Privacy policy
How we process your personal data when you use lokomotif.ai, with reference to Turkish data protection law (KVKK) and, where it applies, the GDPR.
This English version is provided for convenience. The Turkish version is the authoritative text.
This policy explains how Saparda, Inc. (“we”, “Lokomotif AI”) processes the personal data of visitors (“Visitors”, “you”) of our website at lokomotif.ai (the “Website”). It covers who we are, the purposes for which we process your personal data, the parties we share it with, our legal grounds, our processing methods and your rights. It is written with reference to the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and, where the EU General Data Protection Regulation (“GDPR”) applies to you, it also describes that processing.
Data controller: Saparda, Inc., established at 112 Capitol Trail Ste A749 Newark 19711 DE, USA.
Personal data processed during your use of the Website is:
- processed lawfully, fairly and for specific, explicit and legitimate purposes,
- kept accurate and, where necessary, up to date,
- retained for the retention period we determine in line with applicable law.
Categories of personal data processed by Lokomotif AI
Processing security data
Visitors’ IP address data is collected automatically through the cookies on the Website. We process it to identify the device you use to access the Website. Under the Turkish Law No. 5651 on the Regulation of Publications on the Internet, we act as a hosting provider and are required to keep this data as traffic information. The legal ground for this processing is that it is necessary for compliance with a legal obligation to which we are subject (KVKK article 5/2(ç); where the GDPR applies, article 6(1)(c)). This data may be disclosed to judicial authorities if they request it, and to the Turkish Information and Communication Technologies Authority (“BTK”) if it requests it, so that we can meet our obligations under the applicable legislation.
Other
Visitors’ cookie records are collected automatically through the cookies on the Website. We process them to analyze the time Visitors spend on the Website and their activity during that time, in order to improve the user experience. The legal ground for this processing is our legitimate interest in analyzing Website efficiency and Visitor satisfaction, to an extent that does not intrude on your private life (KVKK article 5/2(f); where the GDPR applies, article 6(1)(f)). Subject to your informed explicit consent, cookie records may be shared with the platforms behind the relevant cookies for analysis, depending on the type of cookie used.
All data categories listed in this policy are shared with the company that provides our Website server and infrastructure services. This sharing arises from the need to host the processed data on a server and from the fact that the servers are operated by that company; it does not involve an active data transfer and takes place as an inherent part of the hosting service.
Your rights
Where the GDPR applies to you, you have the right to:
- request access to your personal data,
- request the rectification of inaccurate or incomplete data,
- request the erasure of your data,
- request the restriction of processing,
- receive your data in a structured, commonly used and machine-readable format (data portability),
- object to processing based on legitimate interest,
- withdraw any consent you have given at any time, without affecting the lawfulness of processing carried out before the withdrawal,
- lodge a complaint with a supervisory authority.
If you are in Turkey, your rights under KVKK remain fully reserved and are not limited by the list above.
You can send any request relating to these rights to hey@lokomotif.ai.