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.

GroupData processed
Every visitorIP 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 askerIn 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)
MemberIn 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 GoogleName, email address and profile picture from the Google account
Person who reports or is reportedThe 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.

PurposeDataLegal ground (KVKK Art. 5/2)
Creating an account, signing in and managing the accountEmail, username, password digest, Google profile information, session information(c) Formation and performance of a contract
Receiving, answering, following up and publishing questionsQuestion, answer and follow-up texts, attachments, avatar(c) Performance of a contract
Recording the asker's sender informationAccount or guest number, IP address(f) Legitimate interest: preventing abuse, enforcing blocks; (ç) Legal obligation: Law No. 5651
Automated content moderationTexts, conversation context, profile fields, images(f) Legitimate interest: user safety; (ç) Legal obligation
Reviewing reports and imposing sanctionsReport 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 bansAccount 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 ModeUnanswered 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 limitsIP address, Turnstile token(f) Legitimate interest: security
Access logs and traffic dataIdentity, IP, browser, time(ç) Legal obligation: Law No. 5651 Art. 5
Error trackingError records(f) Legitimate interest: continuity of the service
Responding to form requestsName, 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 authoritiesThe data concerned by the request(a) Expressly provided for by law; (ç) Legal obligation
Showing adsTotal 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:

  1. 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.
  2. 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.

RecipientPurposeData transferredCountry / regionSafeguard
Google Cloud EMEA Limited (70 Sir John Rogerson's Quay, Dublin 2, Ireland)Servers, database, file storage, system logsAll dataBelgium (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 addressGlobal network, headquartered in the USAData 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, imagesCalled from Frankfurt; processing may take place in any AWS regionStandard 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
Hostingersupport@ mailboxForm contents, daily report summary, KVKK applicationsLithuania / EUData processing agreement (DPA) under the GDPR; data is processed within the European Union
KlipyGIF search and displayFrom 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)AbroadData 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 servicesWeb push notificationsOnly the device address and the time of sending; content is end-to-end encryptedDepending on the browser vendorBrowser standard (RFC 8291); content cannot be read
Google LLCSign in with GoogleName, email and profile picture from your Google account (flows from Google to Whispi)USAA sign-in started by you; Google's own privacy policy
Google LLC (Google Analytics 4)Site usage statisticsPage view and interaction events, approximate location, device and browser information, random cookie identifier; no identity, email or content is sentUSAYour 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.

DataRetention period
Account information, profile, settings, questions received and answersUntil the account is deleted; permanently at the moment of deletion
Questions and follow-ups asked to othersUntil that Profile Owner deletes them; anonymised when the account is deleted
IP address in questions and follow-ups30 days
Session records (IP, browser)At sign-out, password change or account deletion; expired sessions are cleared within 30 days
An asker's IP block30 days
IP ban imposed by the teamLength of the ban (1–365 days) + 30 days
Report records and automated moderation reports (text, context, sender information)1 year
Guest cookie record1 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 notifications90 days
Data export file7 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 username30 days
Access logs (account, IP, browser)1 year (Law No. 5651 Art. 5)
Error tracking records90 days
Database and file backups7 days
Team action logs13 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.