KVKK Information Notice
This notice is provided under Article 10 of Turkish Personal Data Protection Law No. 6698 (KVKK) and the Communiqué on the Procedures and Principles of Fulfilling the Obligation to Inform. The Turkish text is the legally binding version.
1. Identity of the data controller
Data controller: Türkiye Profesyonel Futbolcular Derneği (TPFD, the Turkish Professional Footballers' Association), Istanbul.
Contact: info@pfd.org.tr · +90 212 259 93 94 · https://pfd.org.tr
Processor: Eray Baydemir (Bilgo AI), developer and technical operator of the TPFD member app and website, acting solely on the controller's instructions.
2. Personal data processed
- Identity: name, birth date.
- Contact: email address, phone number, city.
- Professional and sporting details: position, current and past clubs, player status (active, retired, amateur, etc.), optional licence number.
- Visual data: optional passport-style photo.
- Membership information: member number, membership status and validity date, application and review records. Membership of an association may be treated as special-category data under KVKK Article 6.
- Request and transaction data: benefit requests, messages, partner QR scan logs (time, browser information), AI call-session metadata.
- Voice data: streamed in real time during AI voice calls; not recorded by default.
Turkish national ID numbers are not processed.
3. Purposes
- Receiving and reviewing membership applications; creating and managing membership records.
- Issuing the digital member card and verifying membership at partner businesses.
- Receiving and following up on benefit requests.
- Answering support requests and AI support-line calls.
- Communicating with members and sending announcements within the association's purposes.
- Meeting legal obligations, ensuring information security and preventing misuse.
- With your explicit consent, sending campaign and event messages.
4. Recipients and cross-border transfers
For the purposes above, your data may be transferred to association management and authorised staff, to processors providing the technical infrastructure, and to public authorities where legally authorised.
Some infrastructure providers are located outside Türkiye, so your data is transferred abroad under KVKK Article 9:
| Recipient | Data transferred | Country |
|---|---|---|
| Supabase | Account, membership, application and request data and photos (storage) | Germany (EU) |
| Vercel | Website traffic (IP address, browser information) | US / global |
| LiveKit | Real-time audio stream in AI calls | Global infrastructure |
| OpenAI | Call audio and text (speech recognition, language model) | United States |
| ElevenLabs | Reply text (voice synthesis) | US / EU |
Transfers rely on one of the conditions in KVKK Article 9 and are accompanied by the required administrative and technical measures.
5. Method of collection and legal bases
Your data is collected electronically through the mobile app and website, from the forms you complete and automatically while you use the app.
Legal bases (KVKK Articles 5/2 and 6):
- Processing is directly related to establishing or performing a contract or membership relationship (Art. 5/2-c).
- Compliance with the controller's legal obligations, e.g. keeping a member register under association law (Art. 5/2-ç).
- The controller's legitimate interests, e.g. information security and preventing misuse (Art. 5/2-f).
- Explicit consent: processing of association-membership information as special-category data, transfer to providers abroad, and optional campaign messages (Art. 5/1, Art. 6).
6. Your rights under Article 11
By applying to the controller you may:
- learn whether your personal data is processed;
- request information about the processing;
- learn the purpose of processing and whether it is used accordingly;
- know the third parties to whom data is transferred at home or abroad;
- request correction of incomplete or inaccurate data;
- request erasure or destruction under Article 7;
- request that these operations be notified to third parties to whom data was transferred;
- object to a result against you arising from exclusively automated analysis;
- claim compensation for damage caused by unlawful processing.
7. How to apply
Send your request in writing with identifying information to the association's address, or email info@pfd.org.tr from the email address registered in the app. We conclude requests free of charge within 30 days at most, depending on their nature; if the process requires a separate cost, the tariff set by the Board may apply.
If you find the response insufficient, you may complain to the Personal Data Protection Board within 30 days of learning the response, and in any case within 60 days of applying.
Explicit Consent Statement (Açık Rıza Metni)
The explicit-consent checkbox on the membership application form in the app refers to this statement.
I acknowledge that I have been informed by the Turkish Professional Footballers' Association under the Information Notice above, and I give my explicit consent to:
- the processing of my membership application and membership information (membership status, member number, validity date, application and review records), being aware that it may qualify as special-category personal data, for conducting membership procedures, issuing my digital member card and verifying my membership at partner businesses;
- the transfer of this data and the other personal data I provide in my application to the service providers located outside Türkiye that operate the app's technical infrastructure (Supabase, Vercel, LiveKit, OpenAI, ElevenLabs) for the purposes stated in the Information Notice.
If you do not give this consent, your application may not be processed. You may withdraw your consent at any time with effect for the future by deleting your account in the app or writing to the association. Withdrawal does not affect the lawfulness of processing before withdrawal.
Permission for commercial messages (campaigns, events, announcements) is separate and optional; it is not a condition of your membership application.