1IDENTITY OF THE DATA CONTROLLER

Pursuant to Law No. 6698 on the Protection of Personal Data ("KVKK"), your personal data may be processed by Taiga Teknoloji Anonim Şirketi ("LUNAAR" or the "Company"), as the data controller, within the scope described below.

Data Controller: Taiga Teknoloji Anonim Şirketi

Address: Çifte Havuzlar Mah. Eski Londra Asfaltı Cad. Kuluçka Merkezi A1 Blok No 151, Yıldız Teknik Üniversitesi - Teknopark, Esenler / İstanbul

MERSIS No: 0816139800100001

2PURPOSES OF PROCESSING PERSONAL DATA

Your collected personal data may be processed for the following purposes within the framework of the personal data processing conditions specified in Articles 5 and 6 of the KVKK:

2.1 Service Provision and Performance of Contract

Creating and managing your user account on the LUNAAR platform
Providing AI-powered image processing and 3D modeling services
Managing the use of services through the credit system
Carrying out subscription and payment transactions
Handling customer service and technical support requests
Providing information and communication regarding our services

2.2 Fulfillment of Legal Obligations

Fulfilling the obligations under Law No. 6563 on the Regulation of Electronic Commerce
Keeping log records under Law No. 5651 on the Regulation of Publications Made on the Internet
Fulfilling the obligations under tax legislation
Protecting rights under consumer legislation
Fulfilling legal notification obligations to authorized public institutions and organizations

2.3 Within the Scope of Legitimate Interest

Improving service quality and enhancing the user experience
Ensuring system security and preventing fraudulent activities
Conducting statistical analyses and carrying out reporting activities
Managing and developing the technical infrastructure of the platform

2.4 Within the Scope of Explicit Consent

Carrying out marketing and campaign activities
Providing personalized content and recommendations
Using data for training AI models
Collecting data through cookies and similar technologies

3CATEGORIES OF PERSONAL DATA PROCESSED

Data Category	Description
Identity Information	First name, last name, username, date of birth
Contact Information	Email address, phone number
Financial Information	Billing address, payment history, credit balance
Customer Transaction Information	Service usage history, support requests, transaction records
Transaction Security Information	IP address, session information, log records
Marketing Information	Preferences, interests, campaign participation information
Visual and Audio Data	Uploaded images, generated content

4TRANSFER OF PERSONAL DATA

In line with the realization of the purposes specified above, your personal data may be transferred to the following groups of recipients in accordance with the conditions specified in Articles 8 and 9 of the KVKK:

4.1 Domestic Transfers

Business Partners: Payment service providers (iyzico), technical infrastructure providers
Suppliers: Customer service, email and SMS service providers
Authorized Public Institutions and Organizations: Upon request within the scope of legal obligations
Legal Advisors: For the purpose of conducting legal processes

4.2 International Transfers

Cloud Service Providers: For data hosting and processing services (AWS, Google Cloud)
Analytics Service Providers: For usage analytics (Google Analytics)

International data transfers are carried out, within the scope of Article 9 of the KVKK, to countries that provide adequate protection or on the condition that your explicit consent is obtained or standard contractual clauses are applied.

5METHODS OF COLLECTING PERSONAL DATA AND LEGAL GROUNDS

Your personal data is collected through the following methods and based on the following legal grounds:

5.1 Collection Methods

Membership forms via the website and mobile application
Customer service communication channels (email, phone, live support)
Cookies and similar technologies
During payment transactions
Automatically during the use of services

5.2 Legal Grounds

KVKK art. 5/2-a: Being explicitly stipulated in the laws
KVKK art. 5/2-c: Being necessary for the establishment or performance of a contract
KVKK art. 5/2-ç: The legal obligation of the data controller
KVKK art. 5/2-f: Being mandatory for our legitimate interests
KVKK art. 5/1: Your explicit consent

6RIGHTS OF THE DATA SUBJECT

Pursuant to Article 11 of the KVKK, as a personal data subject, you have the following rights:

To learn whether your personal data is being processed
To request information if your personal data has been processed
To learn the purpose of processing your personal data and whether it is used in accordance with its purpose
To know the third parties to whom your personal data is transferred domestically or abroad
To request the correction of your personal data in the event that it has been processed incompletely or inaccurately
To request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the KVKK
To request that the correction, deletion, or destruction operations be notified to third parties to whom your personal data has been transferred
To object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems
To request the compensation of the damage in the event that you suffer damage due to the unlawful processing of your personal data

7HOW CAN YOU EXERCISE YOUR RIGHTS?

To exercise the rights specified above, you may choose one of the following methods:

Email

You may apply to spark@lunaarvision.com together with documents verifying your identity.

Mail

You may send a wet-signed petition to the address "Çifte Havuzlar Mah. Eski Londra Asfaltı Cad. Kuluçka Merkezi A1 Blok No 151, Yıldız Teknik Üniversitesi - Teknopark, Esenler / İstanbul".

Platform

You may make a request via the "Privacy Settings" section of your LUNAAR account.

Information Required in the Application

Your application must include your first name, last name, your signature if the application is in writing, your T.R. identity number (passport number for foreigners), your residence or workplace address for notification purposes, your email address for notification if any, your phone number, and the subject of your request.

8NOTIFICATION OF APPLICATION RESULTS

Your applications will be finalized free of charge as soon as possible and within a maximum of 30 (thirty) days, depending on the nature of the request.

However, in the event that the operation requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board may be charged.

This Disclosure Statement has been prepared pursuant to Article 10 of Law No. 6698 on the Protection of Personal Data. By using LUNAAR services, you are deemed to have accepted that you have read and understood this disclosure statement.

KVKK Disclosure Statement