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Index Harmony — Turkish Data Protection Notice (KVKK)

Effective date: 9 July 2026 · This is a courtesy translation. This notice is governed by Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”); in the event of any conflict or ambiguity, the Turkish version prevails and is the sole legally binding text.

1. Identity of the Data Controller

Under Law No. 6698 on the Protection of Personal Data (“KVKK”), the data controller for personal data processed through indexharmony.com (the “Platform”) is:

Legal name
Renkmobil Bilişim Turizm Optik Sanayi ve Ticaret Anonim Şirketi
MERSİS No.
0734074050328441
Trade Registry No.
198834
Tax office / No.
Hitit Tax Office / 7340740503
Address
Aziziye Mah. Dedekorkut Cad. Minilife No:5/1, Kapı No:1, Çankaya/Ankara, Türkiye
E-mail
info@indexharmony.com
Registered e-mail (KEP)
renkmobil@hs01.kep.tr

(the “Company”) processes your personal data as described below.

2. Categories of Personal Data Processed

Depending on your use of the Platform, the following categories of personal data may be processed:

  • Identity & contact data: name/legal name, e-mail address, billing address (where provided).
  • Account data: account creation date, one-time login code (OTP) records, session data.
  • Transaction security data: IP address, browser/user-agent, session cookie.
  • Financial data: payment method, order/invoice amount and date, bank-transfer reference and IBAN (for refunds). Card numbers are never stored on Company servers — card data is processed directly by our payment provider, PayTR.
  • Customer transaction data: scanned site/domain, scan history, purchased Plan/credit/Fix Pack license, support ticket records.
  • Marketing preferences: newsletter/e-mail notification preferences, where applicable.

Important: the Platform's core “AI accessibility scan” function processes the publicly available technical content of the website you submit — not your or your account's personal data. No special-category personal data belonging to third parties is collected or processed during a scan.

3. Purposes of Processing

Your personal data is processed to: create and authenticate your account (including passwordless OTP sign-in); provide and invoice the Services; process payments via PayTR and/or bank transfer; respond to support requests; secure the service (abuse prevention, rate limiting); comply with legal obligations; and pursue the Company's legitimate interests (service quality, troubleshooting).

4. Method of Collection and Legal Basis

Your personal data is collected directly from you when you register, place an order, or contact support, and automatically while you use the Platform (IP address, cookies, session data). Legal bases: KVKK Art. 5/2(c) — necessary for the performance of a contract; Art. 5/2(ç) — compliance with a legal obligation; Art. 5/2(f) — the Company's legitimate interest (security, fraud/abuse prevention); and, where required, Art. 5/1 — your explicit consent.

5. Transfer of Personal Data

  • Payment provider (PayTR): to process card payments.
  • Hosting/infrastructure provider: to host the Platform and your data.
  • Scan/rendering infrastructure provider: a third-party headless-browser/rendering service used to measure how the URL you submit appears to different AI-bot identities — this transfer concerns the scanned site URL only; your account/identity data is not shared with this service.
  • E-mail delivery service: to deliver OTP codes, order confirmations and invoices.
  • Competent public authorities: where required by law.

The Company may use large-language-model providers (e.g. OpenAI) for its own internal content-generation tooling (e.g. the blog engine); this use is limited to the Company's own brand/content generation and does not involve transferring Customer account or identity data to those providers.

6. Cookies

The Platform uses a single, strictly-necessary session cookie (roughly 24-hour validity) to keep you signed in. No advertising or cross-site tracking cookies are used.

7. Retention Periods

  • Account and transaction data is retained for as long as your account is active, and thereafter per the Data Deletion and Account Closure Policy.
  • Invoice and accounting records are retained for the statutory periods set out in applicable Turkish tax and commercial law.
  • IP/access logs collected for security purposes are retained only for as long as reasonably necessary, then deleted or anonymized.
  • Free, account-less scan records may be retained indefinitely in anonymized form, not linkable to any individual, for statistical purposes.

8. Data Security

The Company applies encryption (including irreversible password hashing), access controls and technical/administrative safeguards. For scan requests, rate limiting and SSRF (server-side request forgery) protection are applied to prevent abuse.

9. Your Rights (KVKK Article 11)

Under KVKK Article 11 you have the right to: learn whether your personal data is processed; request information about such processing; learn the purpose of processing and whether it is used accordingly; know the third parties to whom your data is transferred, domestically or abroad; request correction of incomplete or inaccurate data; request erasure or destruction under the conditions set out in KVKK Article 7; request that corrections/erasure be notified to third parties to whom your data was transferred; object to a result that arises solely from automated analysis to your detriment; and claim compensation for damage arising from unlawful processing.

10. How to Apply

You may submit requests, together with information verifying your identity, to info@indexharmony.com or to our registered e-mail (KEP) address renkmobil@hs01.kep.tr. The Company will conclude your request as soon as possible and within thirty (30) days at the latest, as required by KVKK.

11. Amendments

The Company may update this Notice to reflect changes in law or in the Platform's services. The updated version takes effect once published on indexharmony.com.

info@indexharmony.com · Renkmobil Bilişim Turizm Optik Sanayi ve Ticaret Anonim Şirketi