KVKK Clarification Text
Personal Data Protection Notice
Notice concerning the processing of personal data belonging to The Neural Ledger visitors, users, and members.
Effective date: 5 August 2026
Article 1 – Introduction and Scope
This Personal Data Protection Notice (the “Notice”) has been prepared by Piyote Bilişim ve Danışmanlık Hiz. Tic. Ltd. Şti. (the “Company” or “Data Controller”), operator of the website theneuralledger.com (the “Site” or “The Neural Ledger”), pursuant to Article 10 of Law No. 6698 on the Protection of Personal Data (“KVKK”) and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform, for the purpose of informing visitors, users and members of the Site (each, a “Data Subject”) about the processing of their personal data. The Company processes personal data in accordance with the principles set out in Article 4 of the KVKK, namely lawfulness and fairness, accuracy and, where necessary, being up to date, processing for specified, explicit and legitimate purposes, being relevant, limited and proportionate to the purposes for which they are processed, and being retained for the period stipulated by applicable legislation or required for the purpose of processing.
Article 2 – Identity of the Data Controller
Pursuant to the KVKK, your personal data is processed by Piyote Bilişim ve Danışmanlık Hiz. Tic. Ltd. Şti., acting as data controller, through its registered office at İçerenköy Mah. Üsküdar-İçerenköy Yolu Cad. Bodur İş Merkezi No: 8 İç Kapı No: 11, Ataşehir / İstanbul 34638, Türkiye, within the scope and under the conditions described in this Notice.
Article 3 – Categories of Personal Data Processed
In connection with the provision of the services offered through the Site, the Company may process your identity data (first and last name), contact data (e-mail address), customer transaction data (membership and subscription records, plan preferences, billing and payment history), transaction security data (IP address, session and cookie records, device and browser information, login records), request and complaint management data (correspondence shared with us in connection with support requests) and, where you have subscribed, marketing permission data (newsletter and notification preferences). Sensitive payment instrument data, such as your card number, expiry date and security code, is not stored by the Company on any system; such data is processed exclusively within the infrastructure of the Company’s authorized payment service provider (virtual POS provider), in accordance with applicable legislation.
Article 4 – Purposes of Processing
The personal data referred to above is processed for the purposes of receiving and evaluating your membership application, verifying your identity and creating and managing your account, performing the services under your chosen subscription plan and enforcing the applicable usage limits, carrying out billing and collection processes, responding to support requests submitted by you, ensuring the security of the Site and our services and detecting and preventing unauthorized access and misuse, measuring and improving service quality, sending newsletters and informational content where requested, and fulfilling record-keeping, notification and other legal obligations arising from applicable legislation.
Article 5 – Legal Grounds for Processing
Your personal data is processed on the basis of the legal grounds set out in Article 5(2) of the KVKK, namely that processing is necessary provided that it is directly related to the establishment or performance of a contract, that processing is necessary for the Company to fulfil its legal obligations, that processing is necessary for the establishment, exercise or protection of a right, and that processing is necessary for the legitimate interests of the Company, provided that this does not harm your fundamental rights and freedoms. Where explicit consent is required by law (for example, for the transmission of commercial electronic communications), such consent is separately obtained pursuant to Article 5(1) of the KVKK.
Article 6 – Transfer of Personal Data
Your personal data may be transferred, strictly to the extent necessary for the stated purposes and in accordance with the conditions set out in Articles 8 and 9 of the KVKK, to the authorized payment institution(s) through which the Company’s virtual POS service is supplied, solely for the purpose of executing payment transactions; to cloud hosting and technical infrastructure providers necessary for the operation of the Site and our services; and, where legally required, to competent public authorities and judicial or administrative bodies upon their lawful request. The Company does not sell or rent your personal data to third parties for commercial purposes.
Article 7 – Method of Collection
Your personal data is collected through membership and contact forms completed electronically on the Site, usage records generated through API integration, support request forms and e-mail correspondence, as well as cookies and log records generated automatically during the operation of the Site, on the basis of the legal grounds described in Article 5 of this Notice.
Article 8 – Retention Period
Your personal data is retained for the period required by the relevant processing purpose and, in any event, for the mandatory retention periods stipulated under the Turkish Tax Procedure Law No. 213, the Turkish Commercial Code No. 6102 and other applicable legislation, after which it is deleted, destroyed or anonymized in accordance with the Company’s data retention and destruction policy.
Article 9 – Rights of the Data Subject
Pursuant to Article 11 of the KVKK, you may apply to the Company to learn whether your personal data is being processed, to request information as to such processing, to learn the purpose of processing and whether your data is used in accordance with that purpose, to know the third parties to whom your data is transferred domestically or abroad, to request rectification of incomplete or inaccurate data, to request deletion or destruction of your data where the conditions set out in Article 7 of the KVKK are met, to request that any rectification or deletion be notified to third parties to whom your data has been transferred, to object to a result that is to your detriment arising from the analysis of your data exclusively through automated systems, and to claim compensation for damages arising from the unlawful processing of your personal data.
Article 10 – Procedure for Applications
Data Subjects may submit requests concerning the rights listed in Article 9 above, together with documentation verifying their identity, by e-mail to [email protected] or in writing to İçerenköy Mah. Üsküdar-İçerenköy Yolu Cad. Bodur İş Merkezi No: 8 İç Kapı No: 11, Ataşehir / İstanbul 34638, Türkiye. The Company will finalize such applications free of charge, as soon as possible and in any event within thirty days, in accordance with Article 13 of the KVKK, provided that a fee determined by the Personal Data Protection Board may be charged where the request requires an additional cost to process.
Article 11 – Amendments to this Notice
The Company reserves the right to amend this Notice in line with changes in applicable legislation and/or updates to the Company’s policies. The current version of this Notice will at all times be made available on the Site.