This Disclosure Statement ("Aydınlatma Metni") is prepared by Lumina Yazılım İnovasyon Teknoloji Ticaret Limited Şirketi("Lumina") in its capacity as data controller, in accordance with Article 10 of the Türkiye Personal Data Protection Law No. 6698 ("KVKK"). Lumina cares about the security of your personal data and processes it in line with applicable legal obligations.
1. Identity of the Data Controller
- Legal Name: Lumina Yazılım İnovasyon Teknoloji Ticaret Limited Şirketi
- Address: Esentepe Mah. Tevfik Erdönmez Paşa Sk. 6 Blok No: 5/8 Şişli/İstanbul
- Contact: info@luminateknoloji.net
- For detailed registry and tax information, please reach us at info@luminateknoloji.net.
2. What Personal Data Do We Collect?
When you interact with our website (luminateknoloji.net) or our products (Cuty, Soulwise), we may collect the following:
- Identity: name, surname, username.
- Contact: email, phone, postal address (only if you share it).
- Transaction data: contact form contents, subject, send time.
- Technical data: IP address, user-agent, access logs, cookie data.
- Product usage data: detailed in each product's own privacy policy.
3. Purposes of Processing
Your personal data is processed for the following purposes:
- Evaluating and responding to enquiries submitted via the contact form;
- Improving and personalising our products and services;
- Complying with our legal obligations (tax, commercial legislation, etc.);
- Maintaining information security (preventing malicious access, keeping audit logs);
- Performing business relationships and contractual obligations.
4. Legal Basis for Processing
Your personal data is processed on the legal grounds set out in Article 5/2 of KVKK:
- Establishment or performance of a contract (e.g., responding to your contact-form request);
- Compliance with a legal obligation (tax, commercial law);
- Legitimate interest (system security, service quality);
- Explicit consent (Article 5/1 — for special category data or non-mandatory communications).
5. Third Parties to Whom Your Data May Be Transferred
Your personal data may be shared, only to the extent necessary for the purpose, with the following sub-processors. All operate under data-processing agreements with Lumina:
- Vercel Inc. (web hosting, edge runtime, CDN — EU and US locations)
- Supabase Inc. (database — EU Frankfurt)
- Resend Inc. (transactional email — United States)
- Cloudflare Inc. (Turnstile anti-spam, DNS — global)
- Upstash Inc. (Redis rate limiting — EU Frankfurt)
- Sentry Inc. (production error monitoring — EU Frankfurt)
- Authorities when legally required.
Cross-border transfers comply with KVKK Article 9 and the Personal Data Protection Authority's standard contracts / binding corporate rules.
6. Retention Period
Contact-form records are retained for a maximum of 3 years. Records subject to legal obligations are retained for the period mandated by relevant legislation. At the end of these periods, your data is deleted, destroyed or anonymised.
7. Your Rights under KVKK Article 11
As a data subject, you have the right to:
- Learn whether your personal data has been processed;
- Request information about the processing if it has;
- Learn the purpose of processing and whether the data is used for that purpose;
- Learn about third parties to whom data has been transferred, in or out of the country;
- Request correction of incomplete or inaccurate personal data;
- Request deletion, destruction or anonymisation under Article 7;
- Request that the actions in (e) and (f) be communicated to third parties to whom data has been transferred;
- Object to a result that arises against you due to automated analysis;
- Demand compensation for damages incurred from unlawful processing.
8. How to Apply
To exercise these rights, please email info@luminateknoloji.net in the format prescribed by the Communiqué on Procedures and Principles of Application to the Data Controller, or send a written request to our address above. We will respond within the legal maximum of thirty (30) days.
This Disclosure Statement may be updated as legislation evolves or our processes change. The current version is always available on this page.