How personal data is processed

Privacy Policy and KVKK Notice

This notice explains how we process personal data as data controller under Türkiye's Personal Data Protection Law No. 6698 (KVKK). It is not an explicit-consent form; when explicit consent is required, we request it separately.

Last updated: 2026-08-23

1. Data controller

Avus Ar-Ge Sanayi ve Ticaret LİMİTED ŞİRKETİ, Turkish tax number 1061374161. Address: Evliya Çelebi Mah., Sadi Konuralp Cad., İKSV Vakfı Blok No: 5, İç Kapı No: 2, Beyoğlu/İstanbul, Türkiye. Privacy requests: mustafa@avustr.com.

2. Data we process

Depending on how you use upub, we may process:

  • Identity and contact data, including name, e-mail, and account identifier.
  • Transactions, including package, Polar customer/order references, credits, and usage; Avus does not receive full card details.
  • User content, including uploads, conversion settings, generated EPUBs, and quality reports.
  • Security data, including IP address, user agent, sessions, consents, errors, and audit logs.
  • Usage and analytics data, including pages visited, device/browser data, and performance measurements.

3. Purposes and legal bases

We process data to create accounts, deliver and support conversions, calculate credits, handle payments and refunds, secure the service, prevent abuse, comply with law, and measure and improve performance.

Processing relies on entering into or performing a contract, legal obligations, establishing or protecting rights, and legitimate interests that do not override fundamental rights. Optional processing that legally requires explicit consent uses a separate, withdrawable choice.

4. Providers and international transfers

Limited data may be shared with infrastructure/storage providers, Google Gemini when AI processing is needed, Resend for transactional e-mail, Polar for payments and tax, Cloudflare for delivery/security, Google Analytics for measurement, advisers, and competent authorities.

Some providers may operate abroad. We use safeguards or other lawful transfer mechanisms required by KVKK Article 9. Files that do not need AI processing are not sent to the AI provider.

5. Collection and retention

Data is collected electronically through forms, uploads, account and payment integrations, cookies, and service logs.

Raw inputs are normally deleted no later than 30 days after conversion. Outputs, account, and usage records are kept while needed to provide the service; payment, security, and legal records are kept for applicable statutory periods. Data is then deleted, destroyed, or anonymized. You may request earlier deletion by e-mail.

6. Cookies and security

Essential cookies support sessions, language, and security. Analytics technologies may help us understand performance. Browser controls can limit cookies, but blocking essential cookies may prevent sign-in.

We use reasonable technical and organizational controls such as access controls, encrypted transport, user-isolated storage keys, and audit logs. No internet method can guarantee absolute security.

7. Your KVKK rights

Under KVKK Article 11, you may ask whether and how your data is processed, who receives it, request correction or deletion and notification to recipients, object to exclusively automated adverse results, and seek compensation for unlawful processing.

Send a request with enough information to verify your identity to mustafa@avustr.com or the company address. We respond under the procedures and periods required by law. Your right to complain to the Turkish Personal Data Protection Authority remains available.