Avviso KVKK (Turchia)

Effective date: 2026-09-11 Version: 2026-09-11

This page is the English-language reference version of the disclosure notice required under Article 10 of Turkish Law No. 6698 on the Protection of Personal Data ("KVKK") for users located in Türkiye. The Turkish-language version of this notice is the operative text for KVKK purposes; this English version is provided for convenience. To read the Turkish version, switch the language to Turkish.

It supplements, and should be read together with, the general Privacy Policy.

1. Data controller

Under KVKK, Chord Collect acts as the data controller ("veri sorumlusu") for the personal data described here and in the Privacy Policy. Contact: [email protected]. See the Imprint for the current status of our registered legal entity.

2. Purpose of processing

We process your personal data for the purposes listed in the Privacy Policy §2. These purposes are: operating your account; providing sync, storage, search, performance, Band Mode, and Community features; processing subscriptions; sending transactional communications; automatically screening uploaded images for policy-violating content and acting on Community reports and copyright notices; showing advertising to free-plan users; product analytics; preventing fraud and abuse; and complying with legal obligations.

3. Method of and legal grounds for collecting personal data

We collect personal data by fully or partly automated means, in electronic form. Some of it you provide directly: the information you enter in the sign-up and sign-in forms, the content you add or upload to the app, and the support messages and problem reports you send us. Some of it is collected automatically by our mobile app, our website, and our servers while you use the Service: device and usage information, product analytics events, crash reports, and your IP address. The rest comes from third parties: when you sign in with Google or Apple we receive your account identifier, name, and e-mail address from that provider, and we receive your subscription status from the app stores and our subscription management provider.

We process this data on the following grounds set out in KVKK Art. 5/2:

• (c) Necessary for the performance of a contract: creating and operating your account
• (ç) Necessary for compliance with a legal obligation: tax, accounting, and regulatory recordkeeping, and responding to lawful requests from Turkish authorities
• (f) Necessary for our legitimate interests, provided this does not harm your fundamental rights: security, fraud prevention, and service improvement

Where none of these grounds applies, we rely on your explicit consent (açık rıza) under KVKK Art. 5/1. Examples are non-essential website cookies, publishing your content to the Community, and (where offered) personalized advertising. See §6 below.

4. To whom and for what purpose data may be transferred

We may transfer your personal data to the categories of recipients listed in the Privacy Policy §4 (cloud storage, the AI provider used for Scan Chord Sheet and for automated content moderation, subscription management, crash reporting and analytics tools, advertising, email delivery, and logging), strictly for the purpose of operating the corresponding feature, and to public authorities where legally required. Several of these recipients are located outside Türkiye; see §5.

5. Transfer abroad

Where personal data is transferred outside Türkiye, we rely on the conditions set out in KVKK Art. 9. These include an adequacy decision by the Personal Data Protection Board (the "Board"), a Board-approved undertaking, or your explicit consent where no such decision or undertaking is in place. See Privacy Policy §5 for details of the international recipients involved.

6. Explicit consent (açık rıza)

Some processing activities require your separate, freely given, specific, and informed consent rather than resting on the grounds in §3:

• Publishing content to the Community: you choose, for each song or playlist or through a default preference, whether it is visible to other users. You may withdraw this consent at any time by unpublishing the content.
• Non-essential cookies on our website: our website does not currently use any non-essential cookies. The cookie notice shown on the site still records your choice, and if a non-essential cookie is added in the future it will be set only if you have given consent. See the Cookie Policy.
• Personalized advertising: where and if a consent mechanism for it is offered in the app, as opposed to the non-personalized advertising shown by default to free-plan accounts.

You may withdraw consent at any time by contacting [email protected] or, where an in-app control exists, through that control. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

7. Your rights under KVKK Article 11

Under KVKK Art. 11, you have the right to:

• Learn whether your personal data is being processed
• Request information if it has been processed
• Learn the purpose of processing and whether it is used consistently with that purpose
• Know the third parties to whom your data is transferred, domestically or abroad
• Request correction of incomplete or inaccurate data
• Request deletion or destruction of your data, subject to legally required retention (see Privacy Policy §6)
• Request that corrections, deletions, or destruction be notified to third parties your data was transferred to
• Object to a result that is against you resulting solely from automated analysis of your data (we do not currently engage in such automated decision-making; see Privacy Policy §2)
• Claim compensation for damage arising from unlawful processing

8. How to exercise your rights

Send your request to [email protected] with information sufficient to verify your identity. We will respond free of charge within 30 days as required by KVKK, or notify you if a cost applies as permitted under the Board's tariff.

9. Supervisory authority

If you believe your rights under KVKK have been violated and we have not adequately resolved your request, you may lodge a complaint with the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu, "KVKK Kurulu").