KVKK Data Protection Notice

This Notice is prepared under the Turkish Personal Data Protection Law No. 6698 (KVKK) to explain how the personal data of individuals using the Fonify service is processed in our capacity as data controller. It fulfills the disclosure obligation set out in Article 10 of the law and the related Communiqué. This text will be finalized by our legal counsel.

For further detail on how your personal data is handled, please also review our Privacy Policy, and for consent-based processing activities, our Explicit Consent text.

Your personal data is processed by DefSoft Bilişim Teknolojileri A.Ş. in its capacity as data controller. The company is headquartered in Ankara, and this address is valid for legal notices. Current data controller contact details are available through the panel and in the Contact section of this notice.

Given the nature of the service, personal data is processed in the following categories.

Identity and contact data:

• First name, last name, and title
• Email address and phone number
• Company name, industry, and tax details
• Billing and notification address

Customer transaction and service usage data:

• Call date, duration, and dialed number
• Call recording audio and text transcripts
• Call outcome, tags, and interaction summaries
• Panel login records and activity history

Transaction security data:

• IP address and session information
• Access and security logs

Your personal data is processed for the following purposes:

• Establishing and performing the service contract, answering calls, and delivering results to the panel
• Billing, collection, and financial process management
• Handling customer support requests
• Ensuring service security and preventing fraud
• Meeting legal obligations and providing proof to competent authorities
• Marketing and promotional activities where your explicit consent exists

Your personal data is processed on the following legal grounds set out in Articles 5 and 6 of the KVKK:

• Being directly related to the establishment or performance of a contract
• Being mandatory for the data controller to fulfil a legal obligation
• The legitimate interest of the data controller, provided it does not harm your fundamental rights and freedoms
• Being mandatory for the establishment, exercise, or protection of a right
• The existence of explicit consent (only for consent-based processing)

Your personal data is collected by automated and partially automated means through forms you complete electronically during registration and panel use, voice calls carried out as part of the service, email and support channels, and third-party systems you integrate.

Your personal data is shared, limited to the processing purposes and in line with Articles 8 and 9 of the KVKK:

• Suppliers we work with to deliver the service (telecom operators, cloud infrastructure, and payment providers)
• Competent public authorities upon request
• Relevant parties in structural transactions such as mergers, acquisitions, or demergers

Our cloud infrastructure providers prioritize keeping data within Türkiye and the European Union. Where transfers abroad are necessary, the conditions required by the KVKK and, where needed, your explicit consent are relied upon.

Under Article 11 of the KVKK, you have the following rights:

• To learn whether your personal data is processed
• To request information if it has been processed
• To learn the purpose of processing and whether it is used accordingly
• To know the third parties to whom data is transferred, at home or abroad
• To request correction of incomplete or inaccurately processed data
• To request erasure or destruction of data within the conditions set out in the law
• To request that correction, erasure, and destruction be notified to third parties to whom data was transferred
• To object to a result against you arising from analysis solely by automated systems
• To claim compensation if you suffer damage due to unlawful processing

You can submit requests regarding the rights above to [email protected]. Depending on the nature of the request, your application is concluded free of charge within 30 days at the latest. Where the process incurs a cost, the tariff set by the Board may apply.

For questions and requests under the KVKK, contact us at [email protected]. For written applications, our registered office address is available through the panel.