KVKK Notice

Notice under the Turkish Personal Data Protection Law No. 6698 ("KVKK")

Effective date: May 10, 2026

This Notice has been prepared pursuant to Article 10 of the KVKK and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform, in order to inform our users located in Turkey about the processing of their personal data.

1. DATA CONTROLLER

Your personal data is processed as data controller by FirstDoor.app (referred to as "FirstDoor" / the "Company"), which operates the firstdoor.app platform. FirstDoor's corporate structure is currently in formation; the official company name and registered address will be updated in this document once incorporation is complete. Contact: support@firstdoor.app

2. PERSONAL DATA PROCESSED

Identity and contact: username, e-mail address, (optional) display name;
Membership and transaction security: password hash, session and access logs, IP address, device/browser information, two-factor authentication status;
User content: forum topics, posts, comments, complaint/report records, private messages;
Wallet data: the public wallet address linked to the account;
Marketing: your newsletter subscription and communication consent preferences;
Legal proceedings and compliance: request and application records; (if KYC or sanctions screening is implemented in the future) verification and screening results.

3. PROCESSING PURPOSES

Establishment and performance of the membership agreement; creation and management of the account and provision of forum services;
Ensuring Platform and account security; prevention of fraud, bots, and misuse; moderation;
Fulfillment of legal obligations (responding to requests from competent authorities, record retention; AML/sanctions compliance if implemented in the future);
Carrying out communication activities (verification, informational and security e-mails, support);
Sending marketing and announcement messages where your explicit consent exists;
Analysis, improvement, and troubleshooting of the services;
Establishment, exercise, and protection of legal rights.

4. LEGAL BASES (KVKK Art. 5)

Legal basis	Example processing
Art. 5/2-c: Directly related to the establishment/performance of a contract	Account creation, session management, provision of the forum service
Art. 5/2-ç: Fulfillment of a legal obligation	Responding to official requests; AML/sanctions checks if implemented in the future
Art. 5/2-e: Establishment, exercise, or protection of a right	Retention of logs and content records as evidence in disputes
Art. 5/2-f: Legitimate interest	Security monitoring, misuse detection, service analytics
Art. 5/1: Explicit consent	Marketing messages, non-essential cookies, and the transfer-abroad cases described below

5. TRANSFER AND TRANSFER ABROAD

5.1 Your personal data may, limited to the purposes above, be transferred to our service providers (hosting, e-mail, analytics, security, KYC), to legally authorized public institutions, and to our legal/audit advisors.

5.2 Transfer abroad. As the Company is established abroad (UAE) and its servers and service providers may be located abroad, your data is transferred abroad within the scope of KVKK Art. 9. This transfer is carried out on the basis of the safeguards set out in the applicable legislation (appropriate undertakings, standard contracts, Board decisions) and, where necessary, on the basis of your explicit consent. The text relating to explicit consent is set out in Document 4.

6. METHOD OF COLLECTION

Your data is collected electronically, by partially or fully automated means, through registration and profile forms, your use of the forum, your correspondence with us, cookies and similar technologies, and system logs.

7. YOUR RIGHTS UNDER KVKK ART. 11

To learn whether your personal data is being processed;
To request information if it has been processed;
To learn the purpose of processing and whether it is used in accordance with that purpose;
To know the third parties to whom the data is transferred domestically or abroad;
To request correction of incomplete or inaccurate data;
To request the deletion or destruction of data within the framework of the conditions set out in KVKK Art. 7;
To request that correction, deletion, and destruction be notified to third parties to whom the data has been transferred;
To object to a result arising against you through the exclusive analysis of processed data by automated systems;
To request compensation for damages suffered as a result of unlawful processing.

8. METHOD OF APPLICATION

You may submit your requests to support@firstdoor.app, together with identifying information, in accordance with the Communiqué on the Procedures and Principles for Application to the Data Controller. Applications are, as a rule, concluded free of charge within thirty (30) days at the latest; if the transaction requires an additional cost, a fee set by the Board's tariff may be requested. If your application is rejected or the response is found insufficient, you retain the right to file a complaint with the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu).