1. Data controller

Under Turkish Personal Data Protection Law no. 6698 ("KVKK"), your personal data is processed as data controller within the scope described below.

Data controller: Yiğitcan Kiremitci (sole proprietorship), Küçükbakkalköy Mah. Dereboyu Cad. R5 Blok No: 3A, Interior Door No: 48, Ataşehir/İstanbul, Türkiye. Contact: info@projelio.app

VERBIS: data controllers with fewer than 50 employees and an annual balance sheet total below TRY 25 million, whose principal activity is not the processing of special categories of personal data, are not required to register with the Data Controllers' Registry; our business falls within that exemption.

For the content your organisation creates inside Projelio, your organisation is the controller and we act as a processor.

2. Categories of data

Identity: first and last name. Contact: email, phone, address. Customer transactions: subscription, order, invoice and payment records. Transaction security: IP address, sign-in attempts, session and log records, device information. Professional details: title, department, organisation.

We also process the content you create inside the Service (jobs, projects, tasks, module records, files, comments) and the content of the messages you send to the Lio assistant and over WhatsApp.

We do not seek to collect special categories of personal data and recommend that you do not enter such data into free-text fields.

3. Purposes

Providing the service and performing the contract, managing your account and permissions, keeping invoicing and accounting records, ensuring information security and preventing abuse, handling requests and complaints, meeting legal obligations, and marketing activity where explicit consent exists.

4. Legal grounds

KVKK art. 5/2-c (conclusion or performance of a contract), 5/2-ç (legal obligation), 5/2-e (establishment and protection of rights), 5/2-f (legitimate interest) and, where required, art. 5/1 (explicit consent).

5. Transfers, including abroad

The application server, the database and the files you upload are located in Türkiye. Backups are kept in Türkiye as well.

Your personal data may be transferred, limited to the purpose, to suppliers providing hosting, email, notification and support services, to authorised public bodies, and to relevant parties where legislation requires.

Transfers abroad are limited to: the AI assistant (United States; the People's Republic of China if a fallback supplier is in use), email delivery (USA), your browser's push notification infrastructure, the web font service, and the third-party services you connect yourself. Such transfers are made under KVKK art. 9 with a standard contract or another safeguard the legislation provides.

The full list of suppliers and what each can access is in the "Who we share information with" and "Where your data is kept" sections of the Privacy Policy.

6. Collection method

Data is collected partly by automated means through website and application forms, signing in with Google or Microsoft, email, support channels, conversations over WhatsApp, and automatic system records.

7. Retention

Data is kept for as long as the purpose requires and for the minimum periods the law prescribes; data whose period has expired is deleted or anonymised.

The main periods: a 30-day waiting period after a deletion request followed by permanent deletion, Lio chat history 90 days, WhatsApp conversation records 90 days, technical and security logs at most 12 months, billing records 10 years as required by law. The full list is in the "Retention" section of the Privacy Policy.

8. Your rights and how to apply

Under KVKK art. 11 you may learn whether your data is processed, request information, learn whether it is used for its purpose, request correction or deletion, learn the third parties it was transferred to, request that these actions be notified to those third parties, object to results arising solely from automated analysis, and claim compensation for damage caused by unlawful processing.

You can handle most requests yourself inside the application: update your profile, export your data as an Excel file, and request deletion of your account.

Send applications to info@projelio.app; we may ask for additional information to verify your identity. Requests are concluded free of charge within 30 days at the latest. If you are not satisfied with the outcome you may complain to the Turkish Personal Data Protection Authority.

Privacy Notice (KVKK)