KVKK Privacy Notice

DRAFT — pending legal review. The Turkish text is binding.

Version: kvkk-2026-11-05

1. Data controller

Lamma LLC ("Vagora"). Contact: hello@vagora.net

2. Personal data we process

Waitlist: email address, language, platform choice (iOS / Android / both), privacy notice version and marketing consent, hashed IP address, browser information (user agent), submission time.

Brand application: company legal name, brand name, website, Instagram handle, contact person's name, role, email and phone, store information in Turkey (count, cities, categories, catalog size), message, plus the technical data above.

3. Purposes

• Notify waitlist members when the app launches.
• Keep the double opt-in confirmation and its proof.
• Review brand applications and contact the applicant.
• Prevent abuse and spam (IP hash, rate limiting).

4. Legal basis

• Waitlist and application: KVKK Art. 5/2-c (steps before entering a contract) and Art. 5/2-f (legitimate interest).
• Commercial electronic messages: explicit consent (Law No. 6563); optional and withdrawable at any time.

5. Recipients (including abroad)

Cross-border transfer follows KVKK Art. 9. The safeguard mechanism (explicit consent or undertaking) will be settled in legal review.

6. Retention

• Unconfirmed waitlist entries: 7 days.
• Confirmed entries: until you unsubscribe, or until 12 months after launch.
• Rejected brand applications: 6 months.

7. Your rights (KVKK Art. 11)

You may learn whether your data is processed, request information, learn whether it is used for its purpose, know who receives it, request correction, deletion or destruction, ask that these actions be notified to recipients, object to automated analysis results, and claim compensation for damage.

8. How to apply

Write to hello@vagora.net. You can also leave the waitlist with the link at the bottom of every email.