Personal Data Protection Notice (KVKK)
Last updated:
Pursuant to Article 10 of Law No. 6698 on the Protection of Personal Data (KVKK), we explain who processes your personal data when you use our website, the moducut program and our support channels, for what purposes and on what legal grounds, to whom it is transferred, and what your rights are.
1. Data controller
Your personal data is processed by moducut as the data controller. You can reach us using the following details:
This English version is provided for convenience; if there is any difference, the Turkish version prevails.
- Phone and WhatsApp: +90 540 090 06 29
- Phone: +90 541 778 52 17
- E-mail: destek@moducut.com
- Web: moducut.com
This notice applies to everyone who visits our website, fills in our forms, downloads and uses the program, purchases a license, receives support, or sends us a review or story. How information is collected in practice and where it is stored is described in detail in the Privacy Policy, and cookies in the Cookie Policy.
2. Personal data processed
Which data is processed depends on the service you use. The categories of data we may process are:
- Identity: first and last name.
- Contact: phone number, e-mail address; company or organization name and city, if any.
- Request and customer transaction information: what you write in forms and messages (quote details, appointment type, date and time, preferred call-back time, feature requests), support correspondence, your reviews and stories; account number, setup code, license and activation codes, trial and license dates.
- Visual: a photo you attach to your review.
- Transaction security: IP address, submission and connection times, the time you accepted the privacy notice and gave publication consent, and a hash generated from your computer’s hardware identifiers (machine ID).
- Program and device information: program version, operating system, computer name, hardware and software inventory, the program’s usage and error logs (including project and file names and file locations on the computer), and a copy of your program settings.
- Files requested for support: the diagnostic package and copies of your project files. These files may contain information about your own customers (e.g. name, address, dimensions).
- Remote connection sessions: information visible on your screen during the session.
- Finance: if you make a purchase, the payment method, amount and date, sender details for bank transfers, and the information required for invoicing (name or company name, address, Turkish ID number or tax number).
- Marketing: your newsletter subscription and your consent to commercial electronic messages (if given).
- Website usage information: if you allow analytics cookies, the pages you visit and similar measurement data.
We do not ask for special categories of personal data such as health information; please do not include such information in forms or in files you send us.
3. Method of collection
We collect your personal data through the following channels, by partly or fully automated means:
- Website forms: contact, quote, appointment, call-back request, download registration, customer review and story, feature request, press inquiry, “ask about your machine” and newsletter.
- Cookies and browser storage (Cookie Policy).
- The moducut program: information it sends to our license server while connected to the internet, and the in-app contact form.
- WhatsApp, phone and e-mail correspondence, and remote connection (screen sharing) sessions.
- Information we receive from you during sale and payment.
4. Purposes and legal grounds
We process your data for the following purposes, based on the legal grounds in Article 5 of the KVKK:
| Activity | Purpose | Legal ground |
|---|---|---|
| Forms, WhatsApp, phone and e-mail | Responding to your request; preparing a quote; scheduling a demo, setup or training session | Establishment or performance of a contract (Art. 5/2-c); our legitimate interest in responding to your request (Art. 5/2-f) |
| Download registration and trial | Creating a personal setup file and account; limiting the trial to one computer and preventing abuse | Establishment or performance of a contract (Art. 5/2-c); legitimate interest (Art. 5/2-f) |
| License sale and activation | Selling, invoicing and binding the license to a computer; checking its term and validity | Establishment or performance of a contract (Art. 5/2-c); expressly provided for by law and legal obligation (Art. 5/2-a and ç) |
| Program usage logs, inventory and settings copy | Finding and fixing errors, providing support, improving the program, preventing license abuse | Performance of a contract (Art. 5/2-c); legitimate interest (Art. 5/2-f) |
| Support: diagnostic package, project copy, remote connection, in-app messages | Investigating and solving the problem you report; providing setup and training | Performance of a contract (Art. 5/2-c); legitimate interest (Art. 5/2-f) |
| Customer reviews and stories | Evaluating your submission; with your permission, publishing it with your name, company and photo on our website and social media accounts | Legitimate interest for evaluation (Art. 5/2-f); your explicit consent for publication (Art. 5/1) |
| Feature requests and votes | Evaluating requests; preventing repeated votes from the same address | Legitimate interest (Art. 5/2-f) |
| Newsletter and campaign messages | Announcing new features and campaigns | Your explicit consent (Art. 5/1) and your approval under Law No. 6563 |
| Analytics cookies | Measuring and improving how the website is used | Your explicit consent (Art. 5/1) |
| Security | Preventing spam and abuse (e.g. limiting many submissions from the same address in a short time), ensuring information security | Legitimate interest (Art. 5/2-f) |
| Legal proceedings | Responding to requests from competent authorities; exercising and protecting our rights in disputes | Legal obligation (Art. 5/2-ç); establishment, exercise or protection of a right (Art. 5/2-e) |
Processing based on explicit consent (publication permission, newsletter, analytics cookies) is optional; not giving consent does not affect your use of our other services.
