KVKK Clarification Text

Personal Data Protection and Processing Clarification

Effective Date: January 1, 2025
Last Updated: January 1, 2025

1. Identity of Data Controller

Data Controller: EloRiser
Address: Istanbul, Turkey
Tax ID Number: 5130724524
Contact Email: privacy@eloriser.com
Website: https://eloriser.com

2. Personal Data We Collect

We process the following categories of personal data:

2.1 Identity Information

• Name, surname, username
• Date of birth
• Government-issued ID number (for verified users)
• Profile photograph

2.2 Contact Information

• Email address
• Phone number (optional)
• Discord username
• Billing address

2.3 Customer Transaction Information

• Order history and details
• Transaction records
• Payment history
• Refund records
• Platform balance

2.4 Gaming Account Information

• Riot Games account credentials (when provided for services)
• Current rank and rating
• Server region
• Account level

2.5 Technical Information

• IP address
• Browser type and version
• Operating system
• Device identifiers
• Cookie data
• Login/logout times

2.6 Communication Information

• Support ticket content
• Chat messages with boosters
• Email correspondence
• Feedback and reviews

3. Methods of Data Collection

Your personal data is collected through:

• Direct Provision: Information you provide during registration, order placement, or profile updates
• Automatic Collection: Technical data collected automatically through cookies and similar technologies
• Third-Party Sources: OAuth providers (Discord, Google), anti-fraud services
• Usage Data: Information generated during platform usage

4. Legal Basis and Purposes of Processing

Your personal data is processed based on the following legal grounds under KVKK Article 5:

4.1 Contract Performance (KVKK Art. 5/2-c)

Processing necessary for performance of our service agreement:

• Account creation and management
• Service delivery (boosting, coaching, account sales)
• Order processing and fulfillment
• Payment processing
• Customer support provision

4.2 Legal Obligation (KVKK Art. 5/2-a)

Processing required by law:

• Tax record keeping (Tax Procedure Law)
• Financial record retention (Commercial Code)
• Consumer protection compliance (Consumer Protection Law No. 6502)
• Identity verification (Anti-Money Laundering Law)

4.3 Legitimate Interests (KVKK Art. 5/2-f)

Processing necessary for our legitimate interests:

• Fraud prevention and security
• Platform improvement and optimization
• Business analytics
• Risk assessment

4.4 Explicit Consent (KVKK Art. 5/1)

Processing based on your explicit consent:

• Marketing communications
• Personalized advertising
• Non-essential cookies
• Third-party data sharing (beyond service provision)

5. Transfer of Personal Data

5.1 Domestic Transfers

Your personal data may be transferred to:

• Other platform users (limited public information only)
• Service providers and business partners
• Legal authorities when required by law
• Auditors and advisors

5.2 International Transfers

Your data may be transferred to countries outside Turkey for cloud hosting, analytics, and service provision. We ensure adequate protection through:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by Turkish Data Protection Authority
• Your explicit consent
• Contractual necessity

6. Your Rights Under KVKK

Under Article 11 of KVKK, you have the right to:

• Learn whether your personal data is being processed
• Request information about the processing if your data has been processed
• Learn the purpose of data processing and whether it is used in accordance with its purpose
• Know the third parties to whom your data is transferred domestically or abroad
• Request correction of incomplete or inaccurate data
• Request deletion or destruction of your data within the framework of conditions stipulated under Article 7 of KVKK
• Request notification of correction, deletion, or destruction operations to third parties
• Object to processing that leads to unfavorable results
• Request compensation if you suffer damage due to unlawful processing

7. How to Exercise Your Rights

7.1 Application Methods

You may exercise your rights by:

• Email: Send a written request to privacy@eloriser.com
• Website: Use the contact form at https://eloriser.com/contact.php
• Mail: Send notarized application to our registered address in Istanbul

7.2 Application Requirements

Your application must include:

• Name, surname, and signature
• Turkish ID number or passport number
• Contact address for response
• Email address and phone number
• Subject of the request
• Supporting documents (if any)

7.3 Response Timeline

We will respond to your application:

• Free of charge
• Within 30 days at the latest
• Through the same method you used to apply (unless you request otherwise)
• If response requires additional costs (e.g., material costs), fees determined by the Turkish Data Protection Authority may apply

8. Data Retention Period

We retain your personal data for the following periods:

• Active Account Data: Duration of account activity
• After Account Deletion: 30 days for recovery, then deleted
• Transaction Records: 10 years (tax law requirement)
• Support Communications: 3 years
• Marketing Consents: Until consent withdrawal
• Legal Claims: Duration of statute of limitations

Data is deleted or anonymized when no longer necessary for legal or business purposes.

9. Data Security Measures

We implement technical and administrative measures to protect your data:

• Technical Measures: SSL/TLS encryption, firewalls, access controls, intrusion detection
• Administrative Measures: Staff training, confidentiality agreements, access logging
• Physical Measures: Secure data centers, access restrictions
• Regular Audits: Security assessments and compliance reviews

10. Data Breach Notification

In case of a personal data breach, we will:

• Notify the Turkish Data Protection Authority within 72 hours
• Inform affected data subjects without undue delay
• Take necessary measures to prevent further breaches
• Cooperate with authorities in investigations

11. Complaint to Turkish Data Protection Authority

If you believe your rights under KVKK have been violated, you may file a complaint with:

Turkish Personal Data Protection Authority (KVKK)
Address: Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4, 06520 Balgat-Çankaya/ANKARA
Website: https://www.kvkk.gov.tr
Application Portal: https://www.kvkk.gov.tr/Icerik/6699/Basvuru-Formlari

12. Updates to This Clarification Text

We may update this Clarification Text to reflect changes in our practices or legal requirements. Material changes will be notified via email or platform notification. Continued use after changes constitutes acceptance.

13. Contact Information

Data Controller: EloRiser
Address: Istanbul, Turkey
Tax ID: 5130724524
Email: privacy@eloriser.com
Website: https://eloriser.com
Contact Form: https://eloriser.com/contact.php