Privacy Policy

01

Definitions

Company / Starlecta

Starlecta FZCO, the company operating the Starlecta platform.

Customers

Brands, agencies, e-commerce marketplaces, and project owners holding the title of advertiser who use the Starlecta platform.

STARLECTA

An intelligence platform designed to enable Customers to discover, compare, and monitor Content Providers and/or Influencers by brand and by market.

Content Providers

Creative individuals who produce and publish content, advertise on social media platforms, and maintain an active social media engagement network.

02

Legal Basis for the Collection of Personal Data

The personal data of Content Providers and Customers is collected and processed in accordance with, first and foremost, the Constitution of the Republic of Turkey, Law No. 6698 on the Protection of Personal Data (“KVKK”), the provisions of other relevant legislation, the decrees of the Republic of Turkey, and other applicable regulations.

03

Methods of Collecting Personal Data and the Personal Data Collected

Starlecta processes personal data that has been made publicly available by Content Providers solely for use within the Starlecta platform and for the purpose of enabling collaboration, campaign matching, or market analysis between Content Providers and Customers. The personal data of Content Providers featured on the Starlecta platform is collected from the Content Providers' publicly accessible social media accounts that they themselves have made public. The personal data collected is organized according to the potential Content Provider accounts that Customers wish to collaborate with or are tracking for market analysis purposes. In this context, Starlecta carries out the relevant services once Customers select potential Content Providers to discover, compare, and monitor through the platform.

In this context, Starlecta collects and processes the following data from social media accounts with more than 1,000 followers, primarily on Instagram (with future expansion planned to other platforms such as TikTok, YouTube, etc.):

• The username and/or channel identity used by Content Providers on their social media accounts
• The social media accounts of Content Providers
• Number of followers
• Number of accounts followed
• The profile photo used by Content Providers on social media
• Number of content items shared
• Shared and publicly available content
• Texts and hashtags used in shared content
• The number of likes, comments, and views for shared content

Where a service agreement is executed with Customers, the personal data collected from Customers is as follows:

• Company title
• Full name of the authorized person
• E-mail address of the authorized person
• Phone number of the authorized person
• Financial information

Information we collect automatically:

• IP addresses
• Location data
• Cookies
• Browser type and version
• Time zone setting
• Operating system and platform
• Session records

04

Purposes of Processing Personal Data

The personal data collected under Article 3 is processed by the Company within the scope of the services it provides and its field of activity, in a manner compliant with the law and the principle of good faith, accurately, and up to date, and limited to these purposes. Such data is processed between Content Providers and Customers, limited and proportionate to the purpose for which it is processed, and retained only for the period stipulated by or necessary for that purpose, for the purpose of providing and carrying out content-provider discovery, comparison, market/brand monitoring, collaboration, and reporting services.

The Company will retain the personal data it collects from the social media accounts of Content Providers on the Starlecta platform for a period of 1 (one) year and will destroy it in accordance with applicable legislation at the end of that period.

05

Transfer of Your Personal Data

Personal data may be shared with the Company's business partners, customers, and domestic and foreign organizations from which cloud data storage services are procured, with whom the Company cooperates in order to carry out its services and activities, in accordance with Articles 8 and 9 of the KVKK.

Necessary technical and administrative measures are taken to prevent violations of rights during the transfer of data to third parties. The Company is not responsible for breaches occurring within the risk domain of third parties or arising from the data protection policies of third parties.

Customers using the Starlecta platform shall not share Content Provider information obtained through the platform with third parties. In the event it is determined that Content Provider information has been transferred to third parties by a Customer, any direct or indirect damages shall be compensated by the relevant Customer(s).

06

Rights of Data Subjects

As a data subject, you have the right to inquire whether your personal data is being processed, to request information about it if it is being processed, to inquire whether your personal data has been used in accordance with its purpose; and, if it has been transferred domestically or abroad, to request that it be corrected if processed incompletely or incorrectly, and, if you have suffered damage due to unlawful processing of your personal data, to request that such damage be remedied, and to request the erasure or destruction of your personal data.

To exercise the rights set out herein or to obtain information about the KVKK, you may submit your request by e-mail to legal@starlecta.com, or to the Starlecta address set out below, together with, if you are a citizen of the Republic of Turkey, your national identification number in addition to your name, surname, and signature, or, if you are not a citizen of the Republic of Turkey, your stated e-mail address and phone number, together with your permanent residence and business address, the subject matter of your request, and any information and documents necessary to verify your identity.

Your application will be reviewed by Starlecta and finalized free of charge within 30 (thirty) days.