Privacy Policy and KVKK Disclosure

At EvPaylaşımı, the security of your personal data is our priority. This text has been prepared in accordance with Law No. 6698 on the Protection of Personal Data (KVKK).

1. Data Controller

The data controller responsible for processing your personal data:

• Title: Koray Türk (Ev Paylaşımı)
• Email: [email protected]

2. Personal Data Collected

The following personal data may be collected during platform use:

Identity and Contact Information

• Full Name
• Phone number (verified)
• Date of birth (Required: 18+ age verification & compatibility matching)
• Gender (Required: Enables messaging preferences & roommate matching)
• Profile photo (optional)

Listing Information

• Listing title, description, and photos
• Location information (city, district)
• Price and room features

Messaging and User Content

• Text messages and related sender, recipient, sent time, read status, and listing context information
• Photos and other images sent by users in messages
• Voice recordings created and sent at the user's request, including technical information such as duration, file type, file size, and waveform
• Complaint and report content together with review and moderation records
• The microphone is activated only when the user starts a voice recording; the recording is prepared on the device and transmitted to the platform only after the user confirms sending it

Payment Information

• Payment and purchase transaction records processed through Paddle for web payments or through the Apple App Store or Google Play for mobile in-app purchases
• Card information is processed by the relevant payment or store provider and is not stored by the platform

Technical Information

• IP address
• Browser and device information
• Platform usage history and activity logs
• App- and device-associated notification tokens used to deliver mobile push notifications
• UTM parameters, referring page information, and campaign click identifiers used to measure advertising and campaign sources

3. Purposes of Data Processing

• Creating user accounts and identity verification (18+ age requirement)
• Publishing listings and moderation services
• Providing text, image, and voice messaging services between users (Gender enables user-controlled messaging preferences)
• Roommate compatibility matching based on age ranges and gender preferences
• Processing payment transactions
• Ensuring platform security and preventing misuse
• Fulfilling legal obligations
• Review of messaging content by authorized platform administrators for security, technical support, user complaint, or reporting processes
• Transmission and storage of user content, including voice recordings and images, prevention of abuse, and response to lawful requests when required
• Delivery of notifications and measurement of product usage and campaign performance

4. Legal Basis for Data Processing

Your personal data is processed based on the following legal grounds:

• Explicit Consent: Profile information and optional data with your explicit consent during registration
• Contract Performance: Data necessary for providing platform services
• Legitimate Interest: Platform security, fraud and abuse prevention, and complaint investigation, provided that users' fundamental rights and freedoms are not harmed
• Legal Obligation: Financial legislation and legal reporting requirements

5. Data Sharing and Transfer

Your personal data may be shared with the following parties to a limited extent:

• Other Users: Information you share in listings (name, gender, age, and photo) may be visible to other users. Your messaging content is delivered only to the user you are messaging. Your phone number is not shared with other users.
• Payment Service Providers: Necessary transaction data is shared with Paddle for web payments and with the Apple App Store or Google Play for mobile in-app purchases
• Hosting and Technical Service Providers: The application and database infrastructure may be provided by Railway; full-size and thumbnail profile images, full-size and card-size listing images, and images and voice recordings sent in messages may be stored through Cloudflare R2; and notification delivery may be provided through Expo, Apple, and Google services. These providers may be located abroad; transfers are limited to providing the service and are carried out subject to the conditions and appropriate safeguards under Article 9 of the KVKK.
• Legal Authorities: With authorized authorities such as courts and prosecutors in case of legal obligation

6. Data Retention Periods

• Active user accounts: As long as the account remains active
• Account deletion requests: After the 30-day restoration period, direct identity and contact information is anonymized, the profile image is removed, and listings are deleted
• Payment and transaction records: For the periods required by applicable financial law, evidence, and dispute limitation periods
• Active messages and attachments: May be retained while the account or conversation remains active to provide messaging and preserve the other party's conversation history
• Deleted messages, cleared conversations, and associated image/voice recordings: May be kept in a restricted moderation archive for as long as necessary for security, complaint investigation, abuse prevention, and legal disputes; they are deleted or anonymized when the retention purpose ends

7. Data Security

The following measures have been taken to secure your personal data:

• Secure data transmission with SSL/TLS encryption
• Secure server infrastructure and regular backups
• Access control and authorization systems
• Regular security updates, access authorization reviews, and review of security event records

8. Your Rights Under KVKK

Under Article 11 of Law No. 6698, you have the following rights:

• Learning whether your personal data is being processed
• Requesting information if processed
• Learning the purpose of processing and whether used appropriately
• Knowing third parties to whom data is transferred domestically or abroad
• Requesting correction if incomplete or incorrect
• Requesting deletion or destruction under conditions stipulated by law

You can apply to [email protected] to exercise these rights. Your request will be answered within 30 days at the latest.

9. Cookies

The platform uses cookies to improve user experience:

• Essential Cookies: Cookies necessary for session management and security (session cookies)
• Functional Cookies: Cookies that remember your preferences such as language preference, theme (dark/light mode)

10. Privacy Policy Changes

This privacy policy may be updated when deemed necessary. Significant changes will be announced on the platform and through appropriate communication channels.