As the data controller under the Personal Data Protection Law No. 6698 ("KVKK"), Penyu Teknoloji A.Ş. wishes to inform you about the processing of your personal data.
Data Controller
Penyu Teknoloji A.Ş. - as a company operating in Turkey, we are the data controller under KVKK. Contact: kvkk@penyu.io
Personal Data Processed
Identity information (first name, last name), contact information (email, phone), financial information (payment confirmation records - card number is not stored), and usage data (search history, booking information, device information) are processed.
Purposes of Personal Data Processing
Your personal data is processed for the purposes of service delivery and management, contract performance, identity verification and security, fulfillment of legal obligations, customer support and communication, and service development.
Legal Bases
Your personal data is processed under KVKK Article 5 on the legal bases of the establishment and performance of the contract, fulfillment of legal obligations, protection of our legitimate interests, and your explicit consent (for marketing communications).
Data Transfer
Your personal data may be shared with the payment processor Stripe (USA), server infrastructure providers, and, where mandatory, authorized public authorities, within the framework of the safeguards required by KVKK.
Your Rights Under KVKK
Under KVKK Article 11, you have the right to: learn whether your personal data is being processed, request information if it has been processed, learn the purpose of processing, learn about domestic/international transfers, request correction of incomplete/inaccurate data, request its deletion or destruction, object to processing, and request compensation for damages.
Exercising Your Rights
To exercise your rights, you can apply in writing to kvkk@penyu.io. Your requests will be answered within 30 days at the latest. Applications are free of charge.
Device Information
When you sign in to the Penyu app we record technical information about the device you use: brand, model and model code, device type, operating system and version, app version, memory and screen size, device language, region and time zone, whether the device supports eSIM, mobile carrier name and connection type, the status of notification and location permissions, the app installation ID and the last connection IP address. We do not collect the IMEI, your phone number or advertising identifiers.
We process this information to check eSIM compatibility, support you with installation problems, show you and our security team which devices accessed your account, prevent fraud and improve the app, on the legal bases of performance of the contract and our legitimate interests. Records are kept while your account is open and deleted when you delete your account. You can request a copy or the deletion of your device records at kvkk@penyu.io.
If you have questions about this policy, you can reach us at destek@penyu.io .