privacy Policy and Terms of Service.