5. Who we transfer data to
We may transfer your personal data to the following groups of recipients only to the extent necessary for the purposes above and subject to the conditions in Articles 8 and 9 of the KVKK:
- Hosting and server providers we use: to operate the website, database and license server.
- Google: only if you allow analytics cookies, to measure website usage with Google Analytics.
- Microsoft: only if you allow analytics cookies, to anonymously measure on-page interactions (clicks, scrolling, mouse movement) with Microsoft Clarity.
- WhatsApp (Meta): if you message us on WhatsApp; the correspondence runs on this infrastructure.
- The provider of the remote connection program: when a screen sharing session is set up.
- Banks and payment institutions: to collect and refund payments.
- Financial advisers and legal counsel we work with: for invoicing and accounting obligations and legal disputes.
- Competent public authorities, courts and enforcement offices: as required by our legal obligations and upon their request.
- The public: reviews and stories you allow us to publish are publicly available on our website and social media accounts.
6. Transfers abroad
Some service providers’ servers may be located abroad: Google Analytics and Microsoft Clarity (only if you give permission), WhatsApp, the remote connection program and social media platforms. If our hosting provider’s servers are abroad, the data on the website and license server is also covered.
These transfers are made in accordance with Article 9 of the KVKK: they rely on an adequacy decision of the Personal Data Protection Board for the destination country if one exists, and otherwise on one of the appropriate safeguards listed in the Law (e.g. standard contractual clauses). For incidental transfers where none of these exist, the other conditions listed in the Law apply, such as your explicit consent.
7. Retention period
We keep your data for as long as necessary for the purpose for which it is processed and for the periods required by applicable legislation, for example the periods in the Turkish Commercial Code and the Tax Procedure Law for sales and invoice records. When the reason for retention ceases, we delete, destroy or anonymize the data.
If you withdraw your explicit consent (e.g. publication permission for your review), we stop processing the relevant data for that purpose and remove it from publication. Details are in the Privacy Policy.
8. Your rights
Under Article 11 of the KVKK, by applying to us you may:
- Learn whether your personal data is being processed,
- Request information about it if it has been processed,
- Learn the purpose of processing and whether the data is used in line with that purpose,
- Know the third parties in Turkey or abroad to whom it has been transferred,
- Request correction if it has been processed incompletely or incorrectly,
- Request its deletion or destruction under the conditions in Article 7 of the KVKK,
- Request that correction, deletion and destruction be notified to the third parties to whom the data has been transferred,
- Object to a result against you arising from analysis exclusively by automated systems,
- Claim compensation if you suffer damage due to unlawful processing.
You can withdraw your consent for processing based on explicit consent at any time; withdrawal does not affect processing carried out before that date. You can stop commercial electronic messages free of charge using the opt-out option in each message or by writing to us.
9. How to apply
You can submit your application regarding your rights in English, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, through one of the following channels:
- By e-mail: signed with a secure electronic signature or mobile signature, or sent from an e-mail address you previously provided to us and that is in our records, to destek@moducut.com.
Your application must include your first and last name, your signature for written applications, your Turkish ID number (if you are a foreign national, your nationality and passport or ID number), your residential or business address for notifications, your e-mail address for notifications if any, your phone number, and the subject of your request. For applications about the program or license, including your account number (HSP-…) speeds up the process.
We conclude your application within 30 days at the latest and, as a rule, free of charge; if the process requires an additional cost, a fee may be charged according to the schedule set by the Personal Data Protection Board. If your application is rejected, you find the response insufficient, or no response is given in time, you may file a complaint with the Board within 30 days of learning of the response and in any case within 60 days of the application date.
10. Changes
We update this notice as our services or the legislation change; the current version and its date are shown on this page.
