Disclosure Text Under the Personal Data Protection Law

Godot Technology Information and Consulting Services Industry and Trade Joint Stock Company ("Company" or "We"), pursuant to the Personal Data Protection Law No. 6698 ("KVKK"), Data Controller in our capacity as the Data Controller, inform you that we process your personal data within the scope described below.

Scope: This text applies to our users (account administrators and team members) who create an account on and use the AdaptiveReply platform ("Platform"). With regard to data processed by our users through the Platform concerning their own customers the Company's role is that of a " data processor "; the obligation to provide disclosure and obtain explicit consent regarding such data belongs to the relevant user/company.

1. Your Personal Data Processed

• Identity: First name, last name.
• Contact: Email address, phone number.
• Account and Transaction Security: Password, session information, IP address, login and transaction logs.
• Profile and Device: Profile image, language preference, notification preferences, device information.
• Customer Transactions and Finance: Subscription plan and payment information. Your card details are not stored by us.
• Marketing: Usage data collected through cookies and similar technologies.

2. Purposes of Processing Personal Data

• Membership/account creation, identity verification, and session management.
• Provision of our services and management of operational processes.
• Management of customer requests, complaints, and support processes.
• Ensuring information security and preventing misuse and fraud (IP and log records).
• Billing and subscription management.
• Improving service quality and user experience, and analytics activities.
• Marketing/promotional activities and ad conversion measurement based on your explicit consent.
• Fulfillment of legal obligations arising from applicable legislation.

3. Collection Method and Legal Basis

Your personal data is collected electronically through our website and mobile application, by fully or partially automated means. The following legal bases under Article 5 of the KVKK are relied upon:

• Art. 5/2-c — Establishment/performance of a contract (account creation, service provision, billing).
• Art. 5/2-ç — Fulfillment of a legal obligation.
• Art. 5/2-f — Legitimate interest (information security, fraud prevention, service improvement).
• Art. 5/1 (explicit consent) — For marketing activities and non-essential (analytics/advertising) cookies.

4. Transfer of Personal Data (Domestic and International)

Your personal data may be transferred to the following recipient groups in accordance with Articles 8 and 9 of the KVKK, within the scope of providing the service, fulfilling obligations arising from legislation, and our legitimate interests:

• Our business partners and suppliers,
• Our information technology and cloud service providers located domestically and abroad,
• Payment institutions and billing providers,
• Our legal advisors and auditors,
• Third-party platforms within the scope of integrations you establish,
• Authorized public institutions and organizations and judicial authorities when requested.

International transfer: Such transfers are carried out within the framework of KVKK Art. 9, provided that an adequacy decision exists or, if not, Board-approved appropriate safeguards are provided or your explicit consent is obtained.

5. Retention Period

Your personal data is retained for the period required by the purpose of processing and for the limitation/retention periods stipulated in applicable legislation; at the end of these periods, it is deleted, destroyed, or anonymized. If you delete your account, your data is deleted or anonymized, without prejudice to legal retention obligations.

6. Your Rights Under KVKK Art. 11

Pursuant to Article 11 of the Law, you have the right to learn whether your personal data is processed; request information if it has been processed; learn the purpose of processing and whether it is used in accordance with that purpose; know the third parties to whom it is transferred domestically/abroad; request correction if it has been processed incompletely/incorrectly; request its deletion/destruction under the conditions in KVKK Art. 7; request that these actions be notified to third parties to whom the data has been transferred; object to a result against you arising from analysis exclusively through automated systems; and request compensation for damages if you suffer harm due to unlawful processing.

7. Cookies

Essential, preference, analytics, and advertising cookies are used on our website and application. Non-essential (analytics/advertising) cookies are based on your explicit consent.

8. Contact and Application

To exercise your rights above, you may submit your request, prepared in accordance with KVKK Art. 13 and containing the necessary information to identify you, to info@godottech.com address (with a secure electronic/mobile signature or via the email address registered in our system) or Demirtaş Cumhuriyet Neighborhood, Müjdat Köstendil Street No:129, Osmangazi/Bursa address in writing, in person or through a notary public.