KVKK Privacy Notice (Türkiye)

CLOVERA KVKK PRIVACY NOTICE (TÜRKİYE)
Last updated: July 8, 2026
Contact: kitteniverseclovera@gmail.com

This notice is provided in accordance with Article 10 of Turkish Law No. 6698 on the Protection of Personal Data ("KVKK") and the Communiqué on the Procedures and Principles for Compliance with the Obligation to Inform. In case of any discrepancy between this English version and the Turkish version, the Turkish version prevails for users subject to Turkish law.

1. Data Controller
Clovera is an independent project run under the name "Kitteniverse Studios"; Kitteniverse Studios is not currently a registered company. For the purposes of the KVKK, the data controller is therefore the natural person operating the project, who can be reached at kitteniverseclovera@gmail.com. If the project is later registered as a company, this notice will be updated to show the registered name and contact details.

2. Personal Data Processed
Clovera may process the following categories of personal data:
(a) account data: username, email address, and profile details;
(b) technical data: IP address (only a one-way SHA-256 digest is stored), device identifiers, browser type, operating system, and approximate location derived from IP;
(c) usage data: login times, interactions, reports, blocks, community participation, and feature usage;
(d) content data: messages, posts, attachments, profile text, and other user-submitted content;
(e) safety and moderation data: report records, enforcement history, detection signals, and abuse-prevention logs.

3. Purposes of Processing
Personal data is processed to:
(a) create and manage accounts;
(b) provide messaging, community, feed, moderation, and support functions;
(c) protect users and the service from spam, fraud, abuse, illegal activity, and security threats;
(d) enforce platform rules and legal obligations;
(e) improve reliability, performance, and user experience;
(f) communicate service notices, policy updates, and support responses.

4. Legal Grounds (KVKK Article 5)
Personal data is processed on the following legal grounds set out in Article 5 of the KVKK:
(a) processing being directly related to the establishment or performance of a contract (Art. 5/2-c) — account and service functions;
(b) processing being necessary for the controller to comply with a legal obligation (Art. 5/2-ç);
(c) processing being necessary for the legitimate interests of the controller, provided it does not harm the fundamental rights and freedoms of the data subject (Art. 5/2-f) — security, fraud prevention, moderation, and service improvement;
(d) explicit consent (Art. 5/1) — where required, for the cross-border transfers and optional features described below.

5. Method of Collection
Personal data is collected electronically, by automated and partly automated means, through registration forms, in-app interactions, messaging and content submission, automated logs, and security systems.

6. KittenAI Features and Transfer to Google (Cross-Border Data Transfer)
Clovera's built-in artificial intelligence features ("KittenAI") — conversation summaries, message translation, Live Translation, reply suggestions, Catch-Up digests, the KittenAI chat assistant, writing assistance, and automated content moderation — are powered by Google's Gemini models, accessed through the Google Gemini API. Google acts as a data processor on Clovera's behalf for these features.

When a KittenAI feature runs, the relevant content is decrypted on Clovera's servers and transmitted to Google for processing. Depending on the feature, this content may include:
(a) the text of direct messages, group messages, and channel messages (for summaries, translation, Live Translation, reply suggestions, and Catch-Up);
(b) posts, blog drafts, usernames, profile text, and messages sent to the KittenAI chat assistant;
(c) images such as profile photos, banners, and post attachments (for automated image moderation).

When each feature runs:
(a) User-initiated features (summarize, translate, reply suggestion, community idea, Catch-Up, writing assistance, and the KittenAI chat) run only when the user actively requests them.
(b) Live Translation runs only if the user has turned it on in settings, and can be turned off at any time.
(c) Automated content moderation runs automatically on public posts, usernames, profile images, post images, and — where a community has enabled moderation — community messages, in order to protect users and comply with legal obligations.

Important: content you send to other users may be processed by KittenAI if another participant in the conversation uses an AI feature on that conversation (for example, translation, summarization, or Catch-Up), or if the content is subject to automated safety moderation.

Google may process this content on servers located outside the user's country, including outside Türkiye. This constitutes a cross-border transfer of personal data within the meaning of Article 9 of the KVKK. Such transfers are carried out in accordance with the conditions of Article 9, relying on appropriate safeguards and/or — where required — your explicit consent, which you give by activating or using the relevant KittenAI feature. Users who do not use KittenAI features and have not enabled Live Translation do not have their private message content sent to Google, except where automated safety moderation applies as described above.

Content transmitted to Google is processed subject to Google's applicable API and data processing terms. Clovera does not permit its processors to use this content for their own advertising purposes. Translation results are cached in encrypted form on Clovera's servers to reduce repeat processing.

7. Other Transfers
Personal data may also be shared with service providers acting on Clovera's behalf (such as hosting, security, email, and infrastructure providers), with competent authorities where necessary to investigate abuse, enforce rules, or respond to lawful requests, and in connection with legal claims. Clovera does not sell personal data.

8. Retention
Personal data is retained for as long as reasonably necessary for the purposes described in this notice and in the Privacy Policy. Login records and session tokens are removed upon account deletion. Different categories of data may be kept for different periods depending on risk and legal need.

9. Automated Decision-Making
Automated moderation may result in content being blocked or restricted without prior human review. You may contest a moderation decision and request human review by contacting kitteniverseclovera@gmail.com.

10. Your Rights under KVKK Article 11
Under Article 11 of the KVKK, by applying to the data controller you have the right to:
(a) learn whether your personal data is processed;
(b) request information if it has been processed;
(c) learn the purpose of processing and whether the data is used in accordance with that purpose;
(ç) know the third parties to whom your data is transferred, in Türkiye or abroad;
(d) request correction of incomplete or inaccurate data;
(e) request deletion or destruction of your data under the conditions of Article 7 of the KVKK;
(f) request that the operations under (d) and (e) be notified to third parties to whom the data has been transferred;
(g) object to a result arising against you through analysis carried out exclusively by automated systems;
(ğ) claim compensation for damages arising from unlawful processing.

11. How to Apply
Requests regarding the rights above may be sent to kitteniverseclovera@gmail.com in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. Clovera may need to verify identity before completing certain requests. Applications are concluded within thirty days at the latest, as required by Article 13 of the KVKK.

12. Right to Complain
If your application is rejected, the response is found insufficient, or no response is given in time, you retain the right to lodge a complaint with the Turkish Personal Data Protection Board (Kişisel Verileri Koruma Kurulu) under Article 14 of the KVKK.

13. Withdrawal of Consent and Feature Controls
For user-initiated KittenAI features, you can stop the processing at any time by not using them; for Live Translation, by turning it off in settings. Withdrawing your explicit consent does not affect the lawfulness of processing carried out before the withdrawal.