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Privacy Policy

Last updated: September 10, 2026

This Privacy Policy explains how Abdullah Yiğit Sağlam ("I", "me"), who develops the Mayza platform ("Service": the waitlist page, the web/app interface, and all related services), processes the personal data of visitors and users ("you") under Turkey's Law on the Protection of Personal Data No. 6698 ("KVKK") and related legislation. For users accessing from the European Union, I also observe the principles of the General Data Protection Regulation ("GDPR") to the extent applicable.

This document is for general informational purposes and is not legal advice. For questions, you can reach me at info@lumiverion.com.

1. Data Controller

Under KVKK, the data controller is Abdullah Yiğit Sağlam. For requests relating to your personal data, you can reach me at info@lumiverion.com.

2. Data We Collect

2.1. Waitlist

  • Name
  • Email address

2.2. When you create an account (app users)

  • Email address, username
  • Password (never stored in plain text; kept only in irreversibly hashed form)
  • Exam history, exam results, and progress statistics
  • Your chat messages and any feedback/report content you submit to the platform
  • Technical usage data such as login frequency, last-seen time, and general usage activity
  • When you purchase a subscription: the amount, currency, payment reference, and the start/end dates of your Premium access; also the full name, mobile phone number, Turkish national ID number (T.C. Kimlik No), and billing address you enter in the form at the payment step for invoicing and to start the subscription (and a separate delivery address if you enter one). Your card number, expiry date, and CVC are never seen, processed, or stored by me, they are handled solely by the payment institution.

2.3. Automatically collected data

  • IP address (for request-rate limiting / security purposes, to prevent abuse)
  • Browser and device information, server log records

3. Why We Process Your Data

  • Registering you for the waitlist and announcing the platform launch
  • Creating your account, authenticating you, and managing your session
  • Concluding the subscription agreement, invoicing it, and starting it through the payment institution (processing the identity and address details you enter for this purpose and passing them to iyzico)
  • Generating AI-powered exam questions, powering the chat assistant, and calculating your progress/statistics
  • Securing the Service (preventing abuse, brute-force attacks, and automated exploitation)
  • Evaluating your feedback and responding to support requests
  • Fulfilling legal obligations

My processing activities are based, under KVKK Art. 5, on your explicit consent (e.g. waitlist registration), on the establishment/performance of a contract (e.g. providing services related to your account and granting the Premium access you purchased), or on my legitimate interest (e.g. security and abuse prevention). For a detailed breakdown of legal grounds, see the KVKK Disclosure Notice.

3.1. AI and Retrieval-Augmented Generation (RAG)

I use retrieval-augmented generation (RAG) to produce exam questions and chat answers. I want to be clear about what that involves:

  • Your chat messages and exam generation requests are sent to AI model providers located outside Türkiye so that a response can be generated.
  • Documents uploaded to the platform are split into chunks and converted into vector representations (embeddings), stored in the database alongside the corresponding text.
  • Your question is also converted into a vector; the most relevant chunks are retrieved and sent to the model as context.
  • For this reason I strongly recommend that you do not enter sensitive or special-category personal data into the chat or exam fields.

AI outputs can be wrong and are not used to make automated decisions producing legal effects concerning you. For the full explanation, see the relevant section of the KVKK Disclosure Notice.

4. Who We Share Your Data With

I do not sell your data. To provide the Service, data is shared, only to the extent necessary and kept to a minimum, with the following categories of service providers:

  • Payment institutions: When you purchase a subscription, data is shared with iyzico, an authorised payment and electronic money institution, to take and verify the payment and to start the subscription; for this purpose your full name, e-mail, mobile phone number, Turkish national ID number, and billing/delivery address are sent to iyzico. iyzico is established in Türkiye. I never see your card details, they are processed directly by the payment institution.
  • AI service providers: Messages/requests you send for exam generation and chat responses are transmitted to AI model providers so a response can be generated.
  • Hosting, database, and storage providers: Used for server hosting, database, and file storage services.
  • Email delivery providers: Used to send waitlist confirmation emails and account notifications.
  • Analytics and advertising tools: Cookie-based third-party tools may be used on our marketing pages for conversion measurement (see Section 6).

These providers process your data solely on my behalf and for the stated purposes. Your data is not shared with other third parties unless legally required. For questions about the third parties your data is transferred to, you can reach me at info@lumiverion.com.

5. International Data Transfers

Some of the service providers I use may host their servers outside Turkey. In these cases, your data is transferred only to the extent necessary to provide the Service and in accordance with the international transfer conditions set out in KVKK Art. 9.

6. Cookies and Local Storage

A third-party analytics tool runs on our waitlist/marketing page for conversion measurement; this tool may place cookies in your browser. On the app side (the interface you use once logged in), instead of cookies, a session token is stored in your browser to keep you signed in; this token is kept only on your device.

7. Data Retention Period

I retain your personal data for as long as required by the purpose for which it was collected, or for as long as my legal retention obligations continue. Subscription, invoice, and payment records (including the associated full name, mobile phone number, Turkish national ID number, and billing/delivery address) are retained for ten (10) years under applicable financial legislation. If you request deletion of your account, your data is deleted or anonymized within a reasonable time, subject to my legal retention obligations.

8. Data Security

I apply administrative and technical measures consistent with industry standards to protect your personal data. Your passwords are stored irreversibly hashed, sessions are managed using secure methods, access controls are applied against unauthorized access, and data is transmitted over encrypted connections.

9. Your Rights Under KVKK

Under KVKK Art. 11, you have the following rights:

  • To learn whether your personal data is being processed
  • To request information about it if it has been processed
  • To learn the purpose of processing and whether it is used in accordance with that purpose
  • To know the third parties to whom it is transferred domestically or abroad
  • To request correction if it is processed incompletely or incorrectly
  • To request its deletion or destruction under the conditions of KVKK Art. 7
  • To request that these operations be notified to third parties to whom the data has been transferred
  • To object to a result that is to your detriment arising solely from analysis of the processed data through automated systems
  • To request compensation for damages you suffer due to unlawful processing

To exercise these rights, you can write to info@lumiverion.com. Your request will be evaluated within the periods prescribed by law.

10. Children's Privacy

The Service is intended for adult users preparing for the SGS and SMMM proficiency exams and is not intended to knowingly collect data from anyone under 18.

11. Changes to This Policy

I may update this Privacy Policy from time to time. Material changes are announced by posting on this page and/or notifying you at your registered email address. The current version is always available on this page.

12. Contact

For all privacy-related questions: info@lumiverion.com