Privacy Policy
This Privacy Policy explains how Furkan Türkan (sole proprietorship), who provides pinqloq ("we", "us", "our"), processes personal data. "You" means the person whose personal data is concerned: for example an Admin, a Team Member, a visitor to our website or someone who writes to us. This policy is our information notice under Article 10 of Law No. 6698 on the Protection of Personal Data ("KVKK") and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform, and under Articles 13 and 14 of the EU General Data Protection Regulation ("GDPR") and of the UK GDPR.
It covers our website pinqloq.pinqponq.io, the web Dashboard, the Live Panel, the MCP Server, the ingest service that receives Log Records from our SDKs, the e-mails we send and our checkout, which opens in a checkout window in the Dashboard or on our checkout page. It does not cover how our customers use personal data in the Log Records they send to pinqloq; section 3 explains what applies to that data.
Capitalised words, such as Account, Admin, Team Member, Collection, Log Records, Balance and Automatic Top-up, have the meaning given in our Terms of Service. This Privacy Policy gives you information. It is not part of the Terms of Service, and you are not asked to agree to it.
Contents: 1. Who is responsible; 2. Our role; 3. If your data is in our customers' Log Records; 4. Personal data we process; 5. Purposes and legal bases; 6. Automated decisions; 7. Who receives personal data; 8. Processing outside Türkiye; 9. How long we keep data; 10. Cookies and browser storage; 11. Security; 12. Your rights; 13. Complaints; 14. Children; 15. E-mails we send; 16. Personal data breaches; 17. California residents; 18. Changes to this policy; 19. Contact.
1. Who is responsible
We are the data controller for the personal data described in this policy, except for personal data in Log Records (section 2). Our details are:
| Legal name | Furkan Türkan (sole proprietorship) |
|---|---|
| Brand | pinqloq, a pinqponq product |
| Tax office and number | Kartal Tax Office, 8761221802 |
| Address | Cevizli Mah. Zühal Cad. A Ticari Blok Apt. No:46/50, Maltepe / Istanbul, Türkiye |
| [email protected] | |
| Phone | +382 68 655 482 |
| Website | https://pinqloq.pinqponq.io |
For any question about this policy or about your personal data, write to [email protected].
2. Our role
- We are the controller of the account, Team Member, sign-in, billing, payment, acceptance, Automatic Top-up consent, support, security, diagnostic and website data described in section 4. We decide why and how this data is processed.
- We are a processor of the personal data in Log Records. The customer that sends the Log Records is the controller of that data (or a processor acting for its own client), and we process it only on the customer's instructions under the Data Processing Addendum in Annex A of our Terms of Service.
- Paddle, our reseller and Merchant of Record, is a separate and independent controller of the personal data it collects in its checkout and of the data it processes for its own purposes, such as payments, fraud prevention, tax and its own legal obligations. Paddle's processing is described in the Paddle Privacy Notice.
- AI clients and other tools that you or your company connect to pinqloq with an MCP Key are chosen by you or your company. Their providers process the data they receive under their own terms.
3. If your data is in our customers' Log Records
Our customers use pinqloq to record what happens in their own applications. If your personal data is in Log Records that one of our customers sent to pinqloq, that customer decides what is recorded, why, and for how long it is kept. Please contact that customer to use your rights. If you contact us, we pass your request on to the customer where we can identify it, and we help the customer respond as our Data Processing Addendum requires. We do not use Log Records for our own purposes, except to measure the volume each Collection receives in order to apply limits and to operate and secure the Service.
4. Personal data we process
We collect personal data electronically: through the registration form, the Dashboard and the Live Panel, through the SDKs and the ingest service, through our website, the checkout window in the Dashboard and our checkout page, by e-mail and other messages, and through the notifications and responses we receive from Paddle.
| Category | What it includes | Source |
|---|---|---|
| Account data | The Admin's e-mail address, the company name, the Admin's role and language setting, whether the Account and the Admin are active, and when they were created. | You, when you register. |
| Team Member data | The Team Member's e-mail address, Live Panel password (kept in the user store as a hash; see Diagnostic records), the Collections the Team Member may see and whether the Team Member is active. For each device signed in to the Live Panel: a device identifier, the device name, and when the session was created, last seen and expires. The name of a Team Member's MCP Key, which contains the Team Member's e-mail address. The same data is processed for an Admin who sets a Live Panel password. | The Admin who adds the Team Member; the device used to sign in to the Live Panel. Our Terms of Service require the Admin to tell each Team Member about this Privacy Policy before giving them access, and the sign-in page of the Live Panel links to it. |
| Sign-in and security data | Single-use sign-in codes (kept in our sign-in store as a hash for 5 minutes; see Diagnostic records) and the timing of code requests; refresh tokens (kept in our database as hashes) with their expiry and revocation; the IP address of requests, which we process to apply rate limits; hashes of Ingest Keys and MCP Keys, their last three characters and when they were last used. | Your use of the Service. |
| Billing data | The Balance and ledger entries (type, amount, description and time), Billing Periods, subscription, suspension and cancellation status, the names of Projects and Collections, Retention Periods, prices and the amounts charged or credited. | Your use of the Service. |
| Billing details you choose to enter | The type of billing party (individual, company or foreign), its legal name, e-mail address, phone number and address; for a company, its tax number and tax office; for a foreign billing party, its VAT number and country. For an individual billing party we do not ask for a national identification number. The tax number of a company can be the T.C. identity number of its owner, for example for a sole proprietorship. These details are kept with your Account and shown to its Admins in Billing. They are not sent to Paddle, are not used for the invoices Paddle issues, and we do not use them for any other purpose. | You, in Billing in the Dashboard. |
| Payment data from Paddle | Your Paddle customer identifier and the e-mail address of that customer record; subscription identifiers and status, including the $0 subscription used for the Authorization; payment method type, card brand, last four digits and expiry date, including those of the payment methods saved at Paddle; transaction identifiers, amounts, tax, totals and invoice numbers; refund and chargeback records; and the full content of Paddle's notifications to us, which can include a name, address, billing country, tax number and card details as Paddle sends them. We keep the full content of notifications only as section 9 states. | Paddle. |
| Acceptance records | When an Admin registers: the Admin, the version of the Terms of Service the Admin accepted and the version of this Privacy Policy the Admin confirmed having read, the time (UTC), the IP address recorded for the request and the browser user agent. When an Admin starts a Top-up or an Authorization: the same data for the Terms of Service that apply at that time, together with the order reference. Confirming that you have read this Privacy Policy is not consent to the processing of personal data. | You, when you register or start a Top-up or an Authorization. |
| Automatic Top-up consent records | The user who gave the consent, the version of the consent text, the time of the consent and of its withdrawal, the IP address recorded for the request, the browser user agent, the Fixed Amount, the Monthly Limit and, for a consent given together with an Authorization, the order reference of that Authorization's Paddle checkout. When a consent is withdrawn, only the time of withdrawal is added. | You, when you authorize, turn on or change Automatic Top-up. See Automatic top-up authorization in our Terms of Service. |
| Communications | E-mails and other messages you send us, including by phone, WhatsApp or Viber if you use them, and our replies; withdrawal notices submitted with "Withdraw from contract here" in Billing in the Dashboard, which contain the name you enter, any details you add, the time of submission and the e-mail address of the Admin who submits the notice; records of the service e-mails we send to an Account (type, time and delivery status). | You, including through the Dashboard; our systems. |
| Diagnostic records | Records of requests to our Dashboard API and of actions and errors in the Dashboard, as described in Diagnostic records below. | Your use of the Dashboard. |
| Website and checkout data | The IP address and request details (such as the page requested, the time and the browser user agent) that our web servers and Cloudflare, the network and security service in front of them (section 7), process to deliver and protect our pages; the cookies and browser storage described in section 10; in the checkout window in the Dashboard and on the checkout page, the payment and device data that Paddle's script collects under the Paddle Privacy Notice. | Your browser; Paddle. |
| Usage measurement data | What Google Analytics records on our website and in the Dashboard (section 10): the pages and Dashboard screens opened, clicks on the buttons that lead to the Dashboard, the page you came from, your browser, device and language, and an approximate location that Google derives from your IP address; in the Dashboard, also that a registration form was submitted or a sign-in was completed, that a checkout was started and of which kind, with the amount of a Top-up, that a payment failed or was completed and, for a completed Top-up, Paddle's transaction identifier, the amount, the tax and the currency. It does not include your name, e-mail address, company name or any Log Record. Only if you accept analytics cookies does it include the identifier kept in those cookies. | Your browser. |
| Log Records | Any personal data that our customers include in the Log Records they send. | Our customers, through the SDKs and the ingest service. We process this data as a processor (section 3). |
We never receive full card numbers or card security codes. You enter payment details in Paddle's checkout, and Paddle handles them.
Diagnostic records
When the Dashboard is used, our Dashboard API records each request and its response, including the path, the status, the request and response headers and bodies (each cut off at 32 KB) and the user identifier of the signed-in Admin. While an Admin is signed in, the Dashboard also records the name of each action taken in it and the errors that occur, together with the Admin's e-mail address, the company name, the browser's user agent, a random identifier that the Dashboard creates each time it is opened and keeps only in memory, and the app version.
These records can therefore include e-mail addresses, company names, the names of Projects and Collections, amounts, error messages, and request headers, which can include your browser's user agent and your IP address. The values of the requests and responses that carry single-use sign-in codes, access or refresh tokens, Live Panel passwords, Ingest Keys, MCP Keys, billing details, withdrawal notices or operator credentials are masked before they are recorded, and the values you type into Dashboard forms are not recorded with the actions. Records made by earlier versions of the Dashboard could also include values entered in Dashboard forms and requests, such as billing details, single-use sign-in codes, keys and passwords set for Team Members; we delete those records promptly after the release of this version, and in any case as section 9 states. We send these records into our own pinqloq Account, where they are stored like other Log Records. We use them only to find and fix faults and to keep the Service secure, and they are not shown to Admins. Notifications from Paddle to our payment endpoint are not recorded in this way.
Do you have to give us your data?
Your e-mail address and a company name are needed to create an Account, and your e-mail address is needed to sign in. Accepting our Terms of Service is needed to create an Account and to start a Top-up or an Authorization, and we keep the acceptance records described above. Payment details are needed only if you top up, and Paddle collects them. Billing details are optional; if you choose to save them, the Dashboard asks for the fields required for the type you select. For an individual billing party it does not ask for a national identification number; the tax number of a company can be the T.C. identity number of its owner. Team Member data is needed only if an Admin gives someone access to the Live Panel. If you do not provide the data a feature needs, you cannot use that feature.
5. Purposes and legal bases
Under the GDPR and the UK GDPR we rely on these legal bases: performance of a contract or steps before entering into one (Article 6(1)(b)), compliance with a legal obligation under the law of the European Union, a Member State or the United Kingdom (Article 6(1)(c)) and our legitimate interests (Article 6(1)(f)). Where the table names Article 6(1)(b) and you act for a business customer rather than being our customer yourself, we rely on Article 6(1)(f) instead, and our legitimate interest is to perform our contract with that customer.
Under Article 5(2) of the KVKK we rely on these conditions: processing is necessary for the conclusion or performance of a contract, provided it concerns the personal data of the parties to the contract (c); it is necessary to comply with our legal obligations (ç); it is necessary to establish, exercise or protect a right (e); or it is necessary for our legitimate interests, provided it does not harm your fundamental rights and freedoms (f). Where the table names Article 5(2)(c) and you act for a business customer rather than being our customer yourself, we rely on Article 5(2)(f) instead. For Team Members, who are not parties to our contract, we rely on Article 5(2)(f).
We rely on your consent (Article 6(1)(a) of the GDPR and the UK GDPR; explicit consent under Article 5(1) of the KVKK) only for the analytics cookies described in section 10. You can withdraw it at any time there, which does not affect the processing done before. We do not rely on consent for any other processing described in this policy.
| Purpose | Personal data | Legal basis |
|---|---|---|
| Creating and running the Account: registration, sign-in, sessions, roles and language | Account data; sign-in and security data | GDPR and UK GDPR: Article 6(1)(b). KVKK: Article 5(2)(c). |
| Giving Team Members access to the Live Panel and managing their devices and MCP Keys | Team Member data | GDPR and UK GDPR: Article 6(1)(f). KVKK: Article 5(2)(f). |
| Providing billing: the Balance, Monthly Charges, Paid Changes, billing history and access to Paddle's invoices | Billing data; payment data | GDPR and UK GDPR: Article 6(1)(b). KVKK: Article 5(2)(c). |
| Top-ups, refunds, chargebacks and payment disputes, including checking each payment with Paddle | Payment data; billing data | GDPR and UK GDPR: Article 6(1)(b), and Article 6(1)(f) for handling disputes and defending legal claims. KVKK: Article 5(2)(c) and (e). |
| Keeping evidence of your Automatic Top-up authorization | Automatic Top-up consent records; payment data | GDPR and UK GDPR: Article 6(1)(b) to charge Automatic Top-ups as you authorized, and Article 6(1)(f) to be able to prove the authorization. KVKK: Article 5(2)(c) and (e). This consent is your authorization of payments under our Terms of Service. It is not consent to data processing under data protection law. |
| Proving that the Agreement was concluded, which version of our terms and of this notice applied, and that the pre-contract information was confirmed | Acceptance records; account data | GDPR and UK GDPR: Article 6(1)(f). KVKK: Article 5(2)(ç), for our obligations under the Regulation on Distance Contracts, and (e). |
| Handling withdrawals, terminations and refund requests | Communications; account data; billing data; payment data | GDPR and UK GDPR: Article 6(1)(b), and Article 6(1)(c) where the law of the European Union, a Member State or the United Kingdom requires it. KVKK: Article 5(2)(c) and (ç). |
| Keeping the accounting, tax and commercial records that Turkish law requires | Billing data; payment data | GDPR and UK GDPR: Article 6(1)(f), our legitimate interest in complying with the Turkish laws that govern our business. KVKK: Article 5(2)(ç). |
| Letting the customer keep the billing party's details it chooses to record with its Account, so that its Admins can see and update them in Billing | Billing details | GDPR and UK GDPR: Article 6(1)(f). KVKK: Article 5(2)(f). |
| Sending service e-mails: sign-in codes, copies of the Terms of Service and Refund Policy you accepted, balance and payment notices, notices and confirmations about Automatic Top-up, confirmations of cancellations and withdrawals, and notices of changes to our terms | Account data; billing data; payment data; communications | GDPR and UK GDPR: Article 6(1)(b), Article 6(1)(c) for confirmations that the law of the European Union, a Member State or the United Kingdom requires, and Article 6(1)(f) for notices of changes. KVKK: Article 5(2)(c), (ç) and (f). |
| Delivering the website, the Dashboard with its checkout window, and the checkout page | Website and checkout data | GDPR and UK GDPR: Article 6(1)(b) for the Dashboard, and Article 6(1)(f) for the website. KVKK: Article 5(2)(c) and (f). |
| Measuring how our website and the Dashboard are used, and which visits lead to a registration or a Top-up, with Google Analytics | Usage measurement data | GDPR and UK GDPR: Article 6(1)(a) for the analytics cookies and the identifier kept in them; Article 6(1)(f) for measurement without cookies. KVKK: Article 5(1) for the analytics cookies; Article 5(2)(f) for measurement without cookies. |
| Keeping the Service secure, preventing abuse and applying rate limits | Sign-in and security data; website and checkout data | GDPR and UK GDPR: Article 6(1)(f). KVKK: Article 5(2)(f). |
| Finding and fixing faults | Diagnostic records | GDPR and UK GDPR: Article 6(1)(f). KVKK: Article 5(2)(f). |
| Answering questions, support requests and complaints | Communications; account data; billing data | GDPR and UK GDPR: Article 6(1)(b) where the request concerns our contract with you, otherwise Article 6(1)(f). KVKK: Article 5(2)(c) and (f). |
| Establishing, exercising or defending legal claims, and answering requests from courts and authorities | The data relevant to the matter | GDPR and UK GDPR: Article 6(1)(f), and Article 6(1)(c) where the law of the European Union, a Member State or the United Kingdom requires it. KVKK: Article 5(2)(ç) and (e). |
| Processing Log Records for our customers | Log Records | We act as a processor. The customer decides the legal basis (section 3). |
Our legitimate interests and why they are balanced
- Performing our contract with a business customer: we use only the data needed to give the people the customer authorizes access to the Service it has bought.
- Giving Team Members access: the Admin of the customer the Team Member works with decides who gets access and to which Collections, and we use the data only for that access.
- Handling disputes and proving payments and authorizations: we keep these records securely and use them only when a question, refund, chargeback or legal claim arises.
- Proving that the Agreement was concluded: acceptance records contain only the data needed to show who accepted which version of our terms and confirmed reading which version of this notice, when, from which IP address and browser and, for a Top-up or an Authorization, for which order. We use them only when a question, complaint or legal claim about the Agreement arises, and we delete the IP address and browser user agent 3 years after the Account is closed.
- Keeping billing details: entering them is optional and is done by the customer; in the Dashboard they are shown only to the Admins of the Account; they are not shared with Paddle; and for an individual billing party we do not ask for a national identification number.
- Complying with Turkish law: we keep only the records that law requires, for the periods in section 9.
- Notices of changes: we send them only to the Admins of the Account and only about the Service, so that you can decide what to do before a change applies.
- Security, abuse prevention and rate limits: we process IP addresses and request data only for this purpose, and a secure Service protects you as well as us.
- Delivering the website: request data is processed only to deliver the pages you ask for.
- Measuring use without cookies: unless you accept analytics cookies, Google Analytics stores and reads nothing on your device and receives no identifier that would link one page or visit to another, and we use the result only as statistics about our website and the Dashboard.
- Finding and fixing faults: diagnostic records are used only for this purpose, are kept within our own systems, are not shown to Admins and are deleted automatically as section 9 states.
Your right to object. Where we process your personal data on the basis of our legitimate interests (Article 6(1)(f) of the GDPR or the UK GDPR), you have the right to object at any time, on grounds relating to your particular situation, by writing to [email protected]. We will then stop that processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or we need the data to establish, exercise or defend legal claims.
6. Automated decisions
We do not use personal data for profiling. Some decisions in the Service are made automatically by applying our Terms of Service. For example, log intake is suspended when a Monthly Charge is still unpaid 3 days after the first failed attempt; an Automatic Top-up is not charged when it would not fit within what is left of your Monthly Limit or when the Fixed Amount cannot cover the amount due; a Paid Change is refused when the Balance is too low; and repeated sign-in code requests and attempts are limited. These decisions are necessary to perform our contract and follow rules you can read in our Terms of Service.
You can ask for any such decision to be reviewed by a person by writing to [email protected]. You can also give your point of view and contest the decision. Paddle may make its own automated decisions, for example to prevent fraud, as the Paddle Privacy Notice explains.
7. Who receives personal data
- Paddle. Paddle.com Market Limited (United Kingdom), or Paddle.com Inc. for buyers in the United States and Paddle.com (Canada) Ltd. for buyers in Canada, and the other Paddle group companies named in the Paddle Privacy Notice, each as an independent controller. When a payment or an Authorization is started, we send Paddle the sign-in e-mail address of the Admin who starts it, so that Paddle can create or find your customer record, together with our internal identifier of your Account, the order identifier and purpose, and the amount. For a refund we send the transaction, the amount and the reason. When you delete a saved payment method or end an Authorization, we send that instruction to Paddle. Paddle collects your payment details, billing address, country and any tax number directly in its checkout, and sends us the payment data described in section 4. See the Paddle Privacy Notice.
- Contabo, our hosting provider. Contabo GmbH, Welfenstrasse 22, 81541 Munich, Germany, hosts the servers on which the Service runs, including our databases and the backup copies of our systems, in data centres in its European Union region. It processes the personal data in our systems, including Log Records, on our behalf.
- Cloudflare, our network and security service. Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, United States, operates the network through which all traffic to and from our website, the Dashboard, the Live Panel, the MCP Server and the ingest service passes. The encrypted connection from your browser or application ends at Cloudflare, so Cloudflare processes the full content of each request and response, including IP addresses, request headers, sign-in codes, account and billing data and Log Records, before passing it on. It does so on our behalf, to deliver the Service and protect it.
- Google, our e-mail service provider. We send and receive the e-mails of our pinqponq.io addresses, including [email protected], with Google Workspace, which Google Cloud EMEA Limited, 70 Sir John Rogerson's Quay, Dublin 2, Ireland, provides to customers in Europe, the Middle East and Africa. Google processes, on our behalf, the addresses and content of the e-mails we send, including sign-in codes and the documents attached to them, and of the e-mails you send us.
- Google, our analytics provider. Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, provides Google Analytics and processes the usage measurement data (section 4) on our behalf. We have not turned on Google's advertising features, and we do not let Google Analytics use this data for advertising.
- Messaging services. If you choose to contact us through WhatsApp or Viber, the provider of that service processes your messages, phone number and account details under its own terms and privacy policy.
- The Admins of your company's Account can see the Team Members, the Collections allowed to them, their Live Panel devices and MCP Keys, the billing details, the billing history and the Automatic Top-up settings of the Account. Admins do not see the diagnostic records.
- AI clients and other tools that you or your company connect with an MCP Key receive the Log Records that key allows.
- Courts and public authorities, where the law requires us to disclose data or where disclosure is needed to establish, exercise or defend legal claims.
- Professional advisers, such as lawyers, accountants and auditors, who are bound by confidentiality.
- A successor to our business, if the business is transferred, who may use the data only as this Privacy Policy describes.
We do not sell personal data, and we do not share it for cross-context behavioural advertising.
8. Processing outside Türkiye
We are established in Türkiye, and we operate the Service and access our systems from Türkiye. Personal data is also processed in the following places:
- European Union. Our servers and databases, and the backup copies of our systems, are hosted by Contabo GmbH, a company established in Germany, in data centres in its European Union region. The personal data in our databases, including Log Records, is stored there. Clause 10.6 of our Terms of Service describes this infrastructure and the law it is subject to.
- Countries where Cloudflare operates. Cloudflare, Inc. is established in the United States and operates data centres in many countries, including the United States and Türkiye. The traffic to and from our website and services may be processed in any of them.
- Countries where Google operates. Google may process and store our e-mails and the usage measurement data of Google Analytics in any country where Google or its sub-processors have facilities, including the United States.
- United Kingdom, United States and Canada. Paddle.com Market Limited is established in the United Kingdom, for which the European Commission has adopted an adequacy decision. Paddle's affiliates in the United States and Canada process personal data under the Paddle Privacy Notice and are responsible for their own transfers.
The European Commission and the United Kingdom have not adopted an adequacy decision for Türkiye. When you give us personal data directly, for example when you register or write to us, we protect it as this Privacy Policy describes, wherever it is processed.
Cloudflare processes personal data protected by the GDPR, the UK GDPR or the Swiss Federal Act on Data Protection under its Data Processing Addendum, which forms part of Cloudflare's customer agreement. For the transfers it covers, that addendum includes the standard contractual clauses approved by the European Commission, the UK International Data Transfer Addendum and adaptations for Switzerland. Cloudflare also states that it is certified under the EU-U.S. Data Privacy Framework, the UK Extension to it and the Swiss-U.S. Data Privacy Framework.
Transfers of personal data from Türkiye to other countries are subject to Article 9 of the KVKK, and transfers from the European Economic Area, the United Kingdom and Switzerland are subject to the transfer rules of the GDPR, the UK GDPR and Swiss law. You can ask us at [email protected] where your personal data is stored and which transfer mechanism applies to a particular recipient, and we will tell you. For Log Records, the transfer terms of the Data Processing Addendum in our Terms of Service apply.
If you contact us through WhatsApp or Viber, the provider of that service may process your messages outside Türkiye under its own terms.
9. How long we keep data
We keep personal data only as long as the purposes in section 5 require, for the periods below. When a period ends, we delete or anonymise the data.
| Data | How long |
|---|---|
| Log Records | For the Retention Period of their Collection (3 to 364 days), counted from each record's date. Deleted at once when the Collection or its Project is deleted, and deleted when the Account is closed. Suspension of an Account does not extend a Retention Period. |
| Account data, Team Member data, billing details and records of the service e-mails we sent | While the Account exists. A Team Member's data and MCP Key are deleted when an Admin deletes the Team Member, except Live Panel device records, which are deleted as the next row states. After the Account is closed, deleted or anonymised within 30 days, except data that is part of the records listed below, which is kept as stated for those records. Copies of this data in diagnostic records are deleted as stated for diagnostic records. |
| Live Panel device records | Deleted automatically when the device's session expires, which under our current settings is 30 days after the session was last renewed, or earlier when the device signs out or is removed in the Dashboard. |
| Sign-in codes | 5 minutes in our sign-in store. A code can also appear in diagnostic records made by earlier versions of the Dashboard, which we delete promptly after the release of this version, and in any case as stated for diagnostic records. |
| Dashboard refresh tokens | Deleted 30 days after they expire. |
| Payment, billing, ledger, refund, chargeback and Paddle records | Until the end of the tenth calendar year after the year in which the record was created, and longer while a dispute or legal claim about it is pending. We keep them this long because Turkish law requires accounting and tax records to be kept (for 5 years under Article 253 of the Tax Procedure Law, and for 10 years under Article 82 of the Turkish Commercial Code where it applies) and because claims about payments can be brought for up to 10 years (Article 146 of the Turkish Code of Obligations). |
| Acceptance records | Until the end of the tenth calendar year after the year in which the Account is closed (Article 146 of the Turkish Code of Obligations), and longer while a dispute or legal claim is pending. The IP address and browser user agent are deleted 3 years after the Account is closed, unless a dispute about them is pending. |
| Automatic Top-up consent records | Until the end of the tenth calendar year after the year in which the Authorization ended, because claims about the payments it authorized can be brought for up to 10 years (Article 146 of the Turkish Code of Obligations), and longer while a dispute or legal claim about it is pending. The IP address and browser user agent in a consent record are deleted 3 years after the Authorization ended, unless a dispute about it is pending. |
| Full content of Paddle's notifications | Emptied automatically once 30 days have passed since the notification was processed or set aside as not relevant; a record of its identifier, type and outcome is kept with the payment records. A notification that needs review by us keeps its full content for as long as the review needs it. |
| Diagnostic records | Deleted automatically once they are 30 days old, under the retention period set for those records in our own pinqloq Account. They are not deleted early when an Account is closed. |
| Support correspondence, complaints and withdrawal notices | 3 years after the matter is closed, and longer while a legal claim about it is pending. |
| Server process logs | Only as long as needed to operate and secure the Service. |
| Usage measurement data | In Google Analytics, for the retention period set in our Google Analytics property, which is at most 14 months; statistics that no longer relate to a visit or a browser are kept longer. |
| Browser storage | As described in section 10. |
| Backup copies | Backup copies of our systems are kept with Contabo, our hosting provider, in the same European Union region as our servers (section 8). Data deleted from our systems remains in those copies only until they are replaced in the normal backup cycle. We do not use deleted data held in backup copies to restore data for customers or for any other purpose. |
Cancelling the subscription does not close the Account: while the Account exists, its account and billing data are kept. You can ask us to close the Account at any time, as Closing your Account by e-mail in our Terms of Service explains. Before you ask, retrieve any Log Records you need, because deleted Log Records cannot be restored.
