Contact> Translation notice: This English version is provided for convenience. The Turkish original is the binding text; in case of any discrepancy, the Turkish version prevails.
Draft start date: May 23, 2026 Last updated: July 13, 2026
> This is a V1 draft; it is not a commitment regarding live data flows. The retention, > deletion, and provider chain for the physical device and the parent app should not be > considered in effect until production evidence and legal review are complete.
As data controller within the meaning of Article 3/1-(ı) of the Personal Data Protection Law No. 6698 ("KVKK", the Turkish Personal Data Protection Law):
| Information | Value |
|---|---|
| Data controller | NeuroQubit AI / Neeko |
| Address | Will be published once official service-of-process and registry details are completed. |
| MERSİS number (Turkish Central Registry Number) | Will be published once registry details are completed. |
| Tax office / number | Will be published once registry details are completed. |
| Trade registry number | Will be published once registry details are completed. |
| KEP address (Turkish Registered Electronic Mail) | Will be published once the KEP address is completed. |
| Phone | Contact requests are currently received via email and the web form. |
| support@neekoai.com.tr | |
| Website | neekoai.com.tr |
This table will be updated once official registry, KEP, and service-of-process details are completed. If a VERBİS (Turkish Data Controllers' Registry) obligation arises, the registration process will be carried out.
This Information Notice has been prepared to inform you, pursuant to Article 10 of the KVKK, about your personal data processed through the Neeko physical device, the NeekoApp mobile application, the `neekoai.com.tr` and `app.neekoai.com.tr` websites, and related services (the "Services").
You can find our detailed policy in the Privacy Policy, processing based on explicit consent in the Explicit Consent Statement, and information about your child's data in the Children's Data Policy.
Your personal data is processed in the following categories, excluding special categories of personal data within the meaning of Article 6/1 of the KVKK:
| Category | Data |
|---|---|
| Identity | First name, last name |
| Contact | Email address, phone (optional) |
| Customer transaction | Order record, invoice details, payment reference (v1.1) |
| Transaction security | Password hash, session token, IP address, session log |
| Marketing | Notification preferences, explicit consent history |
| Legal proceedings | Data subject requests, litigation records |
| Child profile data | Child's name, age, interests (entered by the parent) |
| Device interaction data | Voice transcript, memory card, safety event counts |
| Audio recording | Audio stream (processed in real time; no raw file is stored) |
| Technical | Device model, operating system, app version, firmware version, crash trace |
Important: Voice data is assessed as potentially qualifying as a "special category of personal data" under Article 6/1 of the KVKK. For this reason, explicit consent is obtained for the processing of voice data (see the Explicit Consent Statement).
Your personal data is processed for the following purposes:
Processing is carried out on the following legal grounds pursuant to Articles 5/2 and 6/3 of the KVKK:
| Legal Ground (KVKK) | Applicable Processing |
|---|---|
| Art. 5/2-a — Expressly provided for by law | Invoice retention (VUK), consumer law compliance (TKHK), legal dispute records |
| Art. 5/2-c — Formation or performance of a contract | Account registration, order management, product support |
| Art. 5/2-ç — Legal obligation | Requests from competent authorities |
| Art. 5/2-e — Establishment, exercise, or protection of a right | Legal dispute records and defense of legal rights |
| Art. 5/2-f — Legitimate interest (after balancing test) | Transaction security, fraud detection, child safety measures, crash reporting |
| Art. 5/1 — Explicit consent | Processing of voice data, marketing communication, international transfers |
| Art. 6/3 — Explicit consent (if special category applies) | Additional safeguard for voice data |
Your personal data may be transferred to third parties within Turkey in the following cases:
Pursuant to Article 9 of the KVKK, international transfers are made on the basis of your explicit consent or the exceptions provided by law:
| Provider | Country | Purpose of Transfer | Legal Basis |
|---|---|---|---|
| Render, Inc. | USA | Server hosting | Explicit consent (Art. 9/1) |
| Cloudflare, Inc. | USA / Global | Content delivery, storage | Explicit consent |
| LiveKit, Inc. | USA | Real-time audio transmission | Explicit consent |
| OpenAI / Anthropic | USA | Natural language processing | Explicit consent |
| ElevenLabs, Inc. | USA / Global | Generating personalized audio on the website from the name/curiosity text | Explicit consent |
| Functional Software, Inc. (Sentry) | USA | Crash reporting | Explicit consent |
| Apple Inc. / Google LLC | USA | App distribution, push notifications | Explicit consent |
For international transfers, the conditions of Article 9 of the KVKK and additional safeguards such as the GDPR Standard Contractual Clauses (SCC) are applied.
Your personal data is collected through the following channels:
Your personal data is retained for as long as required by the purpose of processing:
| Data | Retention Period |
|---|---|
| Account (email, profile) | For as long as the account is active + a 30-day restoration period |
| Device pairing | For as long as the device is linked to the account |
| Child profile data | For as long as the account is active; the parent can delete it |
| Web demo name and curiosity preference | Until the browser tab/session ends or the user clears it |
| Web demo personalized TTS input and output | The completed audio result is not written to a time-limited result cache on Neeko's server; only simultaneous identical generations may be merged until the operation completes. The browser's playback memory and ElevenLabs' applicable policy may additionally apply |
| Voice transcript | V1 plan candidate: at most 90 days; to be finalized through legal, purpose, backend, and deletion testing |
| Raw audio file | V1 goal: not permanently stored by Neeko; to be verified on the LiveKit/provider account |
| Memory cards | V1 goal: only with parental approval, until the parent deletes them |
| Safety event counts | V1 plan candidate: at most 12 months; subject to legal/backend confirmation |
| Orders and invoices | 10 years (TTK Art. 82, VUK Art. 253) |
| Legal dispute records | Statute of limitations (TBK, the Turkish Code of Obligations, Arts. 146-147) |
When the period expires, the data is deleted, destroyed, or anonymized (KVKK Art. 7).
Pursuant to Article 11 of the KVKK, as a data subject you have the following rights:
a) To learn whether your personal data is being processed
b) If it has been processed, to request information about it
c) To learn the purpose of processing your personal data and whether it is used in accordance with that purpose
ç) To know the third parties, within or outside Turkey, to whom your personal data has been transferred
d) To request the correction of your personal data if it is incomplete or inaccurate
e) To request the deletion or destruction of your personal data under the conditions set out in Article 7 of the KVKK
f) To request that the actions taken under items (d) and (e) be notified to the third parties to whom your personal data has been transferred
g) To object to a result arising against you through the analysis of your processed data exclusively by automated systems
ğ) To claim compensation for damages if you suffer harm due to the unlawful processing of your personal data
In addition:
To exercise your rights, pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller:
Applications sent from the email address registered to your account are taken into consideration for identity verification purposes. Written application and KEP channels will be added to this notice once official service-of-process details are completed.
Your application will be answered within 30 days at the latest (KVKK Art. 13/2). The application is free of charge; however, if the process additionally requires a cost, the fee in the tariff determined by the Board may be requested.
We take the following technical and administrative measures for the security of your personal data:
In the event of a data breach: Pursuant to Article 12/5 of the KVKK, we notify the Board of the breach within 72 hours at the latest and the affected data subjects within a reasonable period, and make a public announcement if necessary.
This Information Notice may be updated due to changes in legislation, product development, or changes in the purpose of processing. In case of significant changes:
Email: support@neekoai.com.tr (with the subject line "KVKK Application") Web: neekoai.com.tr/contact
Official registry, KEP, service-of-process address, and phone details will be added to this Information Notice once completed.
For questions, write to us: support@neekoai.com.tr