Privacy Notice on the Processing of Personal Data

This text was written in Turkish and the Turkish version governs; translations are provided for convenience. Read it in Turkish.

AIsier Investment Assistant · iOS, Android and web app · aisierinvest.com

This notice explains, under Article 10 of Turkey's Personal Data Protection Law No. 6698 ("KVKK"), who processes your personal data when you use our app and the aisierinvest.com site, for which purposes and on which legal grounds, to whom it is transferred and which rights you have. It is information only: we do not ask you to approve or accept it.

1. Data controller

The data controller for your personal data is AIsier Inc.

2. Which data we process, why, on which legal ground and for how long

We collect your data electronically, fully or partly by automated means. You enter some of it yourself (sign-up, profile, portfolio, chat), the app and our servers record some of it automatically (time zone, logs, crash reports), and some of it comes from services you use (Apple, Google, payment stores, the exchange you connect).

The legal grounds we use below are these conditions of KVKK Art. 5(2): c) it is directly related to and necessary for concluding or performing a contract (the contract is the User Agreement you accept when you open your account); ç) it is mandatory for us to fulfil a legal obligation; e) it is mandatory to establish, exercise or protect a right; f) it is mandatory for our legitimate interests, provided it does not harm your fundamental rights and freedoms.

Today none of our processing relies on explicit consent (KVKK Art. 5(1)), so we do not ask you for separate explicit consent. We explain what the AI permission in the app is at the end of this section.

1. Account and identity

2. Preferences and approximate location

3. Portfolio and in-app records

4. Analyses

5. Exchange and broker connections

6. Chat with AIsier

7. Content sent to AI

8. Screenshots, documents and voice recordings

9. Device, notifications and e-mail

10. Usage measurement

11. Crash and error reports

12. Sign-in records

13. Security and server records

14. Purchases, subscriptions and credits

15. Support, feedback and requests

16. Website and web app

17. Quality measurement

What is the AI permission for?

The "AI data sharing" permission in the app is an app setting that lets you choose whether your own data (your portfolio, your questions, the files and voice recordings you upload) is sent to AI providers. If you do not give it, or you turn off the "AI data sharing" switch in Profile, this data is not sent: personal AI features (portfolio analysis, chat, adding by screenshot and voice) turn off; your portfolio, prices and charts keep working. General content that is the same for everyone (e.g. the general analysis of an asset) contains no personal data and is still produced with AI.

Because the AI analysis is the very service you ask for, the legal ground for this processing is concluding and performing the contract (Art. 5(2)(c)). This permission is not a separate explicit consent under KVKK.

When you delete your account

You can delete your account at any time with Profile › Account › "Delete my account permanently". Your account closes at once and the data linked to it (portfolio, transactions, chat, analyses, exchange connections, device tokens, sign-in records, purchase records, feedback) is deleted from our live systems (except the 3-year record of web purchases in category 14); caches specific to you are cleared; your web subscription is cancelled at Stripe and your customer record at Stripe is deleted; if you signed in with Apple, your Apple link is revoked. You must cancel an App Store or Google Play subscription separately in the store; deleting the account does not cancel it.

Copies in database backups are deleted within 30 days at most, when the backups expire. The logs in categories 13 and 16 are deleted with the account link removed when their own periods end; the quality measurement in category 17 remains as a statistic not linked to anyone. Data already sent to service providers is deleted according to their retention periods. To show that the deletion was completed, a trace record without your name or e-mail (internal account number, the status and dates of the deletion steps) is kept; this record is deleted after 3 years.

What we do not collect and what you should keep in mind

3. To whom we transfer your data and why

We transfer your data only for the purposes in section 2 and only as far as needed, to these recipient groups:

Amazon Web Services

Anthropic

xAI

Groq

Google (Firebase)

Google (Workspace)

Apple

Google (Sign-in and Google Play)

Stripe

The exchange or broker you connect (e.g. Binance, BtcTurk, Paribu, Trading 212)

Market data providers (Yahoo Finance, CoinGecko, Twelve Data, EODHD, the European Central Bank) receive only asset symbols, and Yahoo Finance and CoinGecko also the word you search; your identity and your account are not sent.

Transfers abroad

We provide the service with infrastructure outside Turkey. From the moment you open your account your data is stored on our servers in Germany (Frankfurt) and, depending on the feature you use, transferred to the providers whose countries are listed above, mostly to the United States. These transfers are a continuous and ordinary part of the service; they are made for the purposes stated above and on the legal grounds in section 2, and are subject to Article 9 of KVKK.

4. Your rights

Under Article 11 of KVKK you have the right, by applying to us, to:

These are your rights under the law.

You can use some of them yourself right away in the app: with Profile › Account › "Download my data" you get a copy of your data (for security, your password hash, exchange keys and intermediate AI texts not shown to you are not included); you can correct your portfolio and profile in the app, change "AI data sharing" and your notification and e-mail preferences, and delete your account with "Delete my account permanently". AI analyses do not decide anything about you, they only give you information; if you still want to use your right under (g), you can apply as described below.

5. How to apply

Under the Communiqué on the Procedures and Principles of Application to the Data Controller, you can send your requests in Turkish by one of these means:

Your request must include: your name, surname and, for a written request, your signature; your Turkish ID number if you are a citizen of the Republic of Turkey, otherwise your nationality and passport number or ID number if any; your residential or business address for notifications; if any, your e-mail address, phone and fax number for notifications; and the subject of your request. You can attach related information and documents. For a request about your account we may send a verification message to the e-mail address on your account to confirm your identity; we add no other condition.

For written requests, the date the document is served on us is the application date; for other means, the date the request reaches us. We settle your request free of charge as soon as possible according to its nature and within 30 days at the latest; we accept it or refuse it with our reasons and notify you in writing or electronically. If your request is refused, you find our answer insufficient or we do not answer in time, you can complain to the Personal Data Protection Board within 30 days of learning our answer and in any case within 60 days of the application date.

6. Version, language and changes