Turkey Data Processing
Notice (KVKK)
This notice is issued pursuant to Article 10 of Turkish Law No. 6698 on the Protection of Personal Data (KVKK). It explains how Quantum Intelligence Hub Ltd processes personal data of data subjects resident in Turkey, the legal bases for such processing, the rights of data subjects and how those rights may be exercised.
Pursuant to Article 10 of Turkish Law No. 6698 on the Protection of Personal Data (KVKK), Quantum Intelligence Hub Ltd is obliged, as data controller, to inform data subjects resident in Turkey about the processing of their personal data. This notice fulfils that obligation. The Turkish-language version of this notice is also available at qihhub.com/turkiye-veri-isleme-bildirimi.
Identity & Contact Details of the Data Controller
Pursuant to Article 3 of KVKK, the data controller is the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.
- Data Controller: Quantum Intelligence Hub Ltd
- Company Number: 17246860 (registered in England and Wales)
- Registered Office: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
- KVKK Contact Email: legal@qihhub.com
- Data Protection Email: compliance@qihhub.com
- Phone — UK: +44 7447 237982
- Phone — NL: +31 638582434
- Website: www.qihhub.com
Quantum Intelligence Hub Ltd is a foreign company registered in England that provides services to Turkey on a cross-border basis. QIH does not maintain a physical office or branch in Turkey. Our legal advisors are assessing obligations under the KVKK Data Controllers’ Registry (VERBİS) registration requirement for foreign data controllers targeting Turkey.
Categories of Personal Data Processed
QIH may process the following categories of personal data relating to users and clients resident in Turkey:
| Data Category | Data Types | Processing Purpose |
|---|---|---|
| Identity Data | Name, surname, username | Account creation, identity verification |
| Contact Data | Email address, phone number, postal address | Service delivery, customer communications |
| Financial Data | Invoice details, payment records (excluding card data) | Billing, accounting, financial obligations |
| Technical Data | IP address, browser information, cookie data | Security, platform optimisation |
| Usage Data | Platform interactions, preferences, history | Service improvement, personalisation |
| Communication Content | Email correspondence, support tickets | Customer services, dispute resolution |
| Education Data | Course progress, exam results, certificate records | Delivery of education services |
QIH does not process special categories of personal data as defined under KVKK Article 6, including data relating to race, ethnic origin, political opinion, philosophical belief, religion, health, sexual life or biometric data. In exceptional circumstances where such data must be processed, explicit consent will be obtained from the data subject.
Purposes of Processing Personal Data
QIH processes personal data of Turkey-resident data subjects for the following purposes:
- Delivering contracted services accurately and completely
- Creating, managing and securing customer accounts
- Fulfilling billing, accounting and financial obligations
- Handling customer requests, complaints and support enquiries
- Ensuring platform security, integrity and cybersecurity
- Complying with legal obligations, regulatory requirements and court orders
- Service development, analytics and marketing activities subject to explicit consent
- Anti-money laundering and sanctions screening obligations
- Tracking progress and managing certification in education services
Legal Bases for Processing Personal Data
Pursuant to Articles 5 and 6 of KVKK, personal data may only be processed where one of the legal bases prescribed by law exists. QIH relies on the following legal bases:
- Establishment or Performance of a Contract (KVKK Art.5/2-c): Data necessary for the formation and performance of the service agreement is processed under this basis
- Fulfilment of a Legal Obligation (KVKK Art.5/2-ç): Tax, accounting, AML and statutory reporting obligations fall within this basis
- Legitimate Interest (KVKK Art.5/2-f): Processing for platform security, fraud prevention and service quality improvement where it does not prejudice fundamental rights
- Explicit Consent (KVKK Art.5/1): Marketing communications, cookie analytics and optional personalisation services require explicit consent
- Establishment, Exercise or Protection of a Right (KVKK Art.5/2-e): Processing for the purpose of establishing evidence and protecting rights in legal disputes
Transfer of Personal Data
QIH may transfer personal data of Turkey-resident data subjects to third parties under the following conditions:
- Service Providers: Only data necessary for service delivery is transferred to third-party providers offering hosting, payment processing, email and analytics services
- Competent Authorities: Requests from Turkish judicial authorities or regulatory bodies are fulfilled where legally required
- Certification Bodies: Relevant data is transferred to certification bodies such as EC-Council in the context of education services
- Payment Providers: Transaction data is transferred to payment platforms such as Stripe, PayPal or Wise
International Data Transfers:
Your personal data is transferred outside Turkey, in particular to the United Kingdom and the Netherlands. These transfers are carried out under the following safeguards pursuant to Article 9 of KVKK:
- The United Kingdom is assessed as providing adequate protection under the relevant Board decisions; standard contractual clauses are applied as required
- Data processing agreements (DPA) concluded with third-party data processors cover KVKK and UK GDPR safeguards
- Transfers to countries not providing adequate protection are carried out only on the basis of explicit consent or a mandatory legal requirement
Retention Periods for Personal Data
QIH retains personal data only for the period required by the processing purpose and applicable statutory retention obligations.
| Data Category | Retention Period | Legal Basis |
|---|---|---|
| Contract & Invoice Data | 10 years | Turkish Commercial Code / UK accounting legislation |
| Customer Account Data | While account is active + 3 years | Contract performance and legitimate interest |
| Technical Log Data | 12 months | Security and system management |
| AML / KYC Data | 5 years after relationship ends | Anti-money laundering legislation |
| Marketing Data | Until consent is withdrawn | Explicit consent |
| Education & Certificate Data | Duration of service + 5 years | Certification requirements |
Personal data whose retention period has expired is deleted, anonymised or destroyed in accordance with secure erasure procedures.
