Privacy & Data Protection Notice

Your personal data is processed within the framework described below by Eaglessoft BV, operator of the Riddle brand (the "Data Controller"), under the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the EU General Data Protection Regulation ("GDPR").

Adres / Address: Excelsiorlaan 31, 1930 Zaventem, België · E-posta / E-mail: info@eaglessoft.com · Tel: +32 456 73 59 66

The Turkish version of this notice is the authentic text; this English translation is provided for convenience.

• Identity and contact: full name (optional), e-mail address, phone number.
• Account and security: an irreversible hash of your password (bcrypt), your Google account ID if you sign in with Google, session records, IP address, request logs, failed login attempts.
• Customer activity: uploaded price lists, analysis results, favorites, settings; optionally entered bol.com Retailer API keys (stored encrypted) and the store/sales data retrieved with them.
• Invoicing and subscription: billing name, address, VAT number if any, subscription and payment history.
• Payments: payments are processed by the licensed payment institution Mollie. Card details such as card number, expiry date and CVC are never stored or logged on our systems; we keep only the customer and mandate reference numbers generated by Mollie.

• Concluding the membership agreement and providing the service (analyses, panel, data storage),
• Managing subscriptions, charges and statutory invoicing,
• Securing accounts and preventing abuse and unauthorized access,
• Sending service-related notifications such as password resets and trial reminders,
• Complying with legal obligations (tax and commercial law, responses to official requests),
• Measuring and improving service quality (aggregated and anonymized usage statistics).

We process your data based on: performance of a contract, compliance with legal obligations, establishment and protection of legal claims, and our legitimate interests provided your fundamental rights are not impaired (KVKK art. 5/2; GDPR art. 6). Where none of these apply, we ask for your explicit consent.

The Platform uses only the session cookie strictly necessary for the service to work (an httpOnly cookie holding your sign-in state) and your theme/language preferences in browser local storage. No advertising or third-party tracking cookies are used.

• Mollie B.V. (Netherlands) — payment processing,
• Google — authentication, only when you sign in with Google,
• Hetzner Online GmbH (Germany) — server and database hosting,
• E-mail delivery service (SMTP provider) — delivery of service notifications only,
• Competent public authorities — only where required by law.

Servers are located within the European Union. Transfers that qualify as international transfers from a Turkish perspective are carried out in line with the KVKK transfer rules and the GDPR. Your data is never sold to third parties.

• Account data: for the duration of the membership and a reasonable technical deletion window after account closure,
• Invoicing and payment records: for the statutory retention periods under tax and commercial law (even if the account is deleted),
• Security logs: for limited, rotating periods.

Expired data is deleted, destroyed or anonymized.

Under KVKK art. 11 (and GDPR arts. 15-22) you have the right to:

• learn whether your data is processed and request information,
• learn the purpose of processing and whether data is used accordingly,
• request correction of incomplete or inaccurate data,
• request erasure or destruction,
• learn the third parties to whom data is transferred,
• object to a result arising against you from analysis exclusively by automated systems,
• claim compensation for damage caused by unlawful processing.

You can send your request to info@eaglessoft.com; requests are answered free of charge within 30 days at the latest. You may also lodge a complaint with the Turkish Personal Data Protection Board or the data protection authority of your place of residence.

This notice may be updated when necessary; the current version is always published on this page and material changes are announced to members.