KVKK Disclosure Statement

Your personal data is processed by Mirber, 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.

On the server side, the data controller may process personal data in the following categories:

• Identity and contact data: name, organization, email, phone.
• Transaction security data: IP address, session/sign-in logs, device and browser information, a device fingerprint for license validation.
• License and authorization data: user role, access permissions, license status.
• Sanitized technical records: error/performance metadata for software improvement (does not contain HTS content, cell values, file names, or case information).

The HTS files you upload to the platform and the analysis outputs derived from them are processed locally on your device only; this content is not transferred to the data controller and is not stored by the data controller.

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.

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.

Your personal data processed on the server side (account, license, and security records) may be transferred, limited to the processing purposes and in compliance with Articles 8 and 9 of KVKK, to hosting/infrastructure service providers used to maintain the service and to legally authorized public institutions. It is not otherwise shared with third parties.

Because the content of the HTS files you upload and the analysis outputs never leave your device, they fall outside the scope of these transfers; such content is not transferred to any infrastructure/service provider or third party.

Your personal data processed on the server side 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. The retention and deletion of the HTS content and analysis outputs stored locally on your device are entirely under your own control.

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.

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.