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KVKK Clarification Text (Personal Data Protection Act)

Last Updated: 31.07.2026

This clarification text has been prepared under Article 10 of Turkish Law No. 6698 ("KVKK") to explain personal-data processing on the Turna Capital platform (Registered Trademark - Sole Proprietorship of Özgür Daşlıçay).

1. Identity of the Data Controller

The Data Controller for the Turna Capital platform is Özgür Daşlıçay (Turna Capital Sole Proprietorship). Tax Office: Düden Tax Office (Tax ID: 2710895771, National ID: 13304521188). Address: Göçerler Mah. 5351 Sk., Kepez / Antalya, Türkiye. Email: info@turnacapital.com, KEP: ozgur.daslicay@hs01.kep.tr.

2. Processed Personal Data and Purposes of Processing

We process your name, contact information (email, phone, address), corporate role, LinkedIn profile, billing data, tax credentials, payment histories, transaction logs, and identity documents (KYC). These are processed for: (a) Providing, managing, and optimizing the directory matchmaking dashboard; (b) Verifying identities (KYC checks) to prevent fraud and ensure platform safety; (c) Logging digital NDA (Non-Disclosure Agreement) acceptances and managing access control to startup data rooms; (d) Executing secure subscription payments via Creem and maintaining legal bookkeeping; (e) Communicating system alerts, client support updates, and platform newsletters.

3. Legal Grounds for Data Processing

Your personal data is processed based on the legal grounds defined in Article 5/2 of the KVKK: (a) Explicit consent of the data subject (where required); (b) Directly related to the establishment or performance of the Membership Agreement; (c) Mandatory for the Data Controller to fulfill its legal obligations under the Turkish Commercial Code and tax legislation; (d) Mandatory processing for the legitimate interests of the Data Controller, provided it does not harm the fundamental rights and freedoms of the data subject (e.g. system logs, audit logs, and security logs).

4. Transfer of Personal Data and International Transfers

Personal data may be shared with Creem (payments), Convex and Convex Auth (database, authentication and session services), Bunny CDN (document storage), Resend (transactional email), OneSignal (notifications, if consented), and Vercel (hosting and consent-based analytics). International transfers rely on applicable safeguards under Article 9 of the KVKK; explicit consent is requested separately where required.

5. Rights of the Data Subject under Article 11

According to Article 11 of the KVKK, you have the right to apply to Turna Capital via signed request or KEP (ozgur.daslicay@hs01.kep.tr) or email (info@turnacapital.com) to exercise your rights regarding your personal data.