KVKK Privacy Notice
Effective date: · Version: 2026-10
This notice is provided under article 10 of Turkey's Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform. The Turkish version is the authoritative text.
1. Data controller
LunaPCOS (Ankara, Turkey) is the data controller for personal data processed through the LunaPCOS mobile app and website.
2. Data processed and purposes
| Data category | Data | Purpose |
|---|---|---|
| Identity and contact | First and last name, email | Membership, authentication, answering support requests |
| Health (special category) | Period and cycle records, cycle regularity, symptoms, diagnoses, PCOS medication, height and weight history, daily check-ins, water intake, health goals | Cycle tracking, predictions, personalised tips |
| Customer transaction and preferences | Date of birth, notification settings, favourites, language, time zone, consent records | Providing App features, proof of consent |
| Transaction security | Session tokens, device push token, error logs | Information security, fixing errors |
3. Legal bases
- Identity, contact, customer transaction and security data: KVKK art. 5/2-(c) formation and performance of a contract, (ç) legal obligation and (f) legitimate interest.
- Health data: only on the basis of your explicit consent under KVKK art. 6/3-(a).
4. How data is collected
Data is collected electronically and by automated means, from what you enter in the App and through the sign-in provider (Clerk; and Apple or Google if you sign in with them).
5. Transfers
For the purpose of providing the service, and in line with KVKK arts. 8 and 9, data may be transferred to:
- Clerk, Inc. (USA): authentication,
- Hetzner Online GmbH (Almanya): server and database hosting,
- Sentry (Functional Software, Inc., USA): error tracking (sending personal data is turned off).
Transfers abroad are made with the appropriate safeguards set out in KVKK art. 9 (such as standard contracts notified to the Authority). Data is transferred to public authorities only when legally required.
6. Retention
Data is kept while your account is open. When you delete your account your data is taken out of use; requests for permanent erasure are completed within 30 days. See the Privacy Policy for details.
7. Your rights (KVKK art. 11)
By applying to the data controller, you have the right to:
- learn whether your personal data is processed,
- request information about it if so,
- learn the purpose of processing and whether data is used accordingly,
- know the third parties in Turkey or abroad to whom data is transferred,
- request correction of incomplete or inaccurate data,
- request erasure or destruction under KVKK art. 7,
- request that corrections and erasures be notified to third parties who received the data,
- object to a result against you arising solely from automated analysis,
- claim compensation for damage caused by unlawful processing.
Send your application to [email protected]. Applications are answered free of charge within 30 days. If your application is rejected, you find the answer insufficient, or it isn't answered in time, you may complain to the Personal Data Protection Board (KVKK Kurulu).
Explicit consent statement
I declare that I have read and understood this notice, and I give my explicit consent to the processing of my health data entered in the LunaPCOS app — period and cycle details, cycle regularity, symptoms, diagnoses, medication use, height and weight records, daily health check-ins, water intake and health goals — for cycle tracking, predictions and personalised tips, and to its transfer for this purpose to the service providers listed above, including those abroad.
I know I can withdraw my consent at any time in the App under Profile › Legal › Withdraw consent, or by writing to the data controller.