10. Cookies and browser storage
The cookies we set ourselves are the two sign-in cookies below and, only if you accept them, the analytics cookies of Google Analytics. Our website, the Dashboard and the Live Panel also use your browser's local storage, session storage and cache storage for the other items below. Except for the analytics cookies, each cookie and item is strictly necessary to provide the website or a feature of the Dashboard or the Live Panel that you use, so we do not ask for your consent to them. We do not use advertising scripts on our website, in the Dashboard or in the Live Panel, and we do not use analytics in the Live Panel or on the checkout page.
Google Analytics. Our website and the Dashboard load Google's analytics script from www.googletagmanager.com to measure how they are used (section 4). Our website asks whether you accept analytics cookies. Until you accept, and if you decline, Google Analytics sets and reads no cookies and stores nothing in your browser: each page sends its measurements to Google with a random number made for that page alone, which cannot link it to another page or visit. If you accept, it sets the analytics cookies below, which let Google Analytics recognise your browser on later visits to pinqloq.pinqponq.io. The Dashboard does not ask again: it follows the choice you made on our website. You can change your choice at any time: . Declining removes the analytics cookies.
| Item | Purpose | How long |
|---|---|---|
| pinqloq_refresh (cookie of our Dashboard API, pinqloq-dashboard-backend.pinqponq.io) | Keeps you signed in to the Dashboard. It holds your refresh token, with which the Dashboard obtains a new access token; the access token is kept only in the memory of the open page. The cookie is HttpOnly, so no script on the page can read it. It is sent only over HTTPS, only to the sign-in functions of the Dashboard API (path /auth) and not with requests that other websites start (SameSite=Strict). | Until your session ends, which under our current settings is 7 days after you signed in or after the Dashboard last renewed your session. Removed when you sign out. |
| pinqloq_panel_refresh (cookie of our Live Panel API, pinqloq-panel-backend.pinqponq.io) | Keeps you signed in to the Live Panel on the device you use. It holds the refresh token of the device's session, with which the Live Panel obtains a new access token; the access token is kept only in the memory of the open page. The cookie is HttpOnly, so no script on the page can read it. It is sent only over HTTPS, only with requests to path /api/Auth of the Live Panel API, which the Live Panel uses to sign you in, renew and end the session and fetch the list of Collections you may see, and not with requests that other websites start (SameSite=Strict). | Until the device's session expires, which under our current settings is 30 days after you signed in or after the Live Panel last renewed the session. Removed when you sign out. |
| _ga, _ga_GTJ2XZY4DR (analytics cookies of pinqloq.pinqponq.io, set only if you accept them) | Hold a random identifier of your browser and the state of your current visit, so that Google Analytics can count visitors and visits. | 2 years after your last visit. Removed when you decline analytics cookies. |
| pinqloq.analytics.consent (local storage of our website and the Dashboard, pinqloq.pinqponq.io) | Remembers whether you accepted or declined analytics cookies. | Until you clear your browser storage. |
| USER_EMAIL, COMPANY_NAME, IS_LOGGED_IN (local storage of the Dashboard, pinqloq.pinqponq.io) | Keep the details of your Dashboard sign-in: your e-mail address, company name and whether you are signed in. Our home page reads the signed-in flag to show the right button. | Removed when you sign out, or when the Dashboard finds that your session has ended. |
| APP_LANGUAGE (local storage of the Dashboard) | Remembers the language of the Dashboard. | Until you clear your browser storage. |
| PENDING_PAYMENTS (local storage of the Dashboard) | Remembers a Top-up, Authorization or payment method change you started, so that the Dashboard can show its result. | Removed when you sign out, when the Dashboard finds that your session has ended, or when the payment is resolved; an entry is discarded in any case after 24 hours for a Top-up and after 2 hours for an Authorization or a payment method change. |
| pinqloq-sdk (local storage, home and documentation pages) | Remembers the SDK you selected in the code examples. | Until you clear your browser storage. |
| pinqloq.checkout.return (session storage) | Hands the result of a checkout on our checkout page back to the Dashboard. | Removed when the Dashboard reads it, and in any case when you close the browser tab. |
| IS_LOGGED_IN (local storage of the Live Panel, pinqloq-panel.pinqponq.io) | Remembers whether you are signed in to the Live Panel. | Removed when you sign out, or when the Live Panel finds that your session has ended. |
| GENERATED_PLATFORM_IDENTIFIER (local storage of the Live Panel) | A random identifier that the Live Panel creates for your browser when it is opened and sends with its requests as the device identifier, so that the session of your device can be kept and managed and counted towards the limit of 3 devices per user. | Removed when you sign out, or when the Live Panel finds that your session has ended; the Live Panel then creates a new one when it next needs it. |
| compose_web_resources_cache (cache storage of the Dashboard and of the Live Panel) | Keeps copies of the app's own text, font and image files that the Dashboard or the Live Panel has loaded, so that the open page does not download them again. It holds no personal data. | Emptied and filled again each time you open the Dashboard or the Live Panel; otherwise kept until you clear your browser's site data. |
Earlier versions of the Dashboard and the Live Panel kept your access token and refresh token in local storage under the names TOKEN and REFRESH_TOKEN. The current versions keep the refresh token only in the cookies above and the access token only in memory. If they find TOKEN or REFRESH_TOKEN in your browser, they remove them together with the other sign-in items above, and you sign in again.
