LEGAL
KVKK Privacy Notice
Version 2.0 · Effective: November 13, 2026
This is a translation; the Turkish text prevails.
1. Data controller and scope
This notice has been prepared in accordance with 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.
Data controller: Hertz Teknoloji Medya Yayıncılık Pazarlama ve Ticaret Anonim Şirketi ("Whispi")
Address: Esentepe Mah. Şehit Mehmet Mikdat Uluünlü Sk. Propa Plus Residence No: 26 İç Kapı No: 26 Şişli/İstanbul
MERSİS: 0462107776330001 · Tax No: 4621077763 (Zincirlikuyu Tax Office)
KVKK applications: kvkk@whispi.io
This notice covers everyone who visits whispi.io and its subdomains, sends a question, opens an account or uses our forms. Whispi is exempt from the obligation to register with VERBİS; this exemption does not remove its other KVKK obligations.
2. Personal data processed
Which data is processed depends on how you use the Service. Passwords are kept only as an irreversible digest; Whispi never stores your password in plain form.
| Group | Data processed |
|---|---|
| Every visitor | IP address, browser and device information, pages visited and the time (access logs), cookie preference, language and theme preference, Cloudflare Turnstile bot verification token, and, if you have consented to analytics cookies, Google Analytics' random cookie identifier |
| Guest asker | In addition to the above: a digest of the guest cookie, the question and follow-up texts sent, uploaded images and selected GIFs, the selected avatar, the IP address at the time the question is sent, acceptance of the Terms of Use and the declaration of being 18 or over (version and date) |
| Member | In addition to the above: email address, username, display name, bio, avatar and cover image, X and Instagram usernames and Spotify link, time zone, account settings, session information (IP and browser), questions received and answers given, questions asked, block list, karma points and streak information, notification preferences and push device registrations, acceptance of the Terms of Use and the declaration of being 18 or over (version and date), a digest of the Broadcast Mode link |
| Member who signs in with Google | Name, email address and profile picture from the Google account |
| Person who reports or is reported | The reason for the report and its note, the text of the reported content and its attachment links, the identity and IP address of the content's author |
| Form sender (contact, sponsorship, bug report) | Name, email address, message, optional screenshot, browser and operating system information |
Every visitor
- Data processed
- IP address, browser and device information, pages visited and the time (access logs), cookie preference, language and theme preference, Cloudflare Turnstile bot verification token, and, if you have consented to analytics cookies, Google Analytics' random cookie identifier
Guest asker
- Data processed
- In addition to the above: a digest of the guest cookie, the question and follow-up texts sent, uploaded images and selected GIFs, the selected avatar, the IP address at the time the question is sent, acceptance of the Terms of Use and the declaration of being 18 or over (version and date)
Member
- Data processed
- In addition to the above: email address, username, display name, bio, avatar and cover image, X and Instagram usernames and Spotify link, time zone, account settings, session information (IP and browser), questions received and answers given, questions asked, block list, karma points and streak information, notification preferences and push device registrations, acceptance of the Terms of Use and the declaration of being 18 or over (version and date), a digest of the Broadcast Mode link
Member who signs in with Google
- Data processed
- Name, email address and profile picture from the Google account
Person who reports or is reported
- Data processed
- The reason for the report and its note, the text of the reported content and its attachment links, the identity and IP address of the content's author
Form sender (contact, sponsorship, bug report)
- Data processed
- Name, email address, message, optional screenshot, browser and operating system information
Whispi does not collect date of birth, phone number, location or special categories of personal data (health, religion, political opinion, etc.). However, Users may share such information of their own will in their questions and answers; because this content is public, Whispi keeps it as part of the content. The location and device metadata of uploaded images is deleted at the moment of upload.
3. Purposes of processing and legal grounds
Your personal data is processed for the purposes below and on the basis of the legal grounds in Article 5 of the KVKK. The only processing based on explicit consent is analytics cookies (Google Analytics); all other processing is based on the legal grounds below.
| Purpose | Data | Legal ground (KVKK Art. 5/2) |
|---|---|---|
| Creating an account, signing in and managing the account | Email, username, password digest, Google profile information, session information | (c) Formation and performance of a contract |
| Receiving, answering, following up and publishing questions | Question, answer and follow-up texts, attachments, avatar | (c) Performance of a contract |
| Recording the asker's sender information | Account or guest number, IP address | (f) Legitimate interest: preventing abuse, enforcing blocks; (ç) Legal obligation: Law No. 5651 |
| Automated content moderation | Texts, conversation context, profile fields, images | (f) Legitimate interest: user safety; (ç) Legal obligation |
| Reviewing reports and imposing sanctions | Report record, content snapshot, the author's account or guest number and IP | (f) Legitimate interest; (e) Establishment and protection of a right |
| Blocks and IP bans | Account or guest number, IP address | (f) Legitimate interest: protection of the Profile Owner |
| Sending notifications (in-app, email, push) | Email, push registration, notification content | (c) Performance of a contract; preferences are managed in the settings |
| Broadcast Mode | Unanswered questions, the asker's avatar | (c) Performance of a contract with respect to the Profile Owner; (f) legitimate interest with respect to the asker, as notified in clause 8 of the Terms of Use |
| Bot verification and rate limits | IP address, Turnstile token | (f) Legitimate interest: security |
| Access logs and traffic data | Identity, IP, browser, time | (ç) Legal obligation: Law No. 5651 Art. 5 |
| Error tracking | Error records | (f) Legitimate interest: continuity of the service |
| Responding to form requests | Name, email, message, device information | (c) Pre-contractual steps taken on request; (f) Legitimate interest |
| Recording acceptance of the Terms of Use and the declaration of being 18 or over (members and guests) | Version, date | (e) Establishment and proof of a right |
| Responding to requests from competent authorities | The data concerned by the request | (a) Expressly provided for by law; (ç) Legal obligation |
| Showing ads | Total impression and click counts (not personal data) | — |
Creating an account, signing in and managing the account
- Data
- Email, username, password digest, Google profile information, session information
- Legal ground (KVKK Art. 5/2)
- (c) Formation and performance of a contract
Receiving, answering, following up and publishing questions
- Data
- Question, answer and follow-up texts, attachments, avatar
- Legal ground (KVKK Art. 5/2)
- (c) Performance of a contract
Recording the asker's sender information
- Data
- Account or guest number, IP address
- Legal ground (KVKK Art. 5/2)
- (f) Legitimate interest: preventing abuse, enforcing blocks; (ç) Legal obligation: Law No. 5651
Automated content moderation
- Data
- Texts, conversation context, profile fields, images
- Legal ground (KVKK Art. 5/2)
- (f) Legitimate interest: user safety; (ç) Legal obligation
Reviewing reports and imposing sanctions
- Data
- Report record, content snapshot, the author's account or guest number and IP
- Legal ground (KVKK Art. 5/2)
- (f) Legitimate interest; (e) Establishment and protection of a right
Blocks and IP bans
- Data
- Account or guest number, IP address
- Legal ground (KVKK Art. 5/2)
- (f) Legitimate interest: protection of the Profile Owner
Sending notifications (in-app, email, push)
- Data
- Email, push registration, notification content
- Legal ground (KVKK Art. 5/2)
- (c) Performance of a contract; preferences are managed in the settings
Broadcast Mode
- Data
- Unanswered questions, the asker's avatar
- Legal ground (KVKK Art. 5/2)
- (c) Performance of a contract with respect to the Profile Owner; (f) legitimate interest with respect to the asker, as notified in clause 8 of the Terms of Use
Bot verification and rate limits
- Data
- IP address, Turnstile token
- Legal ground (KVKK Art. 5/2)
- (f) Legitimate interest: security
Access logs and traffic data
- Data
- Identity, IP, browser, time
- Legal ground (KVKK Art. 5/2)
- (ç) Legal obligation: Law No. 5651 Art. 5
Error tracking
- Data
- Error records
- Legal ground (KVKK Art. 5/2)
- (f) Legitimate interest: continuity of the service
Responding to form requests
- Data
- Name, email, message, device information
- Legal ground (KVKK Art. 5/2)
- (c) Pre-contractual steps taken on request; (f) Legitimate interest
Recording acceptance of the Terms of Use and the declaration of being 18 or over (members and guests)
- Data
- Version, date
- Legal ground (KVKK Art. 5/2)
- (e) Establishment and proof of a right
Responding to requests from competent authorities
- Data
- The data concerned by the request
- Legal ground (KVKK Art. 5/2)
- (a) Expressly provided for by law; (ç) Legal obligation
Showing ads
- Data
- Total impression and click counts (not personal data)
- Legal ground (KVKK Art. 5/2)
- —
Whispi does not use your data for profiling or targeted advertising; ads are not chosen per person. It does not send emails for marketing purposes. It uses Google Analytics for site usage statistics; this only works if you give explicit consent by ticking the analytics option in the cookie notice (KVKK Art. 5/1), and you can withdraw your consent at any time. The details are in the Cookie Policy.
4. The anonymous asker's identity
Your questions are anonymous towards the Profile Owner and other users; they only see the avatar you chose. A question's sender information consists of: the Whispi account it was sent from, or, if it was sent without an account (as a guest), a random guest number assigned to your browser; and in both cases your IP address. Whispi does not ask for or store official identity information such as a national ID number. For the security of the Service and legal obligations, when you send a question, the system records the question's sender information.
The use of this information, and its limits, are as follows:
- It is used so that the Profile Owner can block you; the Profile Owner blocks you without seeing the sender information.
- In the event of a report review or a request from a competent authority, the Whispi team can see from the admin panel from which account or guest number a question was sent. Your email and IP address are masked by default in the panel, and every access is logged.
- Sender information is never passed on to notifications, data export files or the Profile Owner.
- Your IP address in question and follow-up records is deleted automatically after 30 days. If you have been the subject of a report or a moderation record, your IP address is kept in that record for 1 year.
- Sender information is shared only upon duly made requests from public prosecutors, courts and other authorities empowered by law. "Who asked" requests from Profile Owners are not fulfilled.
5. Automated content moderation and automated decisions
Every question, answer, follow-up message, username, display name, bio and uploaded image goes through AI-based moderation before it is published. The moderation is carried out by an OpenAI model provided through the Bedrock service of Amazon Web Services, Inc. (410 Terry Ave North, Seattle, USA), acting as a data processor on Whispi's behalf. Sender information and your email are not sent to moderation; only the content and (for answers and follow-ups) the latest messages of the conversation are sent. Texts containing a phone number or an email address are rejected on Whispi's servers without being sent to moderation.
Moderation has two automated outcomes that affect you directly:
- Rejection of content. The content is not published and you are shown the reason category. The rejected text is kept for 1 year, together with its context and sender information, in a record accessible to the Whispi team.
- Hiding of the page from search engines. If moderation flags content as "needs review", the content is published, a review record is opened for the team and the page is hidden from external search engines, regardless of your settings and without notifying you.
Automated moderation never suspends or bans an account; only the Whispi team makes such decisions. Under KVKK Art. 11/1-g, if you believe that a result to your detriment has arisen from analysis carried out exclusively by automated systems, you can object through kvkk@whispi.io or support@whispi.io and ask for the decision to be reviewed by a person; objections are concluded within 15 days at the latest.
GIFs are not moderated by Whispi; the provider Klipy's own content filter applies.
6. Parties to whom data is transferred
Within Türkiye, your data is transferred only to public institutions and organisations with legal authority (prosecutors, courts, BTK, the Personal Data Protection Authority) upon a duly made request. Public content can, by its nature, be seen by all visitors and search engines.
Transfers abroad are made by signing the Standard Contract (controller to processor) announced by the Board under KVKK Art. 9 and notifying it to the Board. These contracts have been signed with Google Cloud and Amazon Web Services and notified to the Board. Cloudflare, Hostinger and Klipy are global service providers that do not offer the standard contract announced by the Board; the relationship with these recipients is based on their data processing agreements under the European Union General Data Protection Regulation (GDPR), independent security certifications and the technical limitations set out in the table below. All recipients are data processors acting on Whispi's behalf; they cannot use your data for their own purposes.
