KVKK Disclosure
This text is a draft; it will undergo legal review before launch.
Purpose and scope
This disclosure has been prepared under Turkish Personal Data Protection Law No. 6698 (KVKK) to inform you about how your personal data is processed when you use the Seat Circle service. It is a draft and will undergo legal review before launch.
Identity of the data controller
The data controller is [company name], which operates the Seat Circle service. You can reach us at [address], and for electronic applications via [KEP] and [email]. These details will be filled in with the real legal entity's information before launch.
Categories of personal data processed
We process identity and contact data (name, email, phone), your declaration of being over 18, your compatibility test answers and preferences, your table participation and reservation records, Stripe-sourced payment/transaction references, and WhatsApp communication records. Your card details are not held by us; they are processed only by the payment provider, Stripe.
Purposes of processing
Your data is processed to run the membership and application process, perform algorithmic table matching, ensure the 18+ condition and manual approval, carry out payment and refund operations, send notifications over WhatsApp, provide safety and fraud prevention, and meet our legal obligations.
Legal grounds
Under KVKK Article 5, processing relies on: the necessity of establishing or performing a contract (the table participation service); compliance with our legal obligations (e.g. financial records); our legitimate interests (safety, service quality); and, where required, your explicit consent (e.g. consent-based analytics/marketing cookies). For consent-based processing you can withdraw your consent at any time.
Transfer of data
To provide the service, your data may be shared on a limited basis with processors such as Stripe (payment), WhatsApp infrastructure (communication) and analytics providers. Because some of these providers are located abroad, a transfer abroad may take place under KVKK Article 9 and the conditions required by law. Data may also be shared with authorised public authorities upon a lawful request.
Method of collection
Your personal data is collected electronically through the application form, the compatibility test, the payment step, WhatsApp correspondence and your use of the website.
Your rights under KVKK Article 11
You have the right to: learn whether your personal data is being processed; request information if it is; learn the purpose of processing and whether the data is used accordingly; know the third parties to whom it is transferred at home or abroad; request correction if it is incomplete or inaccurate; request erasure/destruction when the conditions are met; request that these actions be notified to the parties to whom the data was transferred; object to a result against you arising solely from automated analysis; and request compensation for damage caused by unlawful processing.
How to apply
To exercise your rights, you can submit your requests via [email] or [KEP], or in writing to [address]. After verifying your identity, we conclude your application free of charge within 30 days at the latest; if the process entails a separate cost, the tariff set by the Board may apply. If you are not satisfied with our response, you retain the right to file a complaint with the Personal Data Protection Board.