Data Protection Notice

Data controller

Controller: [COMPANY LEGAL NAME], [ADDRESS], [REGISTRY / TAX NUMBER].

For businesses that sign up to agenola we are the controller. For visitors who talk to a business's avatar THAT BUSINESS is the controller; we act as processor on its instruction.

Data processed

Identity and contact: name, email.

Transaction security: password hash, session records, IP address.

Customer transaction: subscription status, usage counters, billing records.

Visitor data (as processor): flow answers, conversation transcript, IP and country, fields read from documents where applicable, and test results.

Purposes

Providing and maintaining the service, managing the account, operating the subscription and quota, billing, security, troubleshooting and meeting legal obligations.

Legal basis

Formation and performance of a contract (KVKK art. 5/2-c): account, subscription and running the service.

Legal obligation (art. 5/2-ç): invoices and accounting records.

Legitimate interest (art. 5/2-f): security, preventing abuse, measuring service quality.

Explicit consent: only for non-essential cookies and analytics tools.

Transfers abroad

TO STATE IT PLAINLY: some suppliers we use to provide the service are located abroad — the language model provider, the speech synthesis service and the payment provider (Stripe) among them. Personal data is therefore transferred abroad.

Transfers are made within the framework of KVKK art. 9 and only to the extent the service requires. [THE LEGAL MECHANISM RELIED ON FOR THE TRANSFER MUST BE STATED HERE: undertaking, binding corporate rules or explicit consent.]

Retention

There is currently no automatic deletion mechanism; records are kept until deletion is requested. Financial records are kept for the period the legislation requires.

Send deletion requests to [email protected].

Your rights (KVKK art. 11)

You have the right to learn whether your personal data is processed, to request information if it is, to learn the purpose and whether it is used accordingly, to know the third parties to whom it is transferred at home or abroad, to request correction if it is incomplete or wrong, to request erasure or destruction, to request that these actions be notified to third parties, to object to a result against you arising solely from automated analysis, and to claim compensation for damage.

Send applications to [email protected] or in writing to [ADDRESS]. Your request is concluded within thirty days at the latest.

Automated decisions

Tests and assessments built on agenola may score candidates. These scores do NOT produce a decision on their own: the business using the result is contractually required to apply human review. If you nonetheless believe an automated assessment has been made about you, you may exercise your right to object under art. 11.