Protection of Personal Data

KVKK Disclosure Statement

Last updated: June 10, 2026

This disclosure statement is prepared by Fotera as the data controller under Turkish Personal Data Protection Law No. 6698 (KVKK).

1. Data Controller

Your personal data is processed by Fotera, the data controller operating the MBHTS platform, in accordance with KVKK and applicable legislation. Contact details for your requests are provided at the end of this statement.

2. Personal Data Processed

Personal data in the following categories may be processed:

  • Identity and contact data: name, organization, email, phone.
  • Transaction security data: IP address, session/sign-in logs, device and browser information.
  • License and authorization data: user role, access permissions, license status.
  • HTS files uploaded to the platform and analysis outputs (content is processed under user control).

3. Purposes of Processing

Your personal data is processed to provide the service, authenticate and authorize users, manage licenses/access, ensure information security and prevent abuse, fulfill legal obligations, and improve service quality.

4. Legal Grounds for Processing

Under Article 5 of KVKK, your personal data is processed on the grounds that it is necessary for the establishment or performance of a contract, for the data controller to fulfill its legal obligations, for the legitimate interests of the data controller (provided it does not harm your fundamental rights and freedoms), and, where required, based on your explicit consent.

5. Transfers

Your personal data may be transferred, limited to the processing purposes and in compliance with Articles 8 and 9 of KVKK, to infrastructure/service providers used to maintain the service and to legally authorized public institutions. It is not otherwise shared with third parties.

6. Retention Period

Your personal data is retained for as long as the processing purpose requires and for the limitation/retention periods prescribed by applicable legislation. At the end of the period, your data is deleted, destroyed, or anonymized.

7. Rights of the Data Subject (KVKK Art. 11)

Under Article 11 of KVKK, you have the following rights:

  • To learn whether your personal data is processed and to request information about it.
  • To learn the purpose of processing and whether it is used accordingly.
  • To know the third parties to whom data is transferred domestically or abroad.
  • To request correction of incomplete or inaccurately processed data.
  • To request deletion or destruction in accordance with the law.
  • To request that correction/deletion be notified to third parties to whom data was transferred.
  • To object to a result against you arising from automated analysis.
  • To claim compensation for damages incurred due to unlawful processing.

8. How to Apply

To exercise the rights above, you may submit your requests, together with information verifying your identity, to the contact address at the end of this statement. Your requests are concluded as soon as possible and at the latest within the period prescribed by KVKK, depending on their nature.

Contact

For any questions, requests, or applications regarding this document, you can contact Fotera at the email address below.

info@mirber.com.tr

This document is provided for informational purposes; the final version should be reviewed by legal counsel before it takes effect.