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Legal

KVKK notice

Draft · awaiting legal review

A lawyer has not yet reviewed this text, and it may change before Atolye opens.

Atolye is not open yet. This notice describes how we will process your personal data once the service opens, and what it says about a feature that is not on the site yet applies once that feature opens.

This notice is given under Article 10 of the Personal Data Protection Law No. 6698 ("KVKK"). It explains how LoreLabs Yazılım Limited Şirketi ("LoreLabs") processes personal data for Atolye.

Data controller

The data controller is LoreLabs Yazılım Limited Şirketi, Emniyet Evleri Mah. Eski Büyükdere Cad. Sapphire No: 1/1 İç Kapı No: 1B04 Kağıthane / İstanbul. MERSİS: 0609147389200001. E-mail: support@lorelabs.co.

For photos you upload that show a person, you decide why they are processed, and LoreLabs processes them on your behalf as a data processor. The terms of that processing are in the Terms of use, under "Data we process on your behalf".

Personal data we process

  • Identity and contact: your name if you give it, your e-mail address, and your phone number if you write to us on WhatsApp.
  • Account and transaction records: your sign-in details, your credit balance and history, your purchases and your support messages.
  • Visual records: the garment photos you upload and the images and videos Atolye produces from them. A photo may show a person, for example when a garment is photographed while worn.
  • Transaction security: IP address, device and browser details, and sign-in and error logs.

Purposes

  • To open and run your account.
  • To produce the images and videos you request and deliver them to you.
  • To keep your credit balance and, once payments open, to take payments and keep sales records.
  • To answer your support requests by e-mail or on WhatsApp.
  • To keep the service secure and prevent misuse.
  • To meet our legal obligations and answer requests from the authorities.

Legal grounds and how we collect data

We collect this data electronically: through the site and the application, from the files you upload and from the messages you send us. We rely on the grounds in Article 5(2) of the KVKK: processing that is necessary to set up and perform our contract with you, our legal obligations, the establishment, exercise or protection of a right, and our legitimate interests, provided they do not harm your fundamental rights and freedoms. Where a purpose needs your explicit consent, we ask for it separately, and you can withdraw it at any time.

Transfers, including abroad

We share personal data only as far as the service needs it: with Google (Firebase and Google Cloud, for hosting, sign-in, the database and file storage), with Eachlabs (which runs the image and video generation models that process your uploads), with the payment institution once payments open, and with the authorities when the law requires it. The servers of Google and Eachlabs may be outside Türkiye. For these transfers abroad we will rely on the standard contracts provided in Article 9 of the KVKK.

For legal review

The standard contracts with Google and Eachlabs, and their notification to the Personal Data Protection Authority, are not yet complete. This section becomes final only after legal review.

What we never do

  • We do not use your uploads or your images to train artificial intelligence models.
  • We do not use face recognition, and we do not derive biometric data from the photos you upload.
  • We do not animate or reuse a face that appears in your uploads. The models in Atolye's images are generated by artificial intelligence and are not based on a real person.

Retention

We delete your original photos at the end of the retention period set for the service, and when you delete your account. The images Atolye produces stay in your account until you delete them or the account. Account and transaction records are kept for the periods the law requires.

For legal review

The retention period for original photos is not yet set. Once it is, this notice will state it in days.

Your rights

Under Article 11 of the KVKK you may ask whether your personal data is processed and request information about it; learn why it is processed and whether it is used for that purpose; learn the third parties in Türkiye or abroad it is transferred to; ask for incomplete or wrong data to be corrected; ask for it to be deleted or destroyed under Article 7, and for any third party that received it to be told of the correction or deletion; object to a result against you that comes solely from automated analysis; and claim compensation if unlawful processing causes you damage.

Send your request in writing to Emniyet Evleri Mah. Eski Büyükdere Cad. Sapphire No: 1/1 İç Kapı No: 1B04 Kağıthane / İstanbul, or by e-mail to support@lorelabs.co from the address registered in your account. We answer free of charge within 30 days at the latest, unless the request involves an extra cost.

For legal review

The application channels follow the Communiqué on the Procedures and Principles of Application to the Data Controller. Legal review confirms them.