Krypteia Privacy Policy

Data Controller

Your personal data is processed by Krypteia Bilişim Ticaret Limited Şirketi ("Company"), acting as the data controller, in accordance with the Turkish Personal Data Protection Law No. 6698 ("Law") within the scope explained below.

The privacy and security of your personal data are important to us, and we take appropriate measures to protect it. As Krypteia Bilişim Ticaret Limited Şirketi, we process and retain your personal data in compliance with the applicable provisions of the Law.

Categories of Personal Data Processed

If you interact with our Company through any of the methods described under "Methods of Collecting Your Personal Data," the following categories of personal data may be processed:

  • Identity Information
  • Contact Information
  • Location Information
  • Customer Transaction Information
  • Requests and Complaints Information
  • Financial Information
  • Transaction Security Information
  • Marketing Information
  • Records Provided Within the Scope of AI Usage

Please note that your full bank account information, debit or credit card number, expiration date, and CVV/security code are not processed or stored by the Company during payment transactions. For purposes such as maintaining legally required sales records or processing subscription cancellation requests, the Company may process limited financial information (for example, the last four digits of your payment card), solely for the purposes described in this Privacy Policy.

Purposes of Processing Personal Data and Information Regarding the Application

Your personal data collected by the Company in connection with your use of the Krypteia application ("Application") will be processed in accordance with:

  • the purposes described below ("Purposes"),
  • the legal grounds set forth under Article 5 of the Law,
  • the general principles established under Article 4 of the Law,

including the principles of lawfulness, fairness, accuracy, necessity, proportionality, purpose limitation, and storage only for as long as necessary under applicable legislation.

Within the Application, responses generated through chatbot interactions are produced by artificial intelligence-based systems.

The categories of personal data processed may vary depending on how you use the Application.

The Application operates independently of any cryptocurrency exchange, brokerage, or financial intermediary.

Users may voluntarily submit information relating to their investment decisions, reasoning, analyses, portfolio preferences, and trading approaches through the AI chatbot and other Application modules.

Based on information voluntarily provided by the User, together with publicly available market information and the User's selected indicators and analytical preferences, the AI system generates educational and explanatory outputs.

Such outputs:

  • do not constitute investment advice;
  • do not constitute personalized financial advice;
  • do not constitute market predictions or forecasts;
  • do not make decisions on behalf of the User;
  • do not initiate or recommend automatic transactions.

The Application is designed solely as a decision-support tool intended to:

  • reduce the need for users to monitor multiple market data sources separately;
  • reduce screen time;
  • assist users in creating their own investment signals and analytical frameworks;
  • explain generally accepted financial analysis methodologies in the context of the User's own workflow; and
  • improve users' understanding and use of financial analysis tools through educational content.

Accordingly, the Application functions solely as an educational and decision-support assistant.

Purposes of Processing

Your personal data may be processed for the following purposes:

