Privacy Notice

Last updated: 2026-10-05

This Privacy Notice has been prepared in accordance with Article 10 of Law No. 6698 on the Protection of Personal Data ("KVKK") and the relevant legislation, to inform you, as the data controller, about the processing of your personal data.

1. Identity of the Data Controller

Your personal data is processed by COON TEKNOLOJİ LİMİTED ŞİRKETİ in its capacity as data controller.

Company: COON TEKNOLOJİ LİMİTED ŞİRKETİ
Address: ITOB OSB MAH. 10032 SOKAK NO:2-209, Menderes / İzmir, Türkiye
Email: [email protected]
Product: Polpo Desk (polpodesk.com)

2. Personal Data Processed

Identity and contact: full name, email address.
Account security: password (stored in hashed form, never kept in plain text).
Membership: organization and plan information.
Transaction security: session and audit logs, IP and connection metadata.

The content of remote access sessions is end-to-end encrypted (WebRTC DTLS-SRTP) and is neither viewed nor stored by the data controller.

3. Purposes of Processing Personal Data

Creating, authenticating and managing your account.
Providing the service and establishing and maintaining remote access sessions.
Carrying out plan and billing processes.
Ensuring information security, preventing misuse and keeping audit trails.
Fulfilling legal obligations and responding to requests.

4. Legal Bases for Processing

Your personal data is processed on the following legal bases set out in Articles 5 and 6 of the KVKK:

Processing is necessary for the conclusion or performance of a contract (Art. 5/2-c).
Processing is mandatory for the data controller to fulfil a legal obligation (Art. 5/2-ç).
Processing is necessary for the legitimate interests of the data controller, provided it does not harm your fundamental rights and freedoms (Art. 5/2-f).
Where required, your explicit consent (Art. 5/1), in particular for transfers abroad.

5. Transfer of Personal Data (Domestic / International)

Your personal data may be transferred only to the extent limited to the purposes above and in accordance with Articles 8 and 9 of the KVKK.

Our service uses Cloudflare for its content delivery network (CDN) and TURN server infrastructure. For this reason, connection metadata and technical records may be transferred abroad to the countries where the servers are located. This transfer is carried out based on your explicit consent and/or other conditions prescribed under Article 9 of the KVKK.

6. Method of Collecting Personal Data

Your personal data is collected electronically through the web panel and registration forms, the Client Software, cookies and similar technologies, by automated or partly automated means.

7. Retention Period

Your personal data is retained for the period required by the purpose of processing and for the statutory limitation and retention periods prescribed by the relevant legislation. At the end of these periods, your data is deleted, destroyed or anonymized.

8. Rights of the Data Subject

Under Article 11 of the KVKK, as a data subject you have the following rights:

To learn whether your personal data is processed and, if so, to request information about it.
To learn the purpose of processing and whether the data is used in accordance with that purpose.
To know the third parties to whom the data is transferred domestically or abroad.
To request rectification if the data is processed incompletely or incorrectly.
To request deletion or destruction under the conditions set out in the KVKK.
To request that rectification, deletion and destruction be notified to third parties to whom the data was transferred.
To object to an outcome against you resulting from analysis solely by automated systems.
To claim compensation for damage you suffer due to unlawful processing.

9. Method of Application

You may submit requests concerning the above rights, together with information verifying your identity, by sending an email to [email protected] or in writing to our company address. Your applications are concluded within the periods prescribed by the KVKK and the relevant legislation.