Paddle's script is not loaded when you open the Dashboard. When you start a Top-up, an Authorization or a change of payment method, the Dashboard loads Paddle's script from cdn.paddle.com and shows Paddle's checkout in a checkout window over the Dashboard; once loaded, the script stays in that page until you reload or close it. Our checkout page, which opens from Paddle's payment links and e-mails, and in place of the checkout window when that window cannot be used, loads the same script to show the same checkout. Paddle's script and checkout may set their own cookies or use similar browser storage, and may collect device and browser information, for example to process the payment and to prevent fraud. Paddle does this under the Paddle Privacy Notice. Cloudflare, the network and security service in front of our website and services (section 7), may set strictly necessary security cookies, such as __cf_bm or cf_clearance, when it needs to check that a request is legitimate, for example to manage automated traffic. Cloudflare describes these cookies in its own documentation and states that it may process cookie data in its data centre in the United States.
Earlier versions of the Dashboard also stored a random identifier for your browser in the Dashboard's local storage under the name GENERATED_PLATFORM_IDENTIFIER and sent it with diagnostic records. The current Dashboard no longer stores or uses it, and removes it from your browser the next time you use the Dashboard while signed in. The Live Panel's item of the same name, described above, is separate and is not sent with diagnostic records.
You can remove these items at any time by signing out and clearing your browser's cookies and site data for pinqponq.io, the domain of all the addresses above. If you block cookies or browser storage, you cannot stay signed in to the Dashboard or the Live Panel.
Do Not Track. We do not track your activity across other websites, and we do not use advertising services on our website, in the Dashboard or in the Live Panel. Google Analytics recognises your browser on later visits to our own website and Dashboard only if you accept analytics cookies, as described above. In the checkout window in the Dashboard and on the checkout page, Paddle may collect information under its own Privacy Notice, as described above. Our website, the Dashboard and the Live Panel do not respond differently to Do Not Track signals.
11. Security
We protect personal data with technical and organisational measures appropriate to the risk. They include:
- HTTPS for our website, with HTTP Strict Transport Security, and HTTPS for our API;
- authentication for every Dashboard API function that is not deliberately public, and a check that every request reaches only the data of its own Account;
- sign-in to the Dashboard with single-use codes sent by e-mail, which are valid for 5 minutes, allow a limited number of attempts and are kept in our sign-in store as hashes;
- rate limits on sign-in and on other requests;
- Ingest Keys and MCP Keys that are generated randomly, shown only once, kept in our key store as hashes and can be revoked or regenerated at any time;
- Live Panel passwords kept in the user store as PBKDF2 hashes, and Dashboard refresh tokens kept in our database as hashes, replaced on each use and revoked if a used token is presented again;
- in the web Dashboard and the Live Panel, refresh tokens held only in HttpOnly cookies that scripts on the page cannot read, and access tokens kept only in memory (section 10);
- masking of sign-in codes, tokens, passwords, keys, billing details, withdrawal notices and operator credentials in our diagnostic records;
- Team Member access limited to the Collections an Admin allows;
- verification of the signature of every notification from Paddle, and confirmation of each payment directly with Paddle before any Balance is credited;
- automatic deletion of Log Records at the end of their Retention Period; and
- payment card numbers and card security codes never reaching our systems.
No system is completely secure. If you believe you have found a security vulnerability, please report it to [email protected].
12. Your rights
Depending on the law that applies to you, you have the following rights.
Under the GDPR and the UK GDPR
- Access: to know whether we process your personal data and to receive a copy of it with information about the processing.
- Rectification: to have inaccurate data corrected and incomplete data completed.
- Erasure: to have your data deleted where the law provides for it.
- Restriction: to have the processing of your data restricted in the cases the law sets out.
- Portability: to receive the data you provided to us, which we process by automated means on the basis of a contract, in a structured, commonly used and machine-readable format, and to have it sent to another controller where this is technically feasible.
- Objection: to object to processing based on our legitimate interests (see your right to object).
- Automated decisions: not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, except as the law allows, and to obtain human review of it (section 6).
- Withdrawal of consent: where processing is based on consent, to withdraw it at any time without affecting the lawfulness of earlier processing. We do not currently rely on consent for any processing described in this policy.
Under Article 11 of the KVKK
You have the right to:
- learn whether your personal data is processed;
- request information about the processing if your personal data has been processed;
- learn the purpose of the processing and whether your personal data is used in line with that purpose;
- know the third parties in Türkiye or abroad to whom your personal data is transferred;
- request the correction of your personal data if it is incomplete or inaccurate;
- request the deletion or destruction of your personal data under the conditions in Article 7 of the KVKK;
- request that a correction, deletion or destruction be notified to the third parties to whom your personal data was transferred;
- object to a result against you that arises from the analysis of your personal data exclusively by automated systems; and
- claim compensation for damage you suffer because your personal data was processed unlawfully.