Rights of Data Subjects Under KVKK
Pursuant to Article 11 of KVKK, data subjects resident in Turkey have the following rights:
The right to learn whether your personal data is being processed and, if so, which data is being processed (KVKK Art.11/1-a).
The right to learn the purpose of processing your personal data and whether it is being used in accordance with that purpose (KVKK Art.11/1-b).
The right to know the third parties to whom your personal data has been transferred, whether domestically or abroad (KVKK Art.11/1-c).
The right to request the correction of incomplete or inaccurately processed personal data (KVKK Art.11/1-d).
The right to request deletion or destruction of personal data where the reasons requiring processing have ceased to exist (KVKK Art.11/1-e).
The right to request that rectification or deletion be notified to third parties to whom the data has been transferred (KVKK Art.11/1-f).
The right to object to a result arising against you through exclusively automated analysis of your processed data (KVKK Art.11/1-g).
The right to claim compensation for damages suffered as a result of unlawful processing of your personal data (KVKK Art.11/1-ğ).
How to Exercise Your Rights — Application Procedure
To exercise your rights under Article 11 of KVKK, you may contact QIH through one of the following channels:
- By Email: Send an email to legal@qihhub.com with the subject line “KVKK Data Subject Request”
- By Post: Send a signed written application to 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Your application must include the following information:
- Full name and signature (for written applications)
- For Turkish Republic citizens: T.R. identity number; for foreign nationals: passport number or identity document details
- Residential or business address for correspondence, or an electronic mail address for notifications
- Subject of the request: which right you wish to exercise and any additional explanations
Applications are concluded free of charge within a maximum of 30 days depending on the nature of the request. Where a request is refused, found inadequate or not responded to within the time limit, you retain the right to lodge a complaint with the Personal Data Protection Authority (KVKK Board).
Security of Personal Data
QIH implements the following technical and administrative measures to ensure the security of personal data in accordance with Article 12 of KVKK:
- Personal data is protected by TLS/SSL encryption during transit and at rest
- System access is restricted through role-based authorisation and multi-factor authentication
- Access logs are regularly audited and unauthorised access attempts are monitored
- Employees and consultants processing personal data are bound by confidentiality obligations
- Data breach detection procedures are in place; in the event of a breach, data subjects and competent authorities are notified within the statutory timeframe
- Periodic penetration testing and security audits are conducted
Cookies and Automated Processing
QIH websites use essential cookies, analytics cookies and marketing cookies. For users resident in Turkey:
- Essential cookies are necessary for the functioning of the service; disabling them may adversely affect your use of the service
- Your explicit consent is obtained for analytics and marketing cookies; you may decline these
- You may change your cookie preferences at any time through your browser settings or our cookie management panel
- Where profiling or automated decision-making processes are used, this is stated separately on the relevant service page
Marketing Communications & Consent Management
QIH obtains explicit consent to send commercial electronic messages to users resident in Turkey in accordance with Turkish Law No. 6563 on the Regulation of Electronic Commerce and KVKK.
- Your consent to receive commercial electronic messages may be withdrawn at any time
- To withdraw consent, use the “unsubscribe” link in emails or notify us at compliance@qihhub.com
- Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal
- Consent withdrawal requests are processed within a maximum of 3 business days
Right to Lodge a Complaint with the KVKK Board
Where your application to QIH is refused, found inadequate or not responded to within 30 days, you have the right to lodge a complaint with the Personal Data Protection Authority (KVKK Board).
- Board Website: www.kvkk.gov.tr
- Online Application: Complaints may be submitted online through the Board’s official website
- Postal Address: Kişisel Verileri Koruma Kurumu, Nasuh Akar Mah. Ziyabey Cad. No:1272 06520 Balgat / Ankara, Turkey
- Telephone: +90 (312) 216 50 50
Notice Updates
QIH reserves the right to update this notice in line with changes to KVKK legislation, Personal Data Protection Board decisions or developments in service operations. The current version is always available at qihhub.com/turkey-data-processing-notice.
Material changes will be communicated by email notification or platform announcement. Continued use of QIH services following the publication of an updated notice constitutes acknowledgement of the revised terms.
This notice has been prepared in accordance with the laws of England and Wales and the provisions of Turkish Law No. 6698 (KVKK). The Turkish-language version of this notice prevails in the event of any inconsistency in interpretation.
Contact
For questions and requests relating to this notice:
- KVKK Applications: legal@qihhub.com (Subject: KVKK Data Subject Request)
- Data Protection: compliance@qihhub.com
- General Support: support@qihhub.com
- UK Headquarters: +44 7447 237982
- NL Operations: +31 638582434
- Registered Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom