KVKK Notice — Personal Data Protection
Son güncelleme: 12 Haziran 2026
KVKK Notice — Personal Data Protection
Effective date: June 12, 2026
This notice describes how Aquila Labs LLC ("Wair", "we", "us"), operating from Sheridan, WY 82801, USA, processes personal data of users located in Türkiye, in accordance with Law No. 6698 on the Protection of Personal Data ("KVKK").
Note: Wair is operated from the United States. KVKK applies where we process personal data of data subjects located in Türkiye. This notice supplements our global Privacy Policy.
1. Data controller
- Controller: Aquila Labs LLC
- Address: Sheridan, WY 82801, USA
- Contact: support@wair.llc
Aquila Labs LLC is established outside Türkiye. For correspondence in Turkish, please email support@wair.llc and we will respond in Turkish where reasonably practicable.
2. Personal data we process
We may process the following categories of personal data:
- Identity & contact data: name, email address (when you contact us or create an App account).
- Wardrobe & visual data (App): photographs of clothing items you upload, AI-generated metadata derived from them.
- Technical data: IP address, device model, operating system, app
version, language preference (
NEXT_LOCALEcookie), crash logs. - Communication data: the content of messages you send via the contact form or support email.
3. Purposes and legal grounds (KVKK Article 5)
| Purpose | Legal ground |
|---|---|
| Responding to contact-form inquiries | Performance of a contract / legitimate interest (Art. 5/2/c, 5/2/f) |
| Operating and improving the App | Performance of a contract (Art. 5/2/c) |
| Generating AI-based styling recommendations | Performance of a contract; explicit consent for AI processing of your photographs (Art. 5/2/c, 5/1) |
| Security, fraud prevention, abuse detection | Legitimate interest (Art. 5/2/f) |
| Compliance with legal obligations | Legal obligation (Art. 5/2/ç) |
Where we rely on explicit consent (e.g., processing of biometric-like visual data in your wardrobe photographs), you may withdraw consent at any time by deleting your account or emailing support@wair.llc.
4. Transfers abroad (KVKK Article 9)
Aquila Labs LLC is established in the United States. Your personal data is therefore transferred to and processed in the United States, and may be sub-processed by US-based providers (Supabase, Resend, and AI model providers).
The United States is not on the Turkish Personal Data Protection Authority's ("KVKK Kurulu") list of countries with adequate protection. We rely on the following safeguards:
- Contractual commitments with each processor requiring KVKK-compatible security measures.
- Encryption in transit (TLS) and at rest.
- Explicit consent of the data subject, where applicable (KVKK Art. 9/1).
By using Wair, you acknowledge that your personal data will be transferred to and processed in the United States.
5. Retention
- Contact form data: up to 24 months, then deleted.
- App account data: while the account is active; deleted on request.
- AI inference logs: anonymized after 30 days unless required for fraud investigation.
6. Your rights under KVKK Article 11
You have the right to:
- Learn whether your personal data is being processed
- Request information about the processing, if any
- Learn the purpose and whether it is used in accordance with the purpose
- Know the third parties (domestic or abroad) to whom data has been transferred
- Request correction of incomplete or inaccurate data
- Request deletion or destruction of your data
- Request notification of correction/deletion to third parties to whom data was transferred
- Object to results derived solely from automated analysis
- Claim compensation for damages caused by unlawful processing
To exercise any of these rights, send a written request to support@wair.llc with sufficient identifying information so we can locate your records. We will respond within 30 days as required by Article 13 of KVKK.
If you are not satisfied with our response, you may file a complaint with the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu) in Türkiye.
7. Security measures
- TLS encryption for all data in transit
- Encrypted-at-rest storage on Supabase
- Role-based access control with least-privilege defaults
- Logging and monitoring of access to personal data
- Regular review of vendor security practices
8. Children
The App is not directed to children under 16. We do not knowingly collect personal data from children. If you believe we have, please contact support@wair.llc.
9. Changes to this notice
We may revise this notice as our processing activities or KVKK guidance evolve. The "Effective date" at the top reflects the most recent revision.
10. Contact
Aquila Labs LLC Sheridan, WY 82801, USA Email: support@wair.llc