As FİNEVER BİLİŞİM TEKNOLOJİLERİ ANONİM ŞİRKETİ (the "Company"), we process the personal data of people who use the Everagent platform (the "Platform") in accordance with Law No. 6698 on the Protection of Personal Data ("KVKK") and related legislation. This notice has been prepared to fulfil our duty to inform under Article 10 of KVKK.
1Data Controller
- Legal name: FİNEVER BİLİŞİM TEKNOLOJİLERİ ANONİM ŞİRKETİ
- Registered address: Akfırat Mah. Fatih Sultan Mehmet Blv. No: 3 İç Kapı No: 65, 34959 Tuzla/Istanbul, Türkiye
- Trade registry: Istanbul Trade Registry Office, no. 475369-5
- MERSIS No: 0388190287500001
- KEP (registered electronic mail): fineverbilisim@hs01.kep.tr
- Email for KVKK applications: support@everagent.app
- Phone: +90 850 242 62 50
2Categories of Personal Data Processed
- Identity Data: First name, last name; Turkish national identity number where provided for individual invoicing.
- Contact Data: Email address, telephone number where provided, address.
- Financial Data: Billing name, tax office and tax number, billing address, billing email, subscription and purchase history, payment amounts
- Customer Transaction Data: Actions on the Platform and the related audit records (who did what, and when), workflow execution metadata, Credit consumption, user account name, passwords, your support requests and the related correspondence
- Legal Transaction Data: Information in correspondence with judicial authorities, information in case files, signature circulars, powers of attorney
- Transaction Security Data: IP address, browser and device information, sign-in records, security event records and bot-protection signals, the version of agreements and texts, the date and time of acceptance
3Purposes and Legal Grounds of Processing Your Personal Data
Processing expressly provided for by law (KVKK Art. 5/2-a)
Category of Personal Data: Identity, Contact, Legal Transaction, Transaction Security, Financial Data
Purpose of Processing:
- Complying with legal and administrative measures and conducting activities in accordance with the legislation
- Preparing the information and documents on which the business and transactions to be carried out are based.
- Complying with the obligations to retain, report and provide information imposed by all competent judicial and administrative authorities under the relevant legislation, and fulfilling the requests or decisions of those authorities.
- Notifying those same authorities in order to investigate, detect and prevent breaches of contract and of the law.
- Verifying the identity of corporate customers and of the persons authorized to represent them, and setting up the organization.
- Carrying out retention and archiving activities.
- Following up requests and complaints, and resolving customer disputes, as part of customer support services.
- Carrying out communication activities.
- Carrying out finance and accounting processes.
Processing necessary for the establishment or performance of a contract, provided that it directly relates to it, of the personal data of the parties to that contract (KVKK Art. 5/2-c)
Category of Personal Data: Identity, Contact, Legal Transaction, Transaction Security,
Purpose of Processing:
- Establishing the contract,
- Carrying out transactions in customer accounts, and preparing the information and documents on which the business and transactions to be carried out are based.
- Protecting accounts and archives, and preventing unauthorized access to accounts.
- Carrying out contract processes.
- Carrying out communication activities.
- Following up requests and complaints, and resolving customer disputes, as part of customer support services.
- Carrying out retention and archiving activities.
- Carrying out operational processes.
- Verifying the identity of corporate customers and of the persons authorized to represent them, and setting up the organization.
Category of Personal Data: Financial Data
Purpose of Processing:
- Establishing the contract, carrying out account opening procedures.
- Confirming the customer's identity,
- Determining and upgrading the plans used.
- Preparing the information and documents on which the business and transactions to be carried out are based.
- Carrying out contract processes.
- Carrying out finance and accounting processes.
- Following up requests and complaints, and resolving customer disputes, as part of customer support services.
Processing necessary for the data controller to fulfil its legal obligation (KVKK Art. 5/2-ç)
Category of Personal Data: Identity, Contact, Legal Transaction, Transaction Security, Financial Data
Purpose of Processing:
- Complying with legal and administrative measures and conducting activities in accordance with the legislation.
- Preparing the information and documents on which the business and transactions to be carried out are based.
- Complying with the obligations to retain, report and provide information imposed by all competent judicial and administrative authorities under the relevant legislation, and fulfilling the requests or decisions of those authorities.
- Notifying those same authorities in order to investigate, detect and prevent breaches of contract and of the law.
- Carrying out retention and archiving activities.
- Following up requests and complaints, and resolving customer disputes, as part of customer support services.
- Following up and conducting legal and litigation matters, following up and conducting mediation matters, following up and conducting enforcement matters.
