Our Policy
Adem Tengiz, residing at Nispetiye Mahallesi Petrol Sitesi Sokak 24.Blok 1AI daire:6 Beşiktaş İstanbul (“Huddle”, “we”, “us” and/or “our”), is committed to protecting your privacy and earning your trust. This Privacy Policy discloses our privacy practices for personal data collected from Huddle users within the scope of membership activities when you use or access our products, services, features, or content (“Services”) through the Huddle application (“Application”).
PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. BY ACCESSING THE HUDDLE APPLICATION OR SERVICES, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATION OR SERVICES.
Changes To Our Policy
We may, in our sole discretion, change this Privacy Policy from time to time. If we make any changes, we will post the revised version within the Application. It is your responsibility to review this Privacy Policy periodically, and your continued use of the Services signifies your acceptance of the updated policy.
Information We Collect
When you interact with us through the Services, we may collect your personal data directly from you and through fully automated methods (when you register for the Huddle Application or upload data to the Application).
Huddle collects only the following categories of information:
Identity Information: Name, surname, and—strictly on an optional basis if you choose to share it—Date of Birth.
Contact Information: Email address, and—strictly on an optional basis if you choose to share it—Phone Number.
Visual and Auditory Records: Strictly on an optional basis if you choose to share it, a Photo.
Information Regarding Business, Education, and Professional Life: Information about the business you own or are authorized to represent.
Important Note: Your date of birth, phone number, and photo are entirely optional and will only be collected if you explicitly choose to share them with us.
How We Use Your Information
Huddle collects and processes your personal data only as reasonably necessary and proportionate to provide the Services. Your personal data is used for the following specific purposes:
- Conducting and managing membership activities for the Huddle Application.
- Enabling the creation of business accounts within the Huddle Application.
- Ensuring the security of data controller operations.
- Receiving suggestions and feedback to improve the Huddle Application.
Lawful Basis for Processing
Your personal data is processed in accordance with the Law No. 6698 on the Personal Data Protection Law (“PDPL”) based on the following legal grounds:
Contractual Necessity (PDPL Art. 5/2-c): Provided that it is directly related to the establishment or performance of a contract, processing the personal data of the parties to the contract is necessary (for conducting membership activities and opening business accounts).
Legitimate Interests (PDPL Art. 5/2-f): Provided that it does not violate the fundamental rights and freedoms of the data subject, data processing is mandatory for the legitimate interests of the data controller (for ensuring operational security and receiving feedback).
How We Share Your Information
Your personal data may only be shared with third parties under the following conditions and for the specified purposes:
Service Providers Abroad: To ensure business continuity, protect operational security, and securely store business and employee data, your information is transferred to our third-party SaaS (Software as a Service), PaaS (Platform as a Service), and database providers located abroad, who are authorized as data processors. This transfer is carried out strictly based on your explicit consent (PDPL Art. 9).
Legal Obligations and Authorized Authorities: For the purposes of legal reporting, conducting audit activities, and managing disputes or legal processes, your data may be disclosed to public institutions, organizations, and judicial authorities legally authorized to request information. This transfer is mandatory for Huddle to fulfill its legal obligations (PDPL Art. 5/2-ç with reference to Art. 8/2-a).
How We Protect Your Information
We implement and maintain all necessary technical and administrative measures to ensure the appropriate level of security. This is done to prevent unlawful processing of personal data, block unauthorized access to data, and ensure safe storage of your information.
Data Retention and Disposal
We will retain your personal data for as long as necessary to provide the Services and fulfill the purposes outlined in this policy. Retention periods are determined by taking into account legal obligations, potential disputes, and business requirements. Once the retention period expires or the purpose of processing ceases to exist, your data will be securely deleted, destroyed, or anonymized in accordance with our data retention and disposal policies.
How to Update Your Information and Your Rights
Pursuant to Article 11 of the PDPL, you may apply to Huddle at any time to exercise the following rights:
- Learn whether your personal data is being processed;
- Request information if your personal data has been processed;
- Learn the purpose of the processing and whether the data is being used in accordance with that purpose;
- Know the third parties to whom your personal data is transferred, whether at home or abroad;
- Request rectification if your personal data is processed incompletely or inaccurately;
- Request erasure or destruction of your personal data under the conditions laid down in Article 7 of the PDPL;
- Request notification of the rectification, erasure, or destruction processes to third parties to whom your personal data has been transferred;
- Object to any automated processing that results in an analysis solely focused on your behavior, if it produces a result against you;
- Claim compensation for damages if you incur losses due to the unlawful processing of your personal data.
Application Methods
To exercise your rights, you can submit your request by filling out our application form (available upon request) or by drafting a petition containing the mandatory elements required by the Communiqué on the Procedures and Principles of Application to the Data Controller (including name, surname, signature, Turkish ID/passport number, physical address, email address, phone number, and the subject of your request). You may send it to us via:
Written Application: Via a notary public, by registered mail (return receipt requested), or via hand delivery with wet signature to Nispetiye Mahallesi Petrol Sitesi Sokak 24.Blok 1AI daire:6 Beşiktaş İstanbul;
Electronic Application: By sending an email to support@mucoai.com using the email address currently registered in our system.
Your request will be reviewed and resolved by Huddle free of charge within the legal timeframe (at the latest within 30 days).
Explicit Consent Declaration
By checking the box provided on the registration screen of the Application, you declare that you have read and understood the Huddle Privacy Policy. You hereby give your free and explicit consent for your personal data (including your name, surname, business details, and—if optionally shared—your date of birth, phone number, and photo) to be transferred to third-party SaaS (Software as a Service), PaaS (Platform as a Service), and database providers located abroad. These providers are authorized by Huddle as data processors to ensure business continuity, maintain secure data storage, and conduct operational processes.
You have the right to withdraw this explicit consent at any time. You may do so by contacting us at support@mucoai.com.