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TürkçePrivacy Policy & Personal Data Notice
Last updated: 06.09.2026
1. Data Controller
The websites www.projekurdu.com and www.projectworm.com and the ProjeKurdu mobile applications (together, the "Platform") are operated by Smart Coders LLC ("Company"), located in Irvine, California, USA. Both websites run on the same membership system: your account, and the profile and listing content you choose to publish, are available on both websites. Your personal data is processed by the Company as data controller under Turkish Law No. 6698 on the Protection of Personal Data ("KVKK") as described below. If you use the Platform from the European Economic Area (EEA), Switzerland or the United Kingdom, the General Data Protection Regulation (GDPR) or the corresponding national law applies in addition; the relevant details are in Section 8. Contact: hello@projectworm.com
2. Personal Data Processed
- Identity and account data: full name, username, account type (client / professional), profile photo.
- Contact data: e-mail address, country; telephone number and address if you add them to your profile.
- Profile and professional data: skills, portfolio, experience, rate expectations and other information you add to your profile.
- Verification documents: identity and proof-of-address documents you upload while the identity-verification feature is active.
- Financial data: wallet balance and transaction records, payment receipts, payout method details (IBAN, account name, SWIFT, etc.).
- Security and log data: IP address, session and traffic logs, device/app information, push notification token and language preference.
- Platform content: project posts, proposals, messages, reviews, support requests.
- Data collected via cookies (see the Cookie Policy).
The Platform does not request a Turkish national identity (T.C. Kimlik) number for membership or use.
3. Purposes and Legal Bases
| Purpose | Legal basis (KVKK Art. 5) |
|---|---|
| Creating and managing membership; matching clients with professionals; providing Platform services | Formation and performance of a contract (Art. 5/2-c) |
| Operating the secure (escrow) payment flow, issuing payment receipts, processing withdrawal requests | Performance of a contract (Art. 5/2-c); legal obligation (Art. 5/2-ç) |
| Keeping traffic records under Law No. 5651; tax and commercial-law obligations; responding to requests from competent authorities | Legal obligation (Art. 5/2-ç) |
| Platform security, fraud and abuse prevention, running the dispute-resolution process | Legitimate interest (Art. 5/2-f) |
| Sending mandatory service notices (transactions, security, contract changes) | Performance of a contract (Art. 5/2-c) |
| Sending commercial electronic messages (campaigns, announcements) | Explicit consent (Art. 5/1) — withdrawable at any time |
| Measuring and improving service quality; statistics | Legitimate interest (Art. 5/2-f) |
4. Transfers
Your personal data may be transferred, to the extent required, to payment and banking service providers, hosting and IT infrastructure providers, and — where legally required — to competent public authorities and courts.
As the Company is located in the USA, your data may also be processed and stored abroad. Such processing and transfers are carried out under Article 9 of the KVKK, on the basis of your informed explicit consent or the other mechanisms provided by the legislation.
5. Retention
Your personal data is kept for the duration of your membership and, after it ends, for the limitation and mandatory retention periods under applicable law (e.g. traffic records under Law No. 5651 and financial records under tax and commercial legislation). At the end of these periods your data is deleted, destroyed or anonymized.
6. Account Deletion
You may delete your account at any time from the account settings in the Platform (including the mobile app) or by contacting us. Upon deletion, personal data that is not subject to a statutory retention duty is deleted or irreversibly anonymized; financial records of completed transactions continue to be kept for their statutory periods.
7. Your Rights (KVKK Art. 11)
You have the right to learn whether your personal data is processed; to request information; to learn the purpose of processing and whether data is used accordingly; to know the third parties to whom it is transferred in Türkiye or abroad; to request correction, deletion or destruction; to request notification of these operations to transferees; to object to a result arising against you from analysis exclusively by automated systems; and to claim compensation for damage caused by unlawful processing.
Applications may be submitted to hello@projectworm.com in accordance with the Communiqué on Application Procedures to the Data Controller. Applications are concluded free of charge within 30 days at the latest.
8. Additional Information for Users in the EU, EEA, Switzerland and the United Kingdom (GDPR)
If you use the Platform from the European Union, the European Economic Area, Switzerland or the United Kingdom, the General Data Protection Regulation (GDPR), the Swiss Data Protection Act or the UK GDPR apply to you in addition. The controller is Smart Coders LLC as named in Section 1; contact: hello@projectworm.com.
Legal bases (Art. 6(1) GDPR). The processing described in Section 3 relies on point (b) (contract) for registration, membership, matching, escrow payments and service messages; point (c) (legal obligation) for accounting, tax and other statutory duties; point (f) (legitimate interest) for platform security, fraud and abuse prevention and the dispute-resolution procedure; and point (a) (consent) for statistics and functional cookies (see the Cookie Policy) and for marketing e-mails, which you can unsubscribe from at any time.
Recipients and processors. Hosting and e-mail infrastructure, payment processing (Stripe, Inc.), audience measurement (Google Analytics – only with your consent), live chat (tawk.to Inc. – only with your consent), and authorities and courts where required by law.
Transfers to third countries. The Company is established in the USA, so your data is processed outside the EEA. The transfer to the Company is necessary for the performance of the contract concluded with you (Art. 49(1)(b) GDPR). Transfers to service providers in the USA rely on the adequacy decision for the EU-US Data Privacy Framework where the provider is certified, and otherwise on EU Standard Contractual Clauses; the respective addenda apply for Switzerland and the United Kingdom.
Retention. The periods in Section 5 apply; data processed solely on the basis of consent is deleted once consent is withdrawn.
Your rights (Art. 15–21 GDPR). You have the right of access, rectification, erasure, restriction of processing, data portability and the right to object to processing based on a legitimate interest. You may withdraw any consent at any time with effect for the future (Art. 7(3) GDPR); cookie consents via the Cookie settings link in the footer. Send requests to hello@projectworm.com; we respond within one month. You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular the authority of your place of residence.
Automated decisions. No decisions based solely on automated processing with legal effect within the meaning of Art. 22 GDPR are made. Search rankings and quality tiers on the Platform are calculated from your activity and reviews and have no legal effect.
9. Cookies
Detailed information on cookies used on the Platform is provided in the Cookie Policy.
10. Changes
The Company may update this notice. The current version takes effect when published on the Platform; material changes are announced through reasonable means. The date of the version in force is shown at the top of this text.