Privacy Policy & KVKK Disclosure
Last updated: March 4, 2026 · Kişisel Verilerin Korunması Aydınlatma Metni
1. Data Controller (Veri Sorumlusu)
FilmTexture (“we”, “us”, “our”) is based in Istanbul, Turkey. We are the data controller responsible for the processing of your personal data in accordance with:
- Turkish Personal Data Protection Law No. 6698 (“KVKK”)
- EU General Data Protection Regulation (“GDPR”), where applicable to EU/EEA residents
- Turkish Electronic Commerce Law No. 6563
Contact: hello@filmtexture.com
Website: filmtexture.com
2. Personal Data We Collect
We collect the following categories of personal data when you make a purchase or interact with our website:
| Category | Data | Purpose |
|---|---|---|
| Identity | First name, last name | Order processing, invoicing |
| Contact | Email address, phone number | Order confirmation, download links, customer support |
| Transaction | Purchase history, order reference, payment status, payment ID | Order fulfillment, accounting, legal compliance |
| Location | Country (auto-detected via IP geolocation) | Currency selection (USD/TRY), tax compliance |
| Technical | IP address, browser type, device information | Security, fraud prevention, website functionality |
We do not collect or store your credit/debit card details. All payment processing is handled exclusively by our PCI DSS-compliant payment provider, iyzico (iyzico Bilgi Teknolojileri A.Ş.).
3. Legal Basis for Processing (KVKK m.5/2, GDPR Art. 6)
We process your personal data based on the following legal grounds:
| Legal Basis | Processing Activity |
|---|---|
| Performance of contract (KVKK m.5/2-c) | Processing orders, delivering digital products, sending download links |
| Legal obligation (KVKK m.5/2-ç) | Tax record retention, fraud prevention, regulatory compliance |
| Legitimate interest (KVKK m.5/2-f) | Website security, analytics, service improvement |
| Explicit consent (KVKK m.5/1) | Marketing communications (only if you opt in) |
4. Third-Party Service Providers & Data Sharing
We share your data with the following service providers, solely for the purposes described in this policy:
| Provider | Purpose | Location |
|---|---|---|
| iyzico (iyzico Bilgi Teknolojileri A.Ş.) | Payment processing (PCI DSS Level 1) | Turkey |
| Vercel Inc. | Website hosting, CDN | EU / USA |
| Supabase Inc. | Database hosting (purchase records) | EU / USA |
| Resend Inc. | Transactional email delivery | USA |
| Plausible Analytics | Privacy-friendly website analytics (no cookies, no personal data) | EU |
We do not sell, rent, or trade your personal data to any third party.
5. Cross-Border Data Transfers (KVKK m.9)
Some of our service providers are located outside of Turkey. In accordance with KVKK Article 9, personal data may be transferred to countries that do not have an adequacy decision from the Turkish Personal Data Protection Board (“Kurul”). In such cases, we ensure adequate protection through:
- Contractual commitments from service providers (Standard Contractual Clauses or equivalent)
- Your explicit consent, obtained at the time of purchase when you agree to these terms
For EU/EEA residents: transfers outside the EEA are protected by Standard Contractual Clauses in accordance with GDPR Article 46(2)(c).
6. Cookies & Local Storage
6.1 Cookies
FilmTexture uses Plausible Analytics, which is a privacy-friendly analytics service that does not use cookies and does not collect personal data. We do not use any third-party tracking cookies.
Essential cookies may be set by our payment provider (iyzico) during the checkout process to facilitate payment security.
6.2 Local Storage (localStorage)
We use your browser’s localStorage to store:
- Shopping cart contents (
ft-cart): Product IDs, names, and prices of items in your cart. This data stays on your device and is not transmitted to our servers until you initiate checkout. - Theme preference (
ft-theme): Your dark/light mode selection.
localStorage data is not personal data and is stored solely on your device.
7. Data Retention
| Data | Retention Period | Reason |
|---|---|---|
| Purchase records (name, email, product, payment ID) | 10 years from purchase date | Turkish tax law (VUK m.253) and commercial record-keeping requirements |
| Account data | Until account deletion request | Ongoing service provision |
| Technical logs (IP, access logs) | 2 years | Security, fraud prevention, legal compliance (5651 sayılı Kanun) |
| Email correspondence | 3 years | Customer support records |
After the retention period expires, personal data is deleted or anonymized.
8. Your Rights (KVKK m.11 / GDPR Art. 15–22)
Under KVKK and GDPR, you have the following rights regarding your personal data:
- Right to know whether your personal data is being processed
- Right to request information about the processing
- Right to know the purpose of processing and whether it is used in accordance with that purpose
- Right to know the domestic or foreign third parties to whom your data is transferred
- Right to request correction of incomplete or inaccurate data
- Right to request deletion or destruction of your data (under conditions set out in KVKK m.7)
- Right to request notification of corrections/deletions to third parties
- Right to object to automated processing that produces a result against you
- Right to claim compensation for damages arising from unlawful processing
9. How to Exercise Your Rights (Başvuru Usulü)
To exercise any of the above rights, please submit your request to:
- Email: hello@filmtexture.com (with the subject line “KVKK Başvurusu” or “Data Subject Request”)
Your request must include your full name, email address used for purchase, and a clear description of your request. We will respond within 30 days of receiving your request, free of charge. If the request requires extensive research, the period may be extended by an additional 30 days, and you will be informed accordingly.
If you believe your rights have been violated, you have the right to file a complaint with:
- Turkey: Kişisel Verileri Koruma Kurulu (KVKK Board) — kvkk.gov.tr
- EU/EEA: Your local Data Protection Authority
10. Data Security
We implement appropriate technical and organizational measures to protect your personal data, including:
- SSL/TLS encryption (256-bit) for all data in transit
- Secure hosting infrastructure (Vercel, Supabase)
- Access controls and authentication for administrative systems
- PCI DSS-compliant payment processing via iyzico
- Regular security reviews
11. Data Breach Notification
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:
- Notify the KVKK Board within 72 hours of becoming aware of the breach (KVKK m.12/5)
- Notify affected individuals as soon as reasonably possible
- For EU/EEA residents: notify the relevant supervisory authority and affected individuals in accordance with GDPR Articles 33–34
12. Automated Decision-Making
We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on you. Country detection (for currency selection) is used solely for pricing display and does not affect your rights or access to products.
13. Children’s Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a minor, please contact us immediately at hello@filmtexture.com and we will promptly delete the data.
14. Changes to This Policy
We may update this privacy policy from time to time to reflect changes in our practices or applicable laws. Changes will be posted on this page with an updated revision date. We encourage you to review this page periodically. Material changes will be communicated via email where feasible.
15. Contact
For privacy-related questions, KVKK requests, or GDPR inquiries:
- Email: hello@filmtexture.com
- Website: filmtexture.com