Disclosure Notice on the Protection of Personal Data (KVKK, Turkish Personal Data Protection Law)

1. Data Controller

Pursuant to Law No. 6698 on the Protection of Personal Data ("KVKK", the Turkish Personal Data Protection Law), your personal data is processed by SporLens (an individually operated platform) (the "Data Controller"), acting in the capacity of data controller, within the scope described below.

E-mail: info@sporlens.com

2. Personal Data Processed

The following categories of personal data are processed through the Platform:

• Identity and contact data: E-mail address.
• Account security data: An irreversible cryptographic digest (hash) of your password. Your password is never stored in plain text in any form.
• Transaction security data: Session records, login date/time information and IP address records.
• Usage data: Telemetry records relating to in-Platform page views and feature usage.
• Third-party account link data: Your Telegram user ID, if you opt in to the Telegram notification feature.

3. Purposes of Processing Personal Data

Your personal data is processed in accordance with the general principles set out in Article 4 of the KVKK for the following purposes:

• Establishing and performing the membership agreement; creating the account, verifying identity and managing sessions,
• Defining and tracking free trial and premium access entitlements,
• Providing the notification service via Telegram upon your request,
• Conducting information security processes; detecting and preventing unauthorized access and misuse,
• Measuring service quality and improving the Platform,
• Fulfilling legal obligations, including providing information to authorized institutions and bodies,
• Handling requests and complaints, and providing evidence in potential disputes.

4. Legal Bases and Method of Collection

Your personal data is collected electronically via the membership form, by automated means during your use of the Platform (server logs, cookies) and, if you initiate the Telegram link, through the relevant pairing flow. This data is processed on the basis of the following legal grounds set out in Article 5 of the KVKK:

• Processing being directly related to the establishment or performance of a contract (Art. 5/2-c): management of the account, trial period and premium access,
• Fulfilment of a legal obligation (Art. 5/2-ç): access and traffic records required to be kept under the legislation,
• Legitimate interest (Art. 5/2-f): ensuring the security of the Platform and improving the service,
• Explicit consent (Art. 5/1): only for the transfer abroad described below and the optional Telegram link.

5. Transfer of Personal Data

Your personal data may be transferred to authorized public institutions and bodies where there is a lawful request, in accordance with Article 8 of the KVKK. Beyond this, your data is not shared with third parties and is not sold for advertising or marketing purposes.

6. Retention Periods

• Account data (e-mail, password hash, Telegram ID): For as long as the membership continues; deleted within 30 days at the latest upon termination of the membership or upon your deletion request.
• Session and IP records: Up to 2 years, without prejudice to minimum retention obligations under the applicable legislation.
• Usage telemetry: Up to 2 years; stored in anonymized form where possible.
• Records subject to a dispute: For the duration of the applicable limitation periods.

Upon expiry of these periods, your data is deleted, destroyed or anonymized.

7. Your Rights under Article 11 of the KVKK

Under Article 11 of the KVKK, by applying to the Data Controller, you have the right to:

• Learn whether your personal data is being processed,
• Request information about such processing if it has taken place,
• Learn the purpose of the processing and whether the data is used in accordance with that purpose,
• Know the third parties to whom your data is transferred, domestically or abroad,
• Request rectification of data that is incomplete or inaccurate,
• Request erasure or destruction of the data under the conditions set out in Article 7 of the KVKK,
• Request that rectification, erasure and destruction operations be notified to the third parties to whom the data has been transferred,
• Object to a result arising to your detriment from analysis carried out exclusively by automated systems,
• Claim compensation for damage incurred as a result of unlawful processing.

All of the rights listed above are available to you.