  • Providing the Company's services through the Application;
  • Delivering purchased services;
  • Establishing and managing subscription and sales agreements;
  • Billing and payment administration;
  • Managing financial and sales records;
  • Managing user accounts and membership processes;
  • Verifying and updating contact and membership information;
  • Informing users regarding purchased services and subscription changes;
  • Complying with legal obligations arising under applicable laws, including but not limited to the Turkish Commercial Code, the Consumer Protection Law, and the Electronic Commerce Law;
  • Responding to requests from competent public authorities;
  • Handling requests made by data subjects under Article 11 of the Personal Data Protection Law;
  • Complying with statutory record retention obligations;
  • Managing customer requests, complaints, and customer relationships;
  • Conducting accounting and financial operations;
  • Managing service termination requests;
  • Carrying out customer acquisition activities;
  • Planning customer satisfaction and corporate communication activities;
  • Maintaining accurate customer contact information;
  • Organizing campaigns, promotions, competitions, and marketing activities;
  • Managing corporate restructuring, mergers, acquisitions, or transfers of business assets;
  • Conducting sales and marketing activities;
  • Improving and developing the Company's products and services;
  • Maintaining information security;
  • Planning and implementing the Company's commercial strategies;
  • Investigating complaints and improving service quality;
  • Managing newsletter subscriptions;
  • Sharing necessary information with business partners where required for legitimate business operations;
  • Protecting the legal, technical, commercial, and operational security of the Company and its business partners;
  • Providing educational information relating to crypto assets;
  • Creating and displaying portfolio views based on portfolio information voluntarily entered by the User;
  • Monitoring user portfolios and generating reports;
  • Producing alerts, risk notifications, and behavioral insights based on the User's portfolio, preferences, and Application activity;
  • Preparing AI outputs that reflect the User's selected investment profile and preferences;
  • Generating AI-powered responses within the Application;
  • Improving AI quality by monitoring input/output quality, identifying inaccurate or inappropriate responses, and enhancing system performance;
  • Delivering operational notifications, including portfolio alerts, volatility notifications, and important Application updates;
  • Improving recommendation quality, AI performance, and overall user experience using User-provided information where appropriate;
  • Sending marketing communications, promotional materials, and commercial electronic messages, subject to the User's consent where required by law; and
  • Conducting customer satisfaction surveys, research, and analytical studies.

Artificial Intelligence Processing

The artificial intelligence chatbot used within the Application is based on a pre-trained Large Language Model (LLM).

As a general principle, User data is not used to retrain the underlying AI model.

However, for the purposes described above, including improving AI response accuracy, enhancing system security, identifying inaccurate or inappropriate responses, and improving overall system quality, the Company may review User interaction records to the limited extent necessary.

Such improvement activities are carried out using anonymized or encrypted data whenever possible, and appropriate technical and organizational safeguards are implemented to protect personal data.

The AI system operates by using:

  • text-based User inputs;
  • contextual information derived from interactions with different modules of the Application (such as portfolio analysis modules, signal generation tools, and similar features); and
  • other contextual information necessary to generate relevant responses.

As explained above, any data processed for the provision of the services is used solely for generating responses requested by the User and enabling the functionality of the Application.

The term "personalized" used within the Application should not be interpreted in the conventional financial advisory sense.

The Application does not provide:

  • personalized investment advice;
  • investment recommendations;
  • market forecasts;
  • price predictions; or
  • portfolio management services.

Information voluntarily entered into the AI chatbot is processed in encrypted form solely to support the User's financial analysis process and improve the technical quality of the interaction.

Such processing does not constitute individualized investment guidance or automated decision-making.

Transfer of Personal Data

Your personal data collected for the purposes described above may be transferred, in accordance with Articles 5, 6, 8, and 9 of the Turkish Personal Data Protection Law, to the following recipients where necessary:

  • suppliers providing services to the Company for legitimate business purposes, including but not limited to infrastructure providers, database management providers, cloud hosting providers, advertising agencies, communication service providers, and similar technical service providers;
  • the Company's business partners and shareholders;
  • entities acquiring all or part of the Company's business in connection with mergers, acquisitions, restructurings, or similar corporate transactions;
  • legally authorized public authorities where disclosure is required by applicable law;
  • legally authorized private entities where required by applicable legislation; and
  • foreign service providers where international data transfers are carried out under the applicable legal mechanisms, including standard contractual clauses approved by the relevant authority.

Personal data collected through the Application is not visible to other users.

As a general rule, the inputs you provide to the AI chatbot and the outputs generated for you remain private and are not shared with other users or displayed within their conversations.

Methods of Collecting Personal Data and Legal Grounds

Your personal data may be collected through:

  • the Application;
  • membership registration forms;
  • online forms;
  • the Company's website;
  • social media channels;
  • communication platforms;
  • mobile applications; and
  • email correspondence.

