Talky Personal Data Protection Notice (KVKK)
Version: 2026-10-14 · Effective: 14 October 2026
This notice is given under Article 10 of Türkiye's Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform. It covers everyone who uses the Talky mobile app and the talky.cat website. Because the data controller is in Türkiye, KVKK applies to all users wherever they live. This is an English rendering of the Turkish notice at talky.cat/kvkk; if the two differ, the Turkish version prevails.
1. Data controller
The data controller is Ata Kılıç, an individual based in Türkiye. Contact and applications: ata@kilicov.dev
2. Personal data we process
| Category | Data |
|---|---|
| Identity | Display name (first name and last-name initial are shown in the weekly league) |
| Contact | The email address your Apple or Google account shares with us |
| Customer transactions | Apple/Google account ID, Apple refresh token, app language, time zone, onboarding answers (including free text), lesson, exam, certificate, points, streak and league records, in-app events, purchase and subscription records, support messages |
| Audio recordings | Voice recordings you start yourself |
| Speech analysis | Transcript, word timings, measurements such as pace, pauses and filler words, scores, voice snapshot summaries, findings and quotes of your words in findings (up to 14 words) |
| Transaction security | Session records, push token, platform, device model, operating system, app version, crash reports, server logs and IP address |
| Legal transactions | Records of accepting the Terms, acknowledging notices and the voice screen, and giving or withdrawing marketing consent (type, document version, time, app version, platform, language, method) |
| Marketing | If you opted in to marketing, the use of your email address and push token for that purpose |
Your card and payment details never reach us; Apple or Google takes the payment.
Your voice is not processed as biometric data: no voiceprint or template is extracted, and your voice is not used to identify or authenticate you. Talky does not process health data; please don't write health information in the onboarding free-text field.
3. Purposes and legal grounds
| Purpose | Legal ground (KVKK Art. 5) |
|---|---|
| Creating your account, running sign-in and sessions, applying the age limit | Establishment and performance of a contract (Art. 5(2)(c)) |
| Transcribing and measuring your recordings and giving you feedback | Establishment and performance of a contract (Art. 5(2)(c)) |
| Setting your plan, level and progress; running the weekly league | Establishment and performance of a contract (Art. 5(2)(c)) |
| Sending service notifications such as practice reminders, streak and quest alerts, the weekly summary, trial and exam notices | Performance of a contract (Art. 5(2)(c)) and legitimate interest (Art. 5(2)(f)) |
| Providing and maintaining a Talky Plus subscription | Establishment and performance of a contract (Art. 5(2)(c)) |
| Keeping accounting and tax records; responding to competent authorities | Legal obligation (Art. 5(2)(ç)) |
| Keeping consent and acknowledgment records, staff audit logs and records relevant to possible disputes | Establishing, exercising or protecting a right (Art. 5(2)(e)) |
| Information security, preventing abuse and fraud, fixing bugs through crash reports, improving the service using aggregate data | Legitimate interest (Art. 5(2)(f)) |
| Sending marketing messages (campaigns, discounts, Talky Plus offers) by notification and email | Explicit consent (Art. 5(1)) and commercial electronic message approval under Law No. 6563 |
No processing other than marketing messages relies on explicit consent. The marketing consent text is published separately as Marketing Consent. You can turn crash reports off in Settings › Privacy › Crash reports.
4. How we collect data
Electronically and partly by automated means: Sign in with Apple and Google sign-in, questions and settings in the app, the microphone (only when you tap record), your use of the app, purchase notifications from the stores and RevenueCat, error records produced by the app and our servers, emails you send us, and the waitlist form on the website.
5. Recipient groups and purposes of transfer
| Recipient group | Recipient | Purpose |
|---|---|---|
| Service providers (processors) | Amazon Web Services, including Amazon Transcribe (Frankfurt, Germany) | Servers, database and queue; temporary storage and transcription of recordings |
| Service providers (processors) | Functional Software, Inc. — Sentry (US; data stored in Germany) | Collecting crash reports |
| Service providers (processors) | 650 Industries, Inc. — Expo (US) | Delivering notifications through Apple and Google push services |
| Service providers (processors) | RevenueCat, Inc. (US) | Managing Talky Plus purchase status |
| Service providers (processors) | Tally BV (Belgium) | Waitlist form on the website |
| Separate controllers | Apple and Google | Sign in with Apple and Google sign-in, store purchases, notification delivery (your relationship with them) |
| Public authorities | Legally competent authorities | Meeting legal obligations |
In the weekly league, other users in your group see your first name, last-name initial and weekly points. We do not sell your data or share it with anyone for advertising.
6. Transfers abroad
Your data is transferred to Germany, the United States and Belgium. There is no adequacy decision of the Personal Data Protection Board for these countries, so transfers are made under Article 9(4) of KVKK using the Board's standard contracts (controller to processor), signed with each provider and notified to the Board. Transfers to Apple and Google result from your own use of their services.
7. Retention periods
| Data | Retention |
|---|---|
| Audio recording (on our servers) | Deleted after analysis; any leftover file within 24 hours |
| Transcripts and quotes | 180 days |
| Measurements, scores, progress, account and profile data | While the account is open; deleted or anonymized within 24 hours after account deletion |
| Purchase and subscription records | 10 years |
| Consent and acknowledgment records | 10 years after account deletion |
| Staff audit logs | 10 years |
| Crash reports | Up to 90 days |
| Server logs | Up to 30 days |
| Support messages | 2 years after the request is closed; KVKK applications 10 years |
| Waitlist email | Until launch is announced or you leave the list, at most 2 years |
| Marketing consent | Until you withdraw it |
When a period ends, data is deleted, destroyed or anonymized. More detail is in the Privacy Policy.
8. Your rights under Article 11 of KVKK
As the data subject, you have the right to:
- learn whether your personal data is processed and, if so, request information about it,
- learn the purpose of processing and whether data is used for that purpose,
- know the third parties in Türkiye or abroad to whom it is transferred,
- request correction if it is incomplete or inaccurate,
- request deletion or destruction under the conditions in Article 7 of KVKK,
- request that correction, deletion or destruction be notified to the third parties it was transferred to,
- object to an outcome against you that results solely from analysis by automated systems,
- claim compensation if you suffer damage from unlawful processing.
Talky's measurements and level placement are automated. They only shape your study plan and have no legal or similarly significant effect on you; you can undo the placement on the voice snapshot result screen.
How to apply. Send your application in writing to ata@kilicov.dev from the email address registered in your Talky account (Communiqué on the Procedures and Principles of Application to the Data Controller, Art. 5). Include the information the Communiqué requires: your name, your Turkish ID number if you are a Turkish citizen, or your nationality and passport or ID number if not, an address for notices, a phone number if you have one, and what you are asking for. We conclude applications within 30 days. This is free of charge as a rule; if it involves an extra cost, the fee in the Board's tariff may be charged. If you are not satisfied with our answer, or get no answer in time, you can complain to the Personal Data Protection Board.
You can also delete your account and data in the app: Profile › Settings › Account and data › Delete account. If you can't use the app, follow the steps on Delete your account.