Explicit Consent Notice
Most of the processing Kullya carries out is based on grounds that do not require consent, such as a contract or a legal obligation. This page describes only the processing that depends on your explicit consent. This English version is provided for convenience; the Turkish text prevails.
Nature of explicit consent
Explicit consent is consent that relates to a specific matter, is based on information and is given of your own free will. Consent is requested separately for each processing activity below, no pre-ticked boxes are used, and consent is not made a condition of membership or purchase.
Before giving consent, please read the KVKK Privacy Notice, issued under Law No. 6698 on the Protection of Personal Data ("KVKK"). The data controller is Emre Işık ("Kullya").
Transfers abroad for artificial intelligence features
When you use features in the panel such as AI Studio, AI website creation, and AI content and image generation, the prompt you enter, any file or image you attach and the website content that needs to be processed are sent to one of the following providers, depending on the model you select or that is selected automatically: OpenAI (USA), Anthropic (USA), Google (USA and European Union), DeepSeek (People's Republic of China), Z.ai (Singapore), Cloudflare Workers AI (USA).
There is no adequacy decision of the Personal Data Protection Board for these countries, and the transfer is based on your explicit consent under subparagraph (a) of paragraph six of Article 9 of the Law. Possible risks: the data becoming subject to a legal system that may not protect it to the same level as in Türkiye, the data possibly becoming subject to access requests from that country's public authorities, and the data being kept according to the provider's own retention period. Kullya connects to the providers under enterprise API terms that do not use customer data for model training.
You give this consent separately in the panel when you first use AI features. If you do not give consent, AI features will not work; the rest of the panel and your websites are not affected. You can withdraw your consent from Account settings in the panel or by writing to us; withdrawal stops transfers from that moment on.
Commercial electronic messages and marketing
Commercial electronic messages such as campaigns, discounts, new feature announcements and newsletters are sent only if you have given your approval. For this purpose, your first name, last name, email address, phone number and message preferences are processed; your approval may be recorded in the Message Management System (İYS) as required by Law No. 6563.
Details are on the Commercial Electronic Message Consent page. Messages about your account, orders, invoices, security and legal notices are not commercial messages and are sent regardless of your approval.
Withdrawal of consent
You can withdraw your explicit consent at any time, without giving any reason and free of charge. You can withdraw through the panel settings, the opt-out link in messages, İYS, or by sending an email to info@kullya.com. Withdrawal does not affect the lawfulness of processing carried out on the basis of consent up to that date.
For a question about your consent, go to the contact page.