Personal data is processed under the following legal grounds:

Performance of a Contract

Where processing is necessary for the establishment or performance of a contract, your personal data may be processed for purposes including:

  • providing the Company's services through the Application;
  • establishing subscription and service agreements;
  • processing payments and invoices;
  • managing financial records;
  • managing memberships;
  • verifying and updating User information; and
  • notifying Users regarding purchased services.

Compliance with Legal Obligations

Where processing is required by law, your personal data may be processed in order to:

  • comply with obligations arising under the Turkish Commercial Code, Consumer Protection Law, Electronic Commerce Law, and other applicable legislation;
  • respond to requests from competent public authorities;
  • process applications submitted by data subjects under Article 11 of the Personal Data Protection Law; and
  • comply with statutory record-retention obligations.

Establishment, Exercise, or Protection of Legal Rights

Personal data may be processed where necessary for:

  • handling customer complaints;
  • resolving disputes;
  • conducting legal proceedings; and
  • retaining information as evidence during applicable statutory limitation periods.

Legitimate Interests

Where processing is necessary for the legitimate interests of the Company, provided that such processing does not override the fundamental rights and freedoms of the User, personal data may be processed for purposes including:

  • accounting and financial operations;
  • customer acquisition;
  • customer relationship management;
  • customer satisfaction activities;
  • newsletters and promotional campaigns;
  • information security;
  • business planning and corporate strategy;
  • improving products and services;
  • portfolio visualization and reporting;
  • generating behavioral insights and risk notifications;
  • improving AI models and recommendation quality (without retraining the underlying foundation model using personal data);
  • delivering operational notifications;
  • improving system performance and user experience; and
  • providing educational crypto-related content.

Consent

Where required under applicable law, and subject to your explicit consent, your personal data may also be processed for:

  • sending marketing communications;
  • promotional campaigns;
  • commercial electronic messages;
  • customer surveys; and
  • customer satisfaction research.

Your Rights as a Data Subject

Pursuant to Article 11 of the Turkish Personal Data Protection Law No. 6698 ("Law"), you have the following rights regarding your personal data:

  • To learn whether your personal data is being processed;
  • To request information if your personal data has been processed;
  • To learn the purpose of processing your personal data and whether it is being used in accordance with that purpose;
  • To learn the third parties to whom your personal data has been transferred, whether within Türkiye or abroad;
  • To request the correction of incomplete or inaccurate personal data and to request that such corrections be communicated to third parties to whom your personal data has been transferred;
  • To request the deletion, destruction, or anonymization of your personal data where the reasons requiring its processing no longer exist, even if it has been processed in accordance with applicable law, and to request that such actions be communicated to third parties to whom your personal data has been transferred;
  • To object to any result arising against you through the exclusive analysis of your personal data by automated systems;
  • To request compensation for damages arising from the unlawful processing of your personal data.

How to Exercise Your Rights

You may submit any request concerning the rights listed above directly to the Company.

Requests submitted by email may be sent to: info@krypteia.app

Your request will be evaluated and responded to free of charge as soon as possible and, in any event, within thirty (30) days, depending on the nature of your request.

However, where the requested process requires additional costs, the Company reserves the right to charge the fee determined by the Turkish Personal Data Protection Board in accordance with the applicable legislation.

Important Notice

The Company implements commercially reasonable technical, administrative, and organizational measures to protect personal data against loss, misuse, unauthorized access, disclosure, alteration, or destruction.

Nevertheless, no method of data transmission over the Internet or electronic communication system can be guaranteed to be completely secure or error-free.

Accordingly, Users are responsible for exercising appropriate care when sharing information through the Application and acknowledge the inherent security risks associated with electronic communications and online data transmission.

Contact Information

Data Controller

Krypteia Bilişim Ticaret Limited Şirketi

Registered Address:

Kolektif House Levent
Esentepe Mahallesi, Talatpaşa Caddesi No: 5/1
34394 Şişli, Istanbul
Türkiye

Email: info@krypteia.app