INFLYZE (SFENKIA LTD) PRIVACY POLICY

1. INTRODUCTION

As Sfenkia Ltd operating under the Inflyze brand ("Company", "we", "us"), we attach great importance to the privacy of your personal data in the services we provide through our website (inflyze.com) and mobile application ("Platform").

This Privacy Policy explains how we collect, process, store, and protect your personal data in accordance with Turkish Personal Data Protection Law No. 6698 (KVKK), European Union General Data Protection Regulation (GDPR), and United Kingdom Data Protection Act (UK GDPR).

2. SCOPE

This policy applies to:

• Influencers, brands, and individual users registered on our Platform,
• People who visit our website and mobile application,
• Business partners and potential customers,
• Job applicants.

3. DATA WE COLLECT

We may collect the following personal data through our Platform:

4. DATA COLLECTION METHODS

• Website and mobile application registration forms
• Social media API integrations (Instagram Graph API, etc.)
• Cookies, SDKs, and tracking technologies
• Customer support channels
• Event and campaign registration forms

5. PURPOSES OF DATA PROCESSING

We process the personal data we collect for the following purposes:

1. Creating and managing user accounts
2. Influencer-brand matching and campaign execution
3. Providing social interaction (likes, comments, messages)
4. Receiving/sending payments and billing
5. Security, fraud and spam prevention
6. Improving user experience
7. Marketing and advertising targeting (with explicit consent)
8. Fulfilling legal obligations

6. LEGAL BASIS

Your personal data may be processed based on the following legal grounds:

• Explicit consent (KVKK Art.5, GDPR Art.6/1-a)
• Establishment or performance of a contract
• Fulfillment of legal obligations
• Protection of our legitimate interests
• Protection of public health (for special category data)

7. DATA SHARING

Your personal data is shared only for the purposes specified above with:

• Business partners, advertising agencies, campaign managers,
• Payment service providers,
• Legal and accounting consultants,
• Cloud storage services (AWS, Google Cloud, etc.),

For data transfers abroad, GDPR Art.45-49 provisions apply.

8. COOKIES AND TRACKING TECHNOLOGIES

The Platform uses mandatory, performance, analytical, and marketing cookies and SDKs. Users can change their cookie preferences through browser or device settings.

9. DATA RETENTION PERIODS

• Account information: 2 years from account deletion
• Invoice records: 10 years
• Cookie data: 2 years
• Legal dispute data: For the duration of the case

10. DATA SUBJECT RIGHTS

In accordance with KVKK Art.11 and GDPR Art.15-21, users have the right to:

• Access their data,
• Request correction,
• Request deletion,
• Restrict processing,
• Request data portability,
• Object to automated processing.

Applications: privacy@inflyze.com

11. SECURITY MEASURES

• SSL/TLS encryption
• Firewall and attack detection systems
• Authorization and access control
• Regular penetration tests
• KVKK & GDPR trained personnel

12. DATA BREACH SITUATION

• Notification to ICO within 72 hours under GDPR & UK GDPR
• Notification to KVKK Authority within 72 hours under KVKK
• Informing affected users

13. POLICY UPDATES

This policy may be updated in accordance with legal changes or technical requirements. The current version is published on inflyze.com and mobile application.