KVKK Personal Data Notice and Terms of Use
The privacy notice prepared by Zabiris as data controller under Turkish Personal Data Protection Law No. 6698 (KVKK), together with the terms of use of our services. It applies to all Zabiris software, apps and games; product-specific data details are in the Privacy Policy.
1. Data controller
Your personal data is processed by Zabiris (a sole proprietorship) as data controller, as described in this notice.
Shown on request so that personal details are not indexed by search engines.
2. Scope
- Software for businesses: Zabiris Kids (zabiris.com/kids), Zabiris Go (zabiris.com/go and the mobile tracking app), the Zabiris Assistant (WhatsApp virtual assistant).
- Apps and games: riBi and Water Garden Pro (App Store and Google Play).
- Website: zabiris.com and its blog.
For data about a business's own customers (e.g. child and parent details in Kids, the ordering customer's details in Go and the Assistant), the business concerned is the data controller; Zabiris processes this data on the business's behalf as a data processor (see section 8).
3. Categories of personal data
| Category | Examples | Service |
|---|---|---|
| Identity and contact | Business name, authorised person's name, phone, email | Go, Assistant, Kids |
| Customer transaction data | In Kids, child's name/age and parent contact; in Go and the Assistant, the ordering customer's name, phone and delivery address; visit, order and appointment records, amounts, payment method | Go, Assistant, Kids |
| Communication content | Messages exchanged between the customer and the assistant for an order or appointment | Assistant |
| Integration data | Platform API keys provided by the business (stored encrypted) | Go |
| Transaction security | IP address, browser/device information, session logs, notification token | Go, Assistant, Kids, website |
| Game account and usage | On Google/Apple sign-in: display name, email, profile picture; game progress and scores; device information; game usage and anonymous analytics data | Water Garden Pro |
| Marketing (advertising) | Advertising identifier for personalised ads (Google AdMob) | Water Garden Pro |
| Customer transactions (purchases) | In-app purchase and subscription records (payment details are not stored) | Water Garden Pro |
| Problem reports | The message the user writes, device/version information, game state, IP address | Water Garden Pro |
| Visit statistics | Page views, device/browser information (Google Analytics, only with consent); anonymous page-view counts from our cookieless counter (no IP address stored) | Website |
riBi collects no personal data; app data stays only on the device.
4. Purposes of processing
- Providing the service and running operational processes.
- Managing order, appointment and visit records.
- Contracts, invoicing and payment tracking.
- Providing technical support and resolving errors and problem reports.
- Ensuring information security and preventing misuse.
- Measuring, statistically, how the website and games are used.
- Saving game progress, showing leaderboards and showing in-game advertising (Water Garden Pro).
- Complying with legal obligations.
5. Legal grounds and method of collection
Personal data is processed on the following legal grounds under Article 5(2) of the KVKK:
- It is directly related to the conclusion or performance of a contract (providing the service, invoicing).
- It is necessary for the data controller to comply with a legal obligation (tax and commercial records, requests from competent authorities).
- It is necessary for the establishment, exercise or protection of a right.
- It is necessary for the data controller's legitimate interests, provided that it does not harm the data subject's fundamental rights and freedoms (service security, fixing errors).
Where the law requires explicit consent (e.g. personalised advertising and use of the advertising identifier in Water Garden Pro), data is processed only on the basis of your explicit consent; you can withdraw it at any time in your device settings.
Data is collected, partly by automated means, through the website and panels, the mobile apps, platform integrations authorised by the business, messages received via WhatsApp, email and phone.
6. Transfers of personal data
Personal data is transferred only to the extent the service requires, to the following groups of recipients:
- Within Turkey: the food delivery platforms authorised by the business (Trendyol Go, Getir, Yemeksepeti, Migros Yemek); competent public authorities where the law requires.
- Abroad: our server hosting provider GoDaddy; Google (Analytics, reCAPTCHA, notification service); Meta (WhatsApp); AI services used to interpret messages; Apple notification service; Firebase (Google Cloud), Google AdMob and RevenueCat for Water Garden Pro; the Apple App Store and Google Play for in-app purchases.
Transfers abroad are made within the scope of Article 9 of the KVKK and only to provide the relevant service. Data is never sold or rented to third parties for marketing.
7. Retention and security
- Data is kept for as long as the purpose of processing requires and for the retention periods set by law (e.g. tax and commercial records); after that it is deleted, destroyed or anonymised. Zabiris Go customer details are deleted 90 days after the order is closed; Zabiris Kids child and parent details are anonymised after 2 years (see the retention policy, Turkish).
- All communication is encrypted with SSL/TLS; passwords are stored with bcrypt; data is backed up regularly and accessed only by authorised people.
8. Data processed on behalf of businesses
Businesses using