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KVKK Privacy Notice

Last updated: October 10, 2026

This is a courtesy English translation. In case of any conflict between this version and the Turkish original, the Turkish version prevails.

1. Data controller

Under Article 10 of Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform, your personal data is processed by the data controller below:

• Data controller: Abdulnur Tecim (an individual)
• Address: Gebizli Mah. İbni Sina Cad. No:39, Muratpaşa/Antalya, Türkiye
• Email: destek@skilltobe.net
• Platform: "Skill ToBe" (skilltobe.net)

2. Personal data we process

• Identity and contact: Name, email address.
• Account and security: Password (stored encrypted), session information, IP address, browser/device type, language and other preferences.
• User activity: The questions you type or say to the avatar, conversation history, saved content and collections.
• Audio and video: Only when you grant permission and use the relevant feature, camera footage and audio to process your request at that moment.
• Location: Only when you grant permission and use a feature that requires location.

The platform is not designed to collect special categories of personal data such as health, religion, or political opinion. If you share such information yourself in free text or speech, it is processed only to respond to your request; we therefore recommend avoiding unnecessary sharing.

3. Purposes of processing

• Creating your membership and managing your account,
• Answering your questions through the avatar and directing you to suitable sources,
• Keeping your conversation history, favorites, and collections to provide features such as "My Library",
• Keeping the platform secure and preventing misuse and unauthorized access,
• Improving the quality and operation of the service,
• Meeting our legal obligations and responding to your requests.

4. Legal bases

Your personal data is processed on the following legal bases under Article 5(2) of KVKK:

• Processing is directly related to the establishment or performance of a contract (membership and provision of the service),
• Processing is necessary for the controller to comply with a legal obligation,
• Processing is necessary for the legitimate interests of the controller, provided it does not harm your fundamental rights and freedoms (security and improving the service),
• Processing is necessary for the establishment, exercise, or protection of a right.

Device permissions such as camera, microphone, and location rely on your explicit consent given through the permission prompt your browser shows you, and can always be withdrawn in your browser settings.

5. How personal data is collected

Your data is collected electronically, wholly or partly by automated means, through forms you fill in while using the site, account creation, your written/spoken conversations with the avatar, your device permissions, and technical information your browser transmits automatically.

6. Transfer of personal data

Your personal data is not sold. To the extent necessary for the platform to work, it may be transferred to the following service providers:

• DeepInfra, Inc. (United States): Processing the messages you send to the avatar with an AI language model to generate replies.
• Supabase: Storing data such as your account, session, and conversation history on cloud infrastructure. Servers may be located abroad.
• Hosting provider: Publishing the site; connection information such as your IP address may technically be visible during this.
• Browser speech recognition service: When you use the microphone button, your browser may send your audio to its own speech recognition service (for example, Google for Chrome). This transfer is made by your browser and is subject to your browser provider's policy.
• Google Fonts: Your IP address may be sent to Google when certain fonts are loaded.
• Competent public authorities: When legally required.

Because some of these providers are located abroad, your personal data may be transferred abroad. These transfers are made in accordance with the conditions in Article 9 of KVKK; the basis is that the transfer is necessary to provide the service and, where required, your explicit consent. If you do not accept transfer abroad, you should not use the avatar and chat features, because they cannot work without these providers.

7. Retention period

Your personal data is kept while your account is active and for as long as the purpose of processing requires. When you delete your account, your data is deleted, destroyed, or anonymized unless there is a legal retention obligation.

8. Your rights under Article 11 of KVKK

By applying to the data controller, you may:

• Learn whether your personal data is processed,
• Request information if it has been processed,
• Learn the purpose of processing and whether it is used accordingly,
• Know the third parties, in Türkiye or abroad, to whom your data is transferred,
• Request correction if it is incomplete or inaccurate,
• Request deletion or destruction under the conditions in Article 7 of KVKK,
• Request that correction, deletion, and destruction be notified to third parties to whom your data was transferred,
• Object to a result against you arising from analysis of your data exclusively by automated systems,
• Claim compensation if you suffer damage due to unlawful processing.

9. How to apply

To exercise the rights above, you can send your requests in the following ways:

• Email: From the email address registered to your account, to destek@skilltobe.net, writing "KVKK Application" in the subject line.
• In writing: By a wet-signed petition to Gebizli Mah. İbni Sina Cad. No:39, Muratpaşa/Antalya, delivered in person or through a notary.

Your application must clearly include your name, surname, contact information, and the subject of your request. We may ask for additional information to verify your identity. Depending on their nature, your requests are concluded free of charge within 30 days at the latest; if the process requires a separate cost, a fee under the tariff set by the Personal Data Protection Board may be charged. If you find the response to your application insufficient, you may file a complaint with the Personal Data Protection Board within 30 days of learning the response, and in any case within 60 days of the application date.