Personal Data Notice (KVKK)

This notice is provided under Article 10 of Turkey’s Law No. 6698 on the Protection of Personal Data (“KVKK”) to explain how the personal data you share through the forms on www.novabynilgun.com is processed.

1. Data controller

Your personal data is processed by NOVA by Nilgün Şahin as the data controller. Contact: contact@novabynilgun.com

2. Personal data we process

• Identity and contact details: full name, email address, phone number, city and country, preferred contact method.
• Business details: business or organization name, industry, business status, number of employees, and the services and support areas you are interested in.
• Request content: the descriptions and messages you write in the forms and, if you choose to attach it, your NOVA Check result.
• Transaction security data: the IP address and browser information recorded when a form is submitted.
• Assistant chats: messages you write to the NOVA Assistant, the name and contact details you share in the chat, and your IP address; if you send a voice message, your recording temporarily, for transcription only (it is not stored on our server), and the written transcript of live voice calls.

3. Purposes of processing

Your personal data is processed to review your application and request, contact you, plan the service you have requested, and keep our forms secure by preventing misuse.

4. Collection method and legal basis

Your data is collected electronically when you complete and submit the Free Preliminary Analysis, Consulting Request or Contact forms on our website, and when you write to the NOVA Assistant. Processing is based on Article 5(2)(c) of the KVKK, as it is directly related to establishing a contract, and on Article 5(2)(f), our legitimate interest in responding to your requests and questions and keeping our forms and chat secure, provided this does not harm your fundamental rights and freedoms. By ticking the checkbox in the forms, you confirm that you have read this notice; the chat box also links to it.

5. Storage and transfer

Form submissions are stored on a server located in Germany (Hetzner Online GmbH), in an area that is not publicly accessible, and are delivered to our business mailbox through the corporate email service (Natro, Turkey). Your data is therefore transferred abroad and to service providers acting as data processors, solely to provide the service. Your data is not sold or shared with third parties for marketing purposes. Transfers abroad are carried out in line with Article 9 of the KVKK. Your data is kept for as long as the purpose of processing requires and within the periods set by applicable law, after which it is deleted or anonymized.

NOVA Assistant chats are stored for 180 days and then deleted. Chats that become a request are kept together with the request record. Chat messages are transferred to OpenAI (USA) to generate answers and transcribe voice messages, answer texts to ElevenLabs (USA) to read them aloud, and call request notifications to NetGSM (Turkey); these transfers are also made to data processors and in accordance with Article 9 of the KVKK.

NOVA Check answers are not sent to our server. They only reach us if you choose to attach them to the Free Preliminary Analysis form and submit it.

6. Your rights under Article 11 of the KVKK

By contacting the data controller, you have the right to:

• learn whether your personal data is being processed,
• request information about the processing if it has taken place,
• learn the purpose of processing and whether the data is used accordingly,
• know the third parties in Turkey or abroad to whom the data has been transferred,
• request correction of incomplete or inaccurate data,
• request deletion or destruction of the data under the conditions set out in Article 7 of the KVKK,
• request that any correction, deletion or destruction be notified to third parties to whom the data has been transferred,
• object to an outcome against you that results from analysis of the data exclusively by automated systems,
• claim compensation for damage suffered as a result of unlawful processing.

7. How to apply

You can send requests concerning your rights to contact@novabynilgun.com, including your full name and contact details so we can verify your identity. Your request will be concluded free of charge within thirty days at the latest, depending on its nature. If your request is rejected, you find the response insufficient, or no response is given in time, you have the right to lodge a complaint with the Turkish Personal Data Protection Board.