Draft — pending legal review

KVKK Information Notice

Version: draft-2026-10-14

DRAFT — requires legal review. Until a lawyer has reviewed it, the site shows it marked "draft". Fields in [square brackets] are facts not yet known; none has been invented, and the text is not final until they are filled.

1. Controller

Under Article 10 of Law No. 6698 on the Protection of Personal Data ("KVKK"), we inform you that the data controller is [CONTROLLER NAME — the founder as a natural person until a company exists], address [ADDRESS], contact hello@dutyclear.net (published once the address works).

2. Data processed

Through the "Request a demo" form, the careers form and contact channels: name and e-mail address; company name, role (broker, importer, other), approximate monthly declaration volume range, and anything you write in the free-text field; for the careers form, the profile link and message you provide; and, for security and record-keeping: the date and time of your submission, the site language you used, the version of this notice you confirmed, whether and when the acknowledgement e-mail for a demo request was sent, and a keyed hash (HMAC) of your IP address — never the address itself — used to limit repeated submissions (for the demo form it is held in a separate attempt record, and records older than 24 hours are deleted when the next attempt is recorded; for the careers form it is kept with the message). The bot check (Cloudflare Turnstile) runs in your browser, and your IP address is passed to Cloudflare to verify it; we do not store the bot-check result, browser information or your browser's user agent. Please do not enter special categories of personal data (health, religion, etc.) in the forms.

3. Purposes

To assess and answer your demo or contact request and arrange a call; to answer your careers message; to keep the site and service secure and prevent abuse and automated submissions; to meet legal obligations.

4. Method and legal basis

Collected electronically through the website forms. Legal bases: KVKK Art. 5/2-(c) (steps preliminary to a contract — answering your request) and Art. 5/2-(f) (legitimate interest — site security and abuse prevention). [LAWYER: confirm bases and whether explicit consent is needed]

5. Transfers

Your data is not sold. It is shared, only as needed, with providers: hosting (Vercel Inc. [region to be confirmed]), database (Supabase [project region to be confirmed]), bot check (Cloudflare, Inc. — Turnstile), e-mail delivery ([Resend — to be confirmed when set up]). Some are outside Türkiye, so transfers abroad under KVKK Art. 9 may occur. [LAWYER: confirm the Art. 9 transfer mechanism]

6. Retention

Demo and careers form data is kept for [PERIOD — to be set with the lawyer] after the request is concluded, then deleted, destroyed or anonymised.

7. Your rights (KVKK Art. 11)

You may ask the controller to: learn whether your data is processed; request information about it; learn its purpose and whether it is used accordingly; know the third parties it is transferred to at home or abroad; request correction if incomplete or wrong; request deletion or destruction under Art. 7; request that those actions be notified to recipients; object to a result against you arising from exclusively automated analysis; and claim compensation for damage from unlawful processing.

8. How to apply

Write to hello@dutyclear.net or to the postal address above. [LAWYER: confirm application methods required by the Communiqué on Application Procedures to the Data Controller]