- Carrying out communication activities.
- Carrying out operational processes.
- Carrying out finance and accounting processes.
Processing necessary for the legitimate interests of the data controller (KVKK Art. 5/2-f)
Category of Personal Data: Identity and Contact Data
Purpose of Processing:
- Keeping customer satisfaction at the highest level by measuring the performance of our systems.
- Planning commercial and business strategies.
- Ensuring the security of our website and our other online applications and products.
- Following up requests/complaints.
- Following up requests and complaints, and resolving customer disputes, as part of customer support services.
Category of Personal Data: Customer Transaction Data
Purpose of Processing:
- Keeping customer satisfaction at the highest level by measuring the performance of our systems.
- Planning commercial and business strategies.
- Ensuring the security of our website and online applications and products.
- Following up requests and complaints, and resolving customer disputes, as part of customer support services.
Category of Personal Data: Transaction Security
Purpose of Processing:
- Ensuring the security of our website and our other online applications and products.
- Ensuring customer account security and system security.
- Ensuring that our systems, the services we offer and the interface are accessible to users on all platforms,
4Method of Collection
Your personal data is obtained and processed electronically, by fully or partly automated means and in line with the principles of the Law: through sign-up, profile and billing forms; from the information your organization admin enters when inviting you; while you use the Platform (server logs, cookies and local storage); and through support correspondence.
5Transfers
Under Articles 8 and 9 of the Law, we may transfer the personal data we process to third parties.
- Your Identity, Contact, Transaction Security, Financial, Legal Transaction and Customer Transaction Data, on the legal grounds that the processing is expressly provided for by law (KVKK Art. 5/2-a) and is necessary for the data controller to fulfil its legal obligation (KVKK Art. 5/2-ç),
are transferred, for the purposes of informing authorized persons, institutions and organizations, following up and conducting legal matters and fulfilling our legal obligations, to the persons, institutions and/or organizations to which the Law and other legislation require or permit a transfer, and to all public institutions and organizations, private institutions and organizations, authorities, auditors, and supervisory and regulatory bodies legally authorized to receive personal data.
- Your Identity, Contact, Transaction Security, Financial, Legal Transaction and Customer Transaction Data, on the legal grounds that the processing is necessary for the establishment or performance of a contract, provided that it directly relates to it, of the personal data of the parties to that contract (KVKK Art. 5/2-c), is necessary for the data controller to fulfil its legal obligation (KVKK Art. 5/2-ç) and is necessary for the legitimate interests of the data controller (KVKK Art. 5/2-f),
are transferred, in order to carry out the company's activities — following up and conducting legal matters, assessing customers' requests and complaints from a legal perspective, following up requests/complaints, carrying out information security processes, communication activities, contract processes, finance and accounting work, customer relationship management processes, business continuity activities, after-sales support services, assessing customers' requests and complaints from a legal perspective, service and operational processes, audit activities and risk management processes — to third parties from whom we obtain services, support and advice in fields such as law and tax, to third parties providing support in other fields, to the service provider institutions and organizations, banks and representatives we work with, to the organizations we cooperate with, and to the organizations/persons from whom we obtain services/support/advice.
6How to Apply
6.1. You may submit your requests under Article 11 of KVKK, together with information identifying you and the subject of your request, by one of the following means:
- A written application with a wet signature sent to the Company's registered address (Akfırat Mah. Fatih Sultan Mehmet Blv. No: 3 İç Kapı No: 65, 34959 Tuzla/Istanbul, Türkiye),
- Registered electronic mail (KEP) sent to fineverbilisim@hs01.kep.tr by means of a secure electronic signature or mobile signature,
- Email sent to support@everagent.app from the email address registered in the Company's systems.
6.2. Your application must include your first and last name, your signature if the application is in writing, your Turkish identity number if you are a citizen of the Republic of Türkiye or your nationality and passport number or identity number if you are a foreign national, your residential or business address for notification, your email address for notification if any, your telephone number and the subject of your request.
6.3. Your application is concluded free of charge as soon as possible depending on the nature of the request, and within 30 days at the latest. If the action requires an additional cost, the fee in the tariff set by the Personal Data Protection Board may be charged.
6.4. If your application is rejected, you find the response inadequate, or no response is given in time, you may lodge a complaint with the Personal Data Protection Board within 30 days of learning of the response and in any event within 60 days of the application date.
8Changes
This notice may be updated. You will be informed of updates by email or in-Platform notice; the current version is always available on the Platform.
9Language
This notice has been prepared in Turkish and English. This text is a translation. In case of any inconsistency, the Turkish version prevails.