This information notice is prepared in accordance with Article 10 of Turkish Personal Data Protection Law No. 6698 (KVKK) to inform you about the processing of your personal data.
1. Identity of the Data Controller
Acting as data controller in an individual capacity is Ozan Can Sisman.
- Name: Ozan Can Sisman
- Address: Suadiye Mah. İclal Karabekir Sok. Ada Apt 19/26, Kadıköy 34740, İstanbul
- Email: privacy@unclefrank.app
2. Categories of Personal Data Processed
- Identity information (name, surname)
- Contact information (email address)
- Customer transaction information (in-app actions, subscription status)
- Financial information (bank accounts, income/expense, asset and debt information)
- Transaction security information (IP address, session information, device information)
- Marketing information (in-app interaction data)
3. Purposes of Processing Personal Data
Your personal data is processed for the following purposes:
- Account creation and management
- Provision of Frank application's core services (statement analysis, expense tracking, AI advice)
- Execution of subscription processes
- Conducting customer satisfaction-oriented activities
- Conducting information security processes
- Conducting activities in compliance with legislation
- Conducting storage and archival activities
4. Recipients of Personal Data and Purposes of Transfer
Your personal data may be transferred to the following parties to the extent required by service provision:
- Domestic: Authorized public institutions and organizations (within the scope of legal obligations)
- International (EU): Supabase (Frankfurt, Germany), Vercel (Frankfurt), PostHog (EU), Adjust (EU)
- International (USA): Anthropic (AI services), Apple and Google (app store billing), RevenueCat (subscription management)
International transfers are carried out based on your explicit consent under KVKK Article 9.
5. Method of Personal Data Collection and Legal Basis
Your personal data is collected through automated means in electronic form when you begin using the Frank application. Your data is processed under KVKK Article 5 on the following legal grounds:
- Existence of your explicit consent
- Direct relevance to the establishment or performance of a contract
- Necessity for the data controller to fulfill its legal obligations
- Necessity for the legitimate interests of the data controller, provided that fundamental rights and freedoms of the data subject are not harmed
6. Your Rights Under KVKK Article 11
As a data subject, you have the following rights:
- To learn whether your personal data is being processed
- To request information if your personal data has been processed
- To learn the purpose of processing and whether the data is used appropriately
- To know the third parties domestically or internationally to whom your data is transferred
- To request correction if your personal data has been processed incompletely or incorrectly
- To request deletion or destruction of your personal data within the scope of conditions set forth in KVKK Article 7
- To request that operations carried out be communicated to third parties to whom personal data has been transferred
- To object to a result that arises against the person through analysis of processed data solely by automated systems
- To request compensation for damages incurred due to unlawful processing of personal data
7. How to Apply
To exercise your rights above, you may apply by email at privacy@unclefrank.app in accordance with the Communiqué on Procedures and Principles for Application to the Data Controller.
Your application must clearly state your identity information and the subject of your request. Applications are concluded free of charge within 30 days.