KVKK Disclosure Notice
Last updated: September 19, 2026
Contents
Purpose
This notice is prepared under art. 10 of Turkey's Personal Data Protection Law No. 6698 (KVKK) to inform you how your personal data is processed by the data controller.
Data controller
Under Law No. 6698 on the Protection of Personal Data, the data controller is PAX GROUP DOO. You can reach the controller at contact@paxgroupglobal.com; the full contact details are in the block at the end of this page.
Personal data processed
The following categories of personal data are processed, with the scope and retention periods shown.
| Data | Scope | Retention |
|---|---|---|
| Account data | Name, email, password hash, language preference, consent timestamp | Until the account is deleted |
| Phone | Phone number and verification status (only while phone verification is enabled or when you add a number yourself; anti-bot / real-user check) | Until the account is deleted |
| Chart images | Screenshots you upload for analysis (private, access-restricted storage) | Until account deletion; rejected/inappropriate uploads deleted immediately. Images you attach in chat follow a shorter period |
| Analysis reports | AI-generated technical-outlook reports | Until the account is deleted |
| Doji AI conversations | The questions you ask, the answers you receive and your feedback (a like/dislike and any note you write). The question and the relevant context are sent to a third-party AI model provider so the answer can be produced | 90 days from the last message in the conversation; deleting a conversation yourself removes it immediately |
| Images you attach in chat | Chart images you attach in a conversation (private, access-restricted storage) and the short note produced by the image precheck. The image is sent to a third-party AI model provider so the answer can be produced | 30 days from sending; when image storage is off, no image is stored at all. The short note stays with the conversation |
| Audit and log data | Security events (register, login, analysis), IP address, device/browser info | Limited period for security |
| Quota counters | Monthly analysis usage counts | Per month; until account deletion |
| Credit records | Earned/granted credits and balance | Until the account is deleted |
| Country | Country code derived from the IP address at sign-up or from the phone country code (no city is stored) | Until the account is deleted |
| Subscription records | Store transaction identifiers, product identifier, period end and environment; card/payment details stay with the store | For the statutory financial record-keeping period |
| Ad delivery | Device identifier and ad-interaction data, passed to the ad provider; no personalised targeting | The ad provider's own retention periods |
This product includes GeoLite2 data created by MaxMind, available from https://www.maxmind.com
Purposes of processing
Your personal data is processed for, and limited to, the following purposes.
| Purpose | Detail |
|---|---|
| Providing the Service | Creating and managing your account and access |
| Producing analyses | Generating technical-outlook reports from your charts |
| Answering chat questions | Answering your questions in the Doji AI chat, assembling the context an answer rests on, and reviewing your feedback to improve the service |
| Security | Preventing abuse and running quota and fraud checks |
| Communication | Sending transactional email/SMS (verification, key notices) |
| Legal obligation | Meeting statutory retention and reporting duties |
Legal grounds
Processing relies on the following legal grounds set out in KVKK art. 5 and 6.
| Legal basis | Applied to |
|---|---|
| Performance of a contract | Account and analysis (KVKK 5/2-c; GDPR 6/1-b) |
| Explicit consent | Risk consent and international transfers (KVKK 5/1, 9; GDPR 6/1-a) |
| Legitimate interest | Security, logging and abuse prevention (KVKK 5/2-f; GDPR 6/1-f) |
| Legal obligation | Statutory retention duties (KVKK 5/2-ç; GDPR 6/1-c) |
Domestic and international transfers
Your personal data may be transferred to sub-processors necessary to run the Service, some located abroad. International transfers rely on your explicit consent and/or appropriate safeguards under KVKK art. 9.
Your rights under KVKK art. 11
You have the right to: learn whether your data is processed; request information if it is; learn the purpose of processing; know the third parties to whom it is transferred at home or abroad; request correction of incomplete/incorrect data; request deletion/destruction where conditions are met; request that these actions be notified to third parties; object to a result against you arising solely from automated analysis; and claim compensation for damage due to unlawful processing.
How to apply
You can submit requests via the contact details below. Your application is resolved within 30 days under KVKK art. 13. You retain the right to complain to the Personal Data Protection Authority where appropriate.
Contact
For KVKK requests, use the data controller's contact details below.
Business and data-controller details
- Legal name
- Mert Gül
- Address
- Tekirdağ, Türkiye
- Data controller
- PAX GROUP DOO
- Controller address
- Zrtava Fasizma 46, Montenegro (PIB 03800709)
- Trade registry no.
- 51348461
- Phone
- +382 68 599708
- Support
- contact@paxgroupglobal.com
- Legal notices
- contact@paxgroupglobal.com
- Governing law
- Karadağ (Montenegro) hukuku