KVKK Clarification Text (Personal Data Protection Act)

Last Updated: 19.06.2026

This Clarification Text has been prepared in accordance with Article 10 of the Turkish Law on the Protection of Personal Data No. 6698 ("KVKK") to inform our users about how their personal data is collected, processed, transferred, and stored by Turna Capital Danışmanlık A.Ş. in our capacity as the Data Controller.

1. Identity of the Data Controller

Under the KVKK, the Data Controller is Turna Capital Danışmanlık A.Ş., located at Maslak Mah. Büyükdere Cad. No:1 Sarıyer / İstanbul. The Company operates the digital matchmaking and directory platform connecting investors, entrepreneurs, and professional consultants.

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

Your personal data is shared with domestic and international service providers to maintain platform operations: (a) Creem: For processing subscription fees securely; (b) Clerk: For secure user logins, verification, and session state; (c) Convex & Bunny CDN: For cloud database systems, server hosting, and secure storage of sensitive documents (KYC files, pitch decks); (d) Resend: For sending transaction emails. Because the secure database and authentication servers of Convex and Clerk are located abroad, your data is transferred abroad based on your explicit consent granted during registration.

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 to: (a) Learn whether your personal data is processed; (b) Request information if your data has been processed; (c) Learn the purpose of processing and whether it is used in line with that purpose; (d) Know the third parties to whom data is transferred, domestically or abroad; (e) Request correction of incomplete/incorrect data; (f) Request deletion or destruction of data; (g) Object to any outcome against you caused by automated analysis; (h) Claim compensation for damages arising from unlawful processing. You can submit your requests to info@turnacapital.com using your registered email address.