Privacy Policy
This document is both the Divançe privacy policy and the disclosure notice required under the Turkish Personal Data Protection Law No. 6698 (KVKK). One text, two functions. The Turkish version at /gizlilik is the authoritative text.
- 1. Who we are
- 2. What data we process
- 3. Legal grounds
- 4. International transfers
- 5. Retention and erasure
- 6. Your rights and how to apply
- 7. Security
- 8. Cookies and local storage
- 9. Children
- 10. Automated decision making
- 11. Changes
1. Who we are
PARLADOR LLC (New Mexico Limited Liability Company)1209 Mountain Road Pl NE, Ste N
Albuquerque, NM 87110
United States of America
Divançe is a web application operated by this company. Contact and application address: merhaba@divance.app
For the purposes of KVKK, PARLADOR LLC is the data controller. If a data controller representative is appointed in Türkiye, it will be announced in this section.
2. What data we process
All of the data below is obtained by fully automated means when you use the app.
| Data category | Example | Purpose | Legal ground (KVKK art. 5) | Retention | Where it goes |
|---|---|---|---|---|---|
| Translation input | The sentence you write to be translated | Producing the translation and the word explanations | Performance of a contract (art. 5/2-c) | Until the history record is deleted or the account is closed. Translations by visitors who are not signed in are also stored under a temporary anonymous identity. | Supabase, Google (Gemini) |
| Account data | Your email address or Google sign in identity, session cookies | Enabling sign in, tying the quota to a person | Performance of a contract (art. 5/2-c) | Until the account is deleted | Supabase |
| Usage and quota records | Daily translation allowance counter, word explanation request counter | Limiting cost, preventing abuse | Legitimate interest (art. 5/2-f) | Deleted together with the account | Supabase |
| Shared translation and card | The result and image card you choose to share | Showing the share link publicly | Explicit consent (art. 5/1): your act of sharing | Until it is unpublished or the account is deleted | Supabase, Netlify |
| Waiting list record | Your email address, the photo feature interest flag, the version of the consent text shown to you, the time of registration | Letting you know when the mobile app is released | Explicit consent (art. 5/1) | Until the announcement is made or you ask to be removed | Supabase |
| Technical rate limit record | A salted hash of your IP address (the raw IP is not stored) | Limiting spam and automated submissions on the waiting list form | Legitimate interest (art. 5/2-f) | 24 hours | Supabase |
| Hosting logs | Server access logs kept by our service providers | Operating and securing the service | Legitimate interest (art. 5/2-f) | The provider's own retention period | Netlify, Supabase, Cloudflare |
Word explanations (gloss) are generated on request and are not stored. Divançe contains no advertising network, no analytics tracker and no third party marketing software development kit; we do not collect data for those purposes and we do not sell data to anyone.
3. Legal grounds
3.1 Contract, legitimate interest, legal obligation
The processing needed to deliver the translation service rests on performance of a contract: processing the sentence you write and recognising your account are necessary for you to use the service at all. Quota counters, request counters and technical rate limit records rest on our legitimate interest in keeping the service running and preventing abuse. If a retention or disclosure obligation arises under applicable law, processing continues to the extent that obligation requires.
3.2 Processing based on explicit consent
Today only two operations rest on explicit consent: choosing to share a result publicly, and leaving your email address on the waiting list. You can withdraw your consent at any time by writing to merhaba@divance.app; withdrawal does not invalidate processing carried out before that point.
The disclosure notice and the collection of explicit consent are handled separately; this document is not a consent form.
3.3 Special categories of personal data (art. 6)
Today we process no special category of personal data. We collect no biometric data, including facial images. If a feature that processes photographs is added later, separate explicit consent will be collected for it and this text will be updated.
4. International transfers
Divançe is operated by a company established in United States of America and its infrastructure runs outside Türkiye. Data is therefore processed abroad. The service providers we use and their functions are:
- Supabase: database, authentication and file storage
- Netlify: hosting and content delivery
- Google: translation and word explanation generation through the Gemini interface
- Cloudflare: domain management and email forwarding
These providers process data only on our behalf and only for the purposes written in this document; they are not permitted to use it for their own purposes or to sell it to third parties.
5. Retention and erasure
Each category of data is kept only for as long as its purpose requires. The table below summarises the retention column of section 2.
| Data | Retention period |
|---|---|
| Translation input and result | Until the record is deleted or the account is closed |
| Account data | Until the account is deleted |
| Usage and quota records | Deleted together with the account |
| Shared translation and card | Until it is unpublished or the account is deleted |
| Waiting list record | Until the announcement is made or you ask to be removed |
| Technical rate limit record (IP hash) | 24 hours |
| Hosting logs | The provider's own retention period |
Data whose period has expired or whose purpose has ceased is deleted. We act on an erasure request within 30 days at the latest.
6. Your rights and how to apply
6.1 Article 11 rights under KVKK
Under article 11 of KVKK you may apply to the data controller and exercise the following rights:
- To learn whether your personal data is processed
- To request information if your personal data has been processed
- To learn the purpose of processing and whether the data is used in line with that purpose
- To know the third parties in the country or abroad to whom your personal data is transferred
- To request rectification if your personal data is incomplete or inaccurate
- To request erasure or destruction of your personal data under the conditions set out in article 7 of the law
- To request that rectification and erasure operations be notified to the third parties to whom the data was transferred
- To object to an adverse outcome arising from analysis of your data solely by automated systems
- To claim compensation if you suffer damage because your personal data was processed unlawfully
You can send your application to merhaba@divance.app; we conclude it within 30 days at the latest.
6.2 Account and data deletion
The steps for asking us to delete your account and the data attached to it are set out on a separate page: Account and data deletion. That page is in Turkish; the process itself is a single email step.
6.3 Users resident in United States of America
We do not sell your personal data and we do not share it for advertising purposes. If the law of your state grants you rights of access, correction or deletion, you can exercise them through the same application address.
7. Security
Connections between your browser and our servers are encrypted with TLS. Only the privileged server side path can write to the waiting list data; the application's public key can neither read nor write that table. IP addresses are kept as a salted hash rather than in raw form. Database privileges are granted at the minimum level: each record is visible only to its owner, and a translation that has not been shared is not exposed to any visitor.
8. Cookies and local storage
Only the Supabase authentication cookies needed to keep your session are used. There are no advertising or tracking cookies. If you block cookies in your browser settings you will not be able to sign in.
9. Children
The service is not directed at children and we do not knowingly collect data from children. If we learn that such a record exists, we delete it.
10. Automated decision making
No decision producing an adverse effect on you is taken by analysing your personal data solely through automated systems. An artificial intelligence model produces the translation text; that is not profiling and it is not a decision about you.
11. Changes
If this text is updated, the version number and the effective date change. If the purpose of processing changes, a separate disclosure is made BEFORE processing starts for the new purpose.