Privacy Policy & Data Protection Notice

This is a courtesy English translation. In case of any discrepancy, the Turkish version prevails as it is governed by Turkish law (Law No. 6698 on the Protection of Personal Data, “KVKK”).

1. Data Controller

Pursuant to the Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”), your personal data is processed by SUB IQ YAZILIM ÇÖZÜMLERİ TİCARET LİMİTED ŞİRKETİ (the “Company”, “validrelay”) in its capacity as data controller, within the scope described below.

Address: SİLAHTARAĞA MAH. ÜNİVERSİTE 1. SK. NO:13/1 İÇ KAPI NO : Z16 ÇORLU TEKİRDAĞ
E-mail: info@subiq.com.tr
Phone: 444 85 39

2. Personal Data Processed

The following data categories may be processed in the course of your use of our platform:

• Identity and contact data: first name, last name, e-mail, phone.
• Company/customer data: company title, tax number, tax office, address.
• Account and usage data: username, password (stored cryptographically), session and transaction logs.
• Payment data: payment transactions are carried out by the licensed payment institution iyzico; your card details are not stored by the Company.
• Transaction security data: IP address, log records.

3. Purposes of Processing

• Establishment and performance of the service agreement,
• Membership and account management,
• Execution of billing and payment processes,
• Fulfilment of legal obligations (tax, regulatory, UTS/EUDAMED notifications),
• Provision of customer support services,
• Protection of information security and system integrity.

4. Legal Grounds for Processing

Your personal data is processed under Article 5 of the KVKK on the grounds that it is directly related to the establishment or performance of a contract, the fulfilment of a legal obligation, the establishment and protection of a right, and the legitimate interests of the data controller; and, where necessary, based on your explicit consent.

5. Transfer of Personal Data

Your personal data may, only to the extent limited to the purpose and where necessary, be shared with:

• The payment service provider (iyzico Ödeme Hizmetleri A.Ş.),
• Cloud infrastructure and hosting service providers,
• Authorised public institutions (TİTCK, European Commission EUDAMED, tax offices),
• Legally authorised authorities,

within the framework of Articles 8 and 9 of the KVKK.

6. Retention Period

Your personal data is retained for the period required by the processing purpose and for the statutory retention periods stipulated in the relevant legislation (e.g. under tax legislation); at the end of these periods it is deleted, destroyed or anonymised.

7. Data Security

The Company takes appropriate technical and administrative measures — including encryption in transit and at rest, access control and regular security audits — to prevent the unlawful processing of and access to your personal data.

8. Cookies

Our platform uses strictly necessary cookies for session management and core functionality. You can manage your cookie preferences through your browser settings; disabling strictly necessary cookies may cause some functions not to work.

9. Rights of the Data Subject (KVKK Art. 11)

As a data subject, you have the right to learn whether your personal data is processed, to request information if it has been processed, to learn the purpose of processing, to know the third parties to whom it has been transferred domestically or abroad, to request its correction if incompletely/incorrectly processed, to request its deletion/destruction, and to claim compensation for damages.

You may submit your requests to info@subiq.com.tr. Your application will be concluded within 30 days at the latest.

10. Amendments

This Privacy Policy may be updated when necessary. The current text is published on this page and its effective date is stated above.