Privacy Policy & KVKK Disclosure

At FinPusula, we care about the security of your personal data. This text explains how your data is processed under Türkiye's Law No. 6698 on the Protection of Personal Data ("KVKK").

1. Data Controller

Data Controller: Metehan Demircioğlu

Address: Mürsel Uluç Mah. 942. Cadde 40/6 Çankaya/Ankara

E-mail: info@finpusula.com

2. Personal Data Processed

• Identity and contact: name, e-mail address (for account creation and sign-in).
• User content (financial data): data you enter yourself, such as income, expenses, credit card, installment, loan, savings and goal information.
• Payment transaction data: the status and amount of a subscription transaction. Payment instrument details such as card numbers are never seen or stored by us; they are processed directly by the Merchant of Record, Paddle.
• Usage/analytics data: anonymized usage statistics collected to improve the app.

3. Purposes of Processing

• Providing the service, creating and managing your account.
• Secure cross-device synchronization and backup of your data.
• Carrying out premium subscription and payment transactions.
• Generating AI-powered financial analysis and suggestions upon your request.
• Improving the service, ensuring security and fulfilling legal obligations.

4. Legal Grounds

Your data is processed based on grounds set out in Articles 5 and 6 of the KVKK, such as the establishment/performance of a contract, the establishment and exercise of a right, the fulfilment of legal obligations, and your explicit consent (e.g. for cross-border transfers and analytics).

5. Transfer of Data

To provide the service, your data may be processed through the infrastructure of the service providers below. As some of these providers are located abroad, such transfers rely on your explicit consent and/or appropriate safeguards under Article 9 of the KVKK:

• Supabase — hosting of account and sync data (database, authentication).
• Paddle (Paddle.com Market Limited) — payment, billing and sales-tax processing (Merchant of Record).
• OpenAI — only when you use AI features, the analysis of the relevant financial summary or document content.
• PostHog (EU) — anonymized usage analytics.

Except for legal obligations, your data is not shared with or sold to third parties for marketing purposes.

6. Retention Period

Your personal data is retained for as long as your account is active and for the periods required by applicable legislation. When you delete your account, your data is deleted or anonymized, subject to any legal retention obligations.

7. Your Rights Under the KVKK

Under Article 11 of the KVKK you have the right to learn whether your personal data is processed, to request information, to learn the purpose of processing, to request correction if processed incompletely/incorrectly, to request deletion or destruction, to object to processing, and to claim compensation if you suffer damage.

8. Cookies

Cookies required for the operation of the service and for anonymous usage measurement may be used on the website. Your browser's "Do Not Track" preference is respected.

9. Applications

You can send requests regarding your rights to info@finpusula.com. Your requests will be concluded as soon as possible and within 30 days at the latest.