As Picsolv Anonim Şirketi ("Picsolv" or the "Company"), in our capacity as "Data Controller" under the Turkish Personal Data Protection Law No. 6698 ("KVKK"), we wish to inform you about the processing of your personal data.
1. Data Controller
Your personal data may be processed by Picsolv Anonim Şirketi within the scope set out below.
2. Purposes of Processing Personal Data
Your collected personal data is processed for the following purposes:
- Provision of photo matching, face recognition and image processing services offered through the Picsolv platform,
- Carrying out membership procedures and ensuring the security of your account (e.g. via liveness testing),
- Improving service quality, detecting and resolving system errors,
- Creating anonymised statistical reports for event organisers (participant density, demographic analyses, etc.),
- Fulfilling legal obligations and notifying competent authorities.
3. Personal Data Processed and Collection Methods
Your personal data is collected by automated means in electronic form through the Picsolv mobile application, website, API integrations and cookies.
Data categories processed:
- Identity Information: First name, last name.
- Contact Information: Email, phone.
- Special Category Personal Data (Biometric Data): Reference photo used for face recognition, face embedding data and liveness check records.
- Audiovisual Records: Photos uploaded to the system or taken at events.
- Transaction Security: IP address, device information, log records.
4. Legal Bases
Your personal data is processed on the following legal bases set out in KVKK Articles 5 and 6:
- Explicit Consent (KVKK Art. 5/1 and Art. 6/2): Your explicit consent is obtained for the processing of your biometric data (face recognition data) and the transfer of all your personal data to servers abroad (AWS, Google).
- Conclusion and Performance of Contract (KVKK Art. 5/2-c): Provision of the core service (showing photos, account management) as required by the membership agreement.
- Legal Obligation (KVKK Art. 5/2-a): Retention of log records as required by Law No. 5651.
- Legitimate Interest (KVKK Art. 5/2-f): Analyses and security measures to improve service quality.
5. Transfer of Personal Data
Your personal data may be transferred to:
- Overseas Service Providers: Amazon Web Services (AWS) and Google Cloud infrastructure whose servers are located abroad, for data storage and AI analysis (face recognition, image enhancement) services,
- Business Partners: Event organisers (limited to your participation in the relevant event and anonymised analyses or photos you have authorised),
- Public Authorities: Competent public institutions where required by law.
6. Data Subject Rights (KVKK Article 11)
In accordance with Article 11 of the KVKK, you have the right to apply to our Company to:
- Learn whether your personal data is being processed,
- Request information if it has been processed,
- Learn the purpose of processing and whether it is used for that purpose,
- Request correction if processing is incomplete or incorrect,
- Request deletion or destruction within the framework of the conditions set out in the KVKK,
- Object to data processing and request compensation where damage has occurred.
You may send your requests to hello@picsolv.com.