KVKK information notice

Data controller

Data controller: NaughtyDevelopment Ltd · 17 Green Lanes, London, N16 9BS, United Kingdom · company no. 12477931, registered in England and Wales. For applications and questions, write to hello@naughtydevelopment.com.

Data processed

Identity and contact: your email address; your computer's name, if it contains your name.

Customer transactions: your store's website address and platform, your plan, subscription status, and your Stripe customer and subscription IDs.

Transaction security: your password hash, session keys, verification codes, device ID, operating system, app version, when the account was first and last seen, sign-in logs and IP address.

Marketing: your consent to product announcements, and the sentence and date of that consent.

Connected services: whether you are signed in to Claude and Gemini, and your plan.

Site crawl: the titles, descriptions and similar fields of your site's public pages; any personal data that appears in those fields.

We do not process special categories of personal data. Data processed on your computer that never reaches us is outside the scope of this notice; you are its data controller.

Method of collection

We collect the data electronically, by automated or partly automated means, through the trial form, the sign-up and sign-in screens, and the device record and plan check the app sends to the server. Payment details come from Stripe; site crawl data comes from your site's public pages.

Purposes and legal grounds

Answering your trial request and corresponding about set-up: directly related to the formation of a contract (Law Art. 5/2-c).

Opening and managing your account, running your subscription, performing the site crawl and providing support: performance of the contract (Art. 5/2-c).

Keeping invoice and accounting records: fulfilling our legal obligation (Art. 5/2-ç).

Keeping accounts and systems secure, preventing misuse and enforcing the device limit: our legitimate interest, provided it does not harm your fundamental rights and freedoms (Art. 5/2-f).

Establishing, exercising or defending a right in a dispute: Art. 5/2-e.

Sending product announcements and release notes: your explicit consent (Art. 5/1) and your approval under Law No. 6563. Not giving consent does not stop you from requesting a trial or opening an account.

Transfers

Your data is transferred, only for the purposes above, to the suppliers that run the service: Railway for hosting, Resend and our mailbox provider for email, Stripe for payment, Cloudflare for network and security, Google for speed measurement. Because these suppliers' servers are abroad, the transfer is made under Article 9 of the Law, relying on the standard contracts published by the Board.

Where the law requires it, your data may be transferred to authorised public authorities. Your data is not sold and is not given to third parties for marketing.

Retention period

Data is kept for as long as the purpose of processing requires and for the retention periods set by law, and is then deleted, destroyed or anonymised. The period for each type of data is in the “Retention” section of the privacy notice.

Your rights

Under Article 11 of the Law you have the right to: learn whether your personal data is processed; request information if it is; learn the purpose of processing and whether it is used for that purpose; know the third parties in Türkiye or abroad to whom it is transferred; request correction if it is incomplete or inaccurate; request its erasure or destruction under the conditions of Article 7; request that these actions be notified to the third parties it was transferred to; object to a result against you arising solely from analysis by automated systems; and claim compensation if you suffer damage from unlawful processing.

You can withdraw the explicit consent you gave for product announcements at any time; withdrawal does not affect the lawfulness of processing before it.

You can send your application in Turkish, stating your identity and your request clearly, from the email address registered in your Mimir account to hello@naughtydevelopment.com, or submit it by registered electronic mail (KEP), secure electronic signature, mobile signature or in writing.

We conclude your application free of charge within thirty days at the latest; if the action involves an additional cost, the tariff set by the Personal Data Protection Board may apply. If you find our reply insufficient or receive no reply in time, you may complain to the Board under Article 14 of the Law.

Language

This is an English translation of the Turkish text. If the two differ, the Turkish text prevails.