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Legal

PRIVACY POLICY

Transparent information about the security and processing of your data.

1. Data Controller

This disclosure text, prepared pursuant to Article 10 of the Personal Data Protection Law No. 6698 ("KVKK"), provides transparent information on the processing of your personal data by Lura Software & Consulting as the data controller.

Data Controller Contact Information

Company

Lura Software & Consulting

Email

support@lurasoftware.com

Web

lurasoftware.com

Request Subject

Please send your requests by e-mail with the subject "KVKK Request".

2. Data Processor / Data Controller Distinction

Lura Software operates in two distinct roles within the SaaS model:

Data Controller Role

For identity, contact, and payment data of client company managers (Supervisors), Lura Software acts as the "Data Controller".

Data Processor Role

For personal, payroll, and HR data belonging to the client's own employees, Lura Software acts solely as a "Data Processor". Primary responsibility for this data rests with the client company.

3. Data Processed and Legal Basis

Within the framework of KVKK Articles 5 and 6, a separate legal basis is stated for each data category:

Identity & Contact Data (Manager)

Name, email, phone. Legal Basis: Establishment and performance of contract (Art. 5/2-c).

HR & Payroll Data (Employee)

ID number, salary, IBAN, SSI records. Legal Basis: Explicitly required by law – Labor Law, Social Security legislation (Art. 5/2-a).

Transaction Security

IP address, session logs, browser info. Legal Basis: Legitimate interest – system security (Art. 5/2-f).

Cookie Data

Essential cookies (legitimate interest Art. 5/2-f); analytics cookies (explicit consent Art. 5/1). See our Cookie Policy for details.

4. Data Transfer

Your personal data may only be transferred for the following purposes and within the framework of KVKK Articles 8-9:

Social Security Institution & Revenue Administration: Within the scope of legal notification obligations (Art. 5/2-a).
Infrastructure Providers (Supabase etc.): For technical operations required for service delivery; bound by a data processing agreement.
International Transfer: Supabase operates within the EU region. No transfers are made to countries without an adequacy decision.
Your data is never sold or transferred to third parties for advertising or marketing purposes.

5. Data Security & Breach Notification

Lura Software implements the following technical and administrative measures for data security:

256-bit SSL/TLS encryption for secure data transmission.
Role-based access control (RBAC) ensuring only authorized users access data.
Regular backups and data integrity audits.
In the event of a personal data security breach, notification will be made to the Board within 72 hours pursuant to KVKK Art. 12/5.

6. Data Retention and Destruction

Your personal data is retained for the period required by the processing purpose:

Active Subscription

Throughout the subscription period and applicable legal retention periods (minimum 10 years for HR records under Labor Law).

Trial Period

30 calendar days after the trial end date.

Automatic Deletion

If no paid subscription is started, all data is automatically and irreversibly deleted at the end of the 30th day.

Account Deletion

Upon user request, deletion is performed immediately, subject to applicable legal retention requirements.

7. International Data Transfer

Our platform's cloud infrastructure (Supabase) is hosted in the EU/EEA region. Where no adequacy decision exists between the EU and Turkey, standard contractual clauses and additional security measures are applied. Supabase is a GDPR-compliant provider operating under a data processing agreement (DPA).

8. Cookie Policy

For detailed information about the cookies used on our platform, please review our separately prepared Cookie Policy. Cookie disclosure is made in accordance with the KVKK Board Decision No. 2022/120 and the Cookie Guidelines. Essential cookies are used under legitimate interest, while functional and analytics cookies are used with explicit consent.

9. Rights of Data Subject (KVKK Art. 11)

As a personal data subject, you have the following rights:

Learn whether your personal data is processed
Request information if processed
Learn the purpose and whether it is used accordingly
Know the third parties to whom data is transferred
Request correction of incomplete or incorrect data
Request deletion or destruction under KVKK Art. 7
Request notification of corrections/deletions to third parties
Object to results of automated data processing against you
Claim compensation for damages due to unlawful processing

Last Update: 7/30/2026