KVKK Disclosure Notice
Last updated
July 2026
Prepared under Article 10 of Law No. 6698 (KVKK).
This English translation is provided for convenience; the Turkish version prevails legally.
Pursuant to Article 10 of Law No. 6698 on the Protection of Personal Data and the Communiqué on the Obligation to Inform, Dahwo, in its capacity as data controller, hereby informs you of the following regarding the processing of your personal data.
Under the "Dahwo" brand, an AI-powered jewellery-imaging service is offered through dahwo.com. This notice explains, for the natural persons ("data subjects") who use the service, the purposes and legal bases on which the data controller processes personal data, the parties to whom it may be transferred, and the data subject’s rights.
The controller’s identity and application details appear in Section 8.
Identity and Contact
Email address; optional first and last name. If "Sign in with Google" is used, the basic profile information of the Google account.
Customer Transaction Data
Credit balance and usage, order and credit-grant records.
Visual Content
Product images you upload and the AI outputs generated.
Synthetic Model Definitions
The "model/persona" attribute selections you save — not data of any real person; the portraits are non-identifiable synthetic images.
Transaction Security / Technical
IP address (solely for rate limiting) and session data.
Support Data
The content of support requests and correspondence.
Payment-card details are not processed; payments are handled by Shopier, a payment institution established in Türkiye. EXIF/location metadata is stripped from uploaded images.
Your personal data is processed on the following legal bases set out in Article 5 of the KVKK:
| Purpose | Legal Basis (KVKK Art. 5/2) |
|---|---|
| Service delivery and account management | (c) Establishment or performance of the contract |
| Credit/order operations and transactional emails | (c) Performance of the contract; for receipts/invoices (ç) legal obligation |
| Retention of financial and commercial records | (ç) Legal obligation of the controller |
| Security, rate limiting and fraud prevention | (f) Legitimate interest |
| Customer support and complaint handling | (c) Performance of the contract and (f) legitimate interest |
The core service does not rely on consent; processing rests on the contract, legal-obligation and legitimate-interest bases above. Your explicit consent is sought separately, at sign-up, only for the cross-border transfer of your data (see Section 5). No advertising/tracking cookies or marketing profiling are used.
Your personal data is collected through dahwo.com in electronic form, by automated or non-automated methods, during account creation, payment, image upload, and site use. The legal basis for collection is the KVKK Article 5/2 grounds shown for each purpose in Section 3.
Your personal data may be transferred to third parties for the following purposes and only to the extent strictly necessary to provide the service:
Domestic transfer
Categories of cross-border recipients
Türkiye has not yet issued an adequacy decision for any country. Cross-border transfer is technically indispensable to delivering the service and is carried out under KVKK Art. 9 on the basis of the explicit consent given when creating your account; consent may be withdrawn at any time with prospective effect. Your personal data is not shared with third parties for advertising.
Your personal data is retained for as long as necessary for the purpose of processing and up to the maximum periods in the applicable legislation. Retention periods by data type are set out in a table in the "Retention Periods" section of the Privacy Policy. In summary: uploaded images and outputs are deleted after 30 days on Free/Starter packages; order/payment and invoice records are retained for 10 years as legally required. At the end of the period the data is deleted, destroyed, or anonymised.
As a data subject you have the following rights:
(a)
Learn whether your personal data is being processed
(b)
Request information about it, if it has been processed
(c)
Learn the purpose of processing and whether it is used in line with that purpose
(ç)
Know the third parties to whom it is transferred, domestically or abroad
(d)
Request correction if it has been processed incompletely or incorrectly
(e)
Request its deletion or destruction
(f)
Request that operations under (d) and (e) be notified to the third parties to whom the data was transferred
(g)
Object to a result against you arising from automated system analysis
(ğ)
Request compensation for damage you suffer due to unlawful processing
The identity and application details of the data controller are as follows:
To exercise the rights above, under the Communiqué on the Procedures and Principles of Application to the Data Controller, you may send an email with the subject "Data Subject Application" to destek@dahwo.com. For a wet-signed written application or an application by registered electronic mail (KEP), the current notification address will be provided to you upon request.
Your application must include:
Response time: Your request is concluded within at most 30 days, depending on its nature, and is generally free of charge. A fee may be charged, according to the tariff set by the Board, only in the exceptional cases specified in Article 7 of the Communiqué.
Right to complain: If you are not satisfied with the response to your application, or do not receive a response within 30 days, you have the right to lodge a complaint with the Personal Data Protection Board (the KVK Board).
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