Memberia Privacy Policy

1. Data Controller / Contact

Under applicable data protection laws (including Türkiye's KVKK), the data controller responsible for your personal data is:

• Data Controller: [TO BE FILLED – Legal name/title]
• Address: [TO BE FILLED]
• Email: [TO BE FILLED]
• Phone: [TO BE FILLED]

2. Accounts and User Content

• Users may create user accounts and organization/business accounts on Memberia.
• Content and data uploaded to Memberia by users or organizations remain the property of the relevant user or organization. Memberia does not disclose or sell such Content without the user's/organization's consent. Memberia will not share Content with third parties outside the purposes and scope described in this Privacy Policy and the Terms of Use.
• Memberia treats Content as private and confidential and takes reasonable technical and administrative measures to prevent unauthorized access, disclosure, or misuse. Data is retained until deleted by the user/organization, subject to legal retention obligations.
• Users can edit their profile and related data at any time via the app or web dashboard.

3. What Data We Collect

Depending on how you use Memberia, we may process:

4. How We Collect Data

We collect data:

• When you register, create an account, or update your profile
• When you scan a QR/barcode or perform check-ins
• Automatically during app/web use (logs, cookies/SDKs)
• When you contact support or participate in surveys

5. Purposes of Processing

Your personal data is processed for the following purposes:

• Providing membership creation, management, and verification services
• Enabling QR/barcode check-in and access control
• Operating organization dashboards and reports
• Processing payments and issuing invoices
• Providing customer support and responding to requests
• Ensuring platform security, preventing abuse/fraud
• Improving and developing Memberia features and performance
• Meeting legal obligations and responding to lawful requests by authorities

6. Legal Bases

We process personal data based on applicable legal grounds, such as:

• Necessity for performance of a contract (to provide Memberia services)
• Compliance with legal obligations
• Legitimate interests (security, fraud prevention, service improvement)
• Your explicit consent where required (e.g., marketing, non-essential analytics, certain optional features)
• You may withdraw consent at any time; withdrawal does not affect processing done before withdrawal.

7. Sharing and Transfers

Memberia does not sell your personal data.

We may share data only as necessary to provide the service and comply with law, including with:

• Hosting, database, backup, and infrastructure providers
• Email/SMS/push notification providers
• Payment and billing providers
• Customer support tools
• Organization/business account administrators and authorized staff
• Law enforcement, courts, or public authorities when legally required
• All such sharing is limited, purpose-bound, and subject to confidentiality and security measures.

8. International Data Transfers

Due to technical infrastructure, data may be stored or processed on servers located outside your country. Where required, we ensure appropriate safeguards and obtain explicit consent for cross-border transfers.

9. Retention

We keep personal data only for as long as necessary to:

• Provide the services,
• Comply with legal retention duties,
• Resolve disputes,
• Enforce our agreements, and
• Prevent fraud/security issues.
• After the retention period, data is deleted, destroyed, or anonymized.

10. Security

We take reasonable and up-to-date security measures, including:

• Encryption in transit (TLS/SSL)
• Role-based access control
• Logging and monitoring for unauthorized access
• Regular backups and disaster-recovery practices
• Confidentiality obligations for personnel and vendors
• No internet-based system can be guaranteed 100% secure, but we continuously work to protect your data.

11. Children's Privacy

Memberia is not intended for children under 18 unless used under the supervision of a parent/guardian or an organization with proper legal basis. We do not knowingly collect data from children without valid consent. If we become aware of such data, we will delete it upon request.

12. AI Features (If Available)

Some Memberia features may be powered by third-party AI services. If you use these features, relevant data you submit for that feature may be transmitted to and processed by the AI provider solely to deliver the feature and improve your experience. We do not allow AI providers to use your data to train generalized AI models unless you have explicitly consented. Organizations can disable AI features for their users through the organization settings.

13. Cookies / Analytics

The Memberia web app may use cookies or similar tools for:

• Session management
• Security
• Performance and usability analytics
• Where required, we request your consent for non-essential cookies/trackers. You can manage cookie preferences in your browser settings.

14. Your Rights

Under KVKK and other applicable laws, you may have the right to:

To exercise your rights, contact us at:

• Access your personal data
• Request correction or update
• Request deletion or anonymization
• Object to processing in certain cases
• Restrict processing
• Receive your data in a portable format where applicable
• Withdraw consent
• Lodge a complaint with the relevant authority

15. Third-Party Links

Memberia may include links to third-party sites or services. We are not responsible for their privacy practices. Please review their policies before using them.

16. Changes to This Policy

We may update this Privacy Policy from time to time. Updates take effect when published within Memberia or on our official website. Continued use of Memberia means you accept the updated policy.