How to use your rights
Send your request by e-mail to [email protected], preferably from the e-mail address registered on the Account, or in writing to our postal address in section 1. Applications under the KVKK may also be made by the other methods that the Communiqué on the Procedures and Principles of Application to the Data Controller allows. You may write in English or Turkish. An application under the KVKK should include your name and surname; if you are a Turkish citizen, your T.C. identity number, or otherwise your nationality and your passport or identity number; your address for notices; your e-mail address or phone number; and what you are asking for. For any other request, please tell us who you are, how we can contact you and what you are asking for.
We may ask you to confirm your identity before we act on a request, for example by replying from the e-mail address registered on the Account. We answer free of charge within 30 days of receiving your request. Some rights have limits: for example, we must keep payment and billing records for the periods in section 9 even if you ask us to delete them, and we tell you if a limit applies.
An Admin can also update or delete some data directly in the Dashboard, such as billing details, Team Members, their Live Panel devices, keys, Collections and Projects.
For personal data that Paddle holds as an independent controller, you can also contact Paddle directly at [email protected] or through preferences.paddle.com. For personal data in Log Records, see section 3.
13. Complaints
You can complain to us about how we process your personal data by writing to [email protected]. We acknowledge your complaint within 5 business days, take appropriate steps without undue delay and tell you the outcome within 30 days of receiving it.
You also have the right to complain to a data protection supervisory authority:
- in the European Union and the European Economic Area, to the supervisory authority of the country where you live, where you work or where the alleged infringement took place (see the list of authorities);
- in the United Kingdom, to the Information Commissioner's Office;
- in Türkiye, to the Personal Data Protection Board.
Under the GDPR and the UK GDPR, you do not have to contact us before you complain to a supervisory authority. Under Article 14 of the KVKK, you can complain to the Personal Data Protection Board after applying to us: if we reject your application, if you find our answer insufficient or if we do not answer in time, you may complain within 30 days of the date you learn of our answer, and in any case within 60 days of the date of your application.
14. Children
The Service is not directed to children. You must be at least 18 years old to create an Account. We do not knowingly process personal data of children under 16 as Admins or Team Members. If we learn that we have, we will delete it. Personal data in Log Records is the responsibility of our customers (section 3).
15. E-mails we send
We send only the service e-mails needed to provide the Service:
- Your sign-in code, to the Admin address that requested it;
- Your agreement documents, with the Terms of Service, the Refund Policy and the model withdrawal form attached, when an Account is created and each time a new version of the Terms of Service is accepted;
- Transaction failed: insufficient balance, sent when a Monthly Charge or a Paid Change cannot be paid from the Balance;
- Your balance is running low and critically low warnings;
- Payment received, after a Top-up or an Automatic Top-up is completed;
- Automatic top-up not charged, when an Automatic Top-up is declined or not charged under our Terms of Service;
- Automatic payments confirmed, when the Authorization becomes active while Automatic Top-up is on, when Automatic Top-up is turned on and when its Fixed Amount or Monthly Limit is changed while it is on;
- Automatic payments reminder, once a year while Automatic Top-up is on, from 45 days before the $0 authorization subscription renews until that renewal, stating the Fixed Amount and the Monthly Limit, that nothing is charged for the $0 renewal, and how to turn automatic payments off;
- Automatic payments turned off, when the Authorization ends because of an event at Paddle or a payment dispute;
- Cancellation received, when an Admin cancels the subscription in the Dashboard;
- Subscription ended, when a cancellation takes effect; and
- Withdrawal received, to the Admin who submits a withdrawal notice with "Withdraw from contract here" in Billing.
Except for the sign-in code and "Withdrawal received", which go only to the Admin concerned, these e-mails go to every active Admin of the Account. We also e-mail Admins about changes to our terms and about other important matters concerning the Account. We do not send marketing e-mails. If we ever offer them, we will ask for your separate consent first, and you will be able to unsubscribe at any time. Paddle may send you its own e-mails about payments, such as receipts, under its own terms.
16. Personal data breaches
If a personal data breach affects personal data we control, we notify the Personal Data Protection Board and the people affected as Article 12 of the KVKK and the Board's decisions require, and we notify the competent supervisory authorities and the people affected as the GDPR and the UK GDPR require. If a breach affects Log Records, we notify the customer as our Data Processing Addendum requires.
17. California residents
If you live in California: section 4 describes the categories of personal information we collect, and section 7 the categories of third parties with whom we share it; section 12 explains how you can review your personal information and ask us to correct it; section 18 explains how we tell you about changes to this policy; and section 10 explains how we respond to Do Not Track signals and whether other parties may collect information about your online activities through our website. The date at the top of this page is the effective date of this policy. We do not sell personal information and do not share it for cross-context behavioural advertising.
18. Changes to this policy
We may update this Privacy Policy, for example when the Service or the law changes. We publish the current version on this page with its "Last updated" date. If we make a material change, we tell the Admins of each Account by e-mail before the change takes effect.
19. Contact
For questions about this Privacy Policy or your personal data, contact us:
| [email protected] | |
| Post | Furkan Türkan (pinqloq), Cevizli Mah. Zühal Cad. A Ticari Blok Apt. No:46/50, Maltepe / Istanbul, Türkiye |
| Phone | +382 68 655 482 |