| Recipient | Purpose | Data transferred | Country / region | Safeguard |
|---|---|---|---|---|
| Google Cloud EMEA Limited (70 Sir John Rogerson's Quay, Dublin 2, Ireland) | Servers, database, file storage, system logs | All data | Belgium (europe-west1) | Standard Contract 2 |
| Cloudflare, Inc. | Traffic proxy, CDN, TLS, bot verification (Turnstile) | All traffic (content passes in clear because encryption is terminated at Cloudflare), IP address | Global network, headquartered in the USA | Data processing agreement (DPA) under the GDPR and EU Standard Contractual Clauses; Cloudflare's own ISO 27001 and SOC 2 certifications; data is not stored at Cloudflare, only processed in transit |
| Amazon Web Services, Inc. (USA) | Automated content moderation (Bedrock) | Texts, conversation context, profile fields, images | Called from Frankfurt; processing may take place in any AWS region | Standard Contract 2 |
| Amazon Web Services, Inc. (USA) | Email delivery (SES) | Email address, notification content (question text, answer preview) | USA (us-east-1) | Standard Contract 2 |
| Hostinger | support@ mailbox | Form contents, daily report summary, KVKK applications | Lithuania / EU | Data processing agreement (DPA) under the GDPR; data is processed within the European Union |
| Klipy | GIF search and display | From the server: search text, language, anonymous client identifier. From the browser: the IP and browser information of anyone viewing a GIF (GIFs are loaded directly from Klipy) | Abroad | Data sent from Whispi's server is not personal data; GIFs are loaded by your browser directly from Klipy, and that connection is governed by Klipy's own privacy policy |
| Google, Apple, Mozilla push services | Web push notifications | Only the device address and the time of sending; content is end-to-end encrypted | Depending on the browser vendor | Browser standard (RFC 8291); content cannot be read |
| Google LLC | Sign in with Google | Name, email and profile picture from your Google account (flows from Google to Whispi) | USA | A sign-in started by you; Google's own privacy policy |
| Google LLC (Google Analytics 4) | Site usage statistics | Page view and interaction events, approximate location, device and browser information, random cookie identifier; no identity, email or content is sent | USA | Your explicit consent (KVKK Art. 5/1); no IP address is processed, no identity or content is sent, Google Signals and advertising features are off; consent can be withdrawn at any time |
Google Cloud EMEA Limited (70 Sir John Rogerson's Quay, Dublin 2, Ireland)
- Purpose
- Servers, database, file storage, system logs
- Data transferred
- All data
- Country / region
- Belgium (europe-west1)
- Safeguard
- Standard Contract 2
Cloudflare, Inc.
- Purpose
- Traffic proxy, CDN, TLS, bot verification (Turnstile)
- Data transferred
- All traffic (content passes in clear because encryption is terminated at Cloudflare), IP address
- Country / region
- Global network, headquartered in the USA
- Safeguard
- Data processing agreement (DPA) under the GDPR and EU Standard Contractual Clauses; Cloudflare's own ISO 27001 and SOC 2 certifications; data is not stored at Cloudflare, only processed in transit
Amazon Web Services, Inc. (USA)
- Purpose
- Automated content moderation (Bedrock)
- Data transferred
- Texts, conversation context, profile fields, images
- Country / region
- Called from Frankfurt; processing may take place in any AWS region
- Safeguard
- Standard Contract 2
Amazon Web Services, Inc. (USA)
- Purpose
- Email delivery (SES)
- Data transferred
- Email address, notification content (question text, answer preview)
- Country / region
- USA (us-east-1)
- Safeguard
- Standard Contract 2
Hostinger
- Purpose
- support@ mailbox
- Data transferred
- Form contents, daily report summary, KVKK applications
- Country / region
- Lithuania / EU
- Safeguard
- Data processing agreement (DPA) under the GDPR; data is processed within the European Union
Klipy
- Purpose
- GIF search and display
- Data transferred
- From the server: search text, language, anonymous client identifier. From the browser: the IP and browser information of anyone viewing a GIF (GIFs are loaded directly from Klipy)
- Country / region
- Abroad
- Safeguard
- Data sent from Whispi's server is not personal data; GIFs are loaded by your browser directly from Klipy, and that connection is governed by Klipy's own privacy policy
Google, Apple, Mozilla push services
- Purpose
- Web push notifications
- Data transferred
- Only the device address and the time of sending; content is end-to-end encrypted
- Country / region
- Depending on the browser vendor
- Safeguard
- Browser standard (RFC 8291); content cannot be read
Google LLC
- Purpose
- Sign in with Google
- Data transferred
- Name, email and profile picture from your Google account (flows from Google to Whispi)
- Country / region
- USA
- Safeguard
- A sign-in started by you; Google's own privacy policy
Google LLC (Google Analytics 4)
- Purpose
- Site usage statistics
- Data transferred
- Page view and interaction events, approximate location, device and browser information, random cookie identifier; no identity, email or content is sent
- Country / region
- USA
- Safeguard
- Your explicit consent (KVKK Art. 5/1); no IP address is processed, no identity or content is sent, Google Signals and advertising features are off; consent can be withdrawn at any time
7. Retention periods
Data is kept for the period necessary for the purpose and the period required by law; when the period ends, it is deleted, destroyed or anonymised.
| Data | Retention period |
|---|---|
| Account information, profile, settings, questions received and answers | Until the account is deleted; permanently at the moment of deletion |
| Questions and follow-ups asked to others | Until that Profile Owner deletes them; anonymised when the account is deleted |
| IP address in questions and follow-ups | 30 days |
| Session records (IP, browser) | At sign-out, password change or account deletion; expired sessions are cleared within 30 days |
| An asker's IP block | 30 days |
| IP ban imposed by the team | Length of the ban (1–365 days) + 30 days |
| Report records and automated moderation reports (text, context, sender information) | 1 year |
| Guest cookie record | 1 year from last use; acceptance of the Terms of Use and the declaration of being 18 or over are kept with this record |
| In-app notifications | 90 days |
| Data export file | 7 days |
| Form submissions (contact, sponsorship, bug) | 1 year |
| Acceptance of the Terms of Use, declaration of being 18 or over and cookie consent preference (with date) | Until the account is deleted |
| Reserved username | 30 days |
| Access logs (account, IP, browser) | 1 year (Law No. 5651 Art. 5) |
| Error tracking records | 90 days |
| Database and file backups | 7 days |
| Team action logs | 13 months |
Account information, profile, settings, questions received and answers
- Retention period
- Until the account is deleted; permanently at the moment of deletion
Questions and follow-ups asked to others
- Retention period
- Until that Profile Owner deletes them; anonymised when the account is deleted
IP address in questions and follow-ups
- Retention period
- 30 days
Session records (IP, browser)
- Retention period
- At sign-out, password change or account deletion; expired sessions are cleared within 30 days
An asker's IP block
- Retention period
- 30 days
IP ban imposed by the team
- Retention period
- Length of the ban (1–365 days) + 30 days
Report records and automated moderation reports (text, context, sender information)
- Retention period
- 1 year
Guest cookie record
- Retention period
- 1 year from last use; acceptance of the Terms of Use and the declaration of being 18 or over are kept with this record
In-app notifications
- Retention period
- 90 days
Data export file
- Retention period
- 7 days
Form submissions (contact, sponsorship, bug)
- Retention period
- 1 year
Acceptance of the Terms of Use, declaration of being 18 or over and cookie consent preference (with date)
- Retention period
- Until the account is deleted
Reserved username
- Retention period
- 30 days
Access logs (account, IP, browser)
- Retention period
- 1 year (Law No. 5651 Art. 5)
Error tracking records
- Retention period
- 90 days
Database and file backups
- Retention period
- 7 days
Team action logs
- Retention period
- 13 months
8. Data security
In line with KVKK Art. 12 and the Board's Personal Data Security Guide, Whispi applies the following measures: storing passwords only as an irreversible digest, and guest, Broadcast Mode and share link tokens as digests; protecting traffic with TLS and keeping data encrypted on disk; httpOnly and Secure cookies; CSP and HSTS security headers; IP- and account-based rate limits for sign-in, questions, uploads and email; removing metadata from uploaded images; and not writing message content or email addresses to system logs.
Access to the admin panel requires two-step verification (TOTP), sessions expire after 12 hours, re-verification is required for critical actions, email and IP addresses are masked by default and every action of the team is written to an unalterable log.
In the event of a data breach, Whispi notifies the Board within 72 hours at the latest after becoming aware of the breach, in accordance with KVKK Art. 12/5, and informs the persons affected as soon as possible.
9. Your rights and how to apply
Under KVKK Art. 11 you have the right to: learn whether your personal data is processed; request information if it has been processed; learn the purpose of processing and whether it is used in line with that purpose; know the third parties to whom it is transferred in Türkiye or abroad; request rectification if it has been processed incompletely or inaccurately; request its erasure or destruction within the framework of the legal conditions; request that these actions be notified to the third parties to whom it was transferred; object to a result to your detriment arising from analysis exclusively by automated systems; and claim compensation if you suffer damage because of unlawful processing.
Within the app: Members can correct their profile information in the settings, download a copy of their data as a ZIP and delete their account. The ZIP file does not include IP addresses, session history, consent records, notifications or reports; for these, use the channel below.
Applications: In accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, you can apply by email to kvkk@whispi.io or in writing to the address in section 1, together with information that verifies your identity. Your application is concluded free of charge within 30 days at the latest. This channel is open to everyone, including suspended users and guests.
If your application is rejected, the answer is found insufficient or no answer is given in time, you can file a complaint with the Personal Data Protection Board.
This notice is version 2.0 and is effective as of November 13, 2026. Changes are announced in three ways: a new processing purpose, a new recipient or a change that narrows your rights, with your explicit acceptance on the screen shown at sign-in; other significant changes, with an in-app notification or announcement; and corrections to spelling, links and contact details, only by updating the version and date on this page.
For any questions, please use the Contact page or write to support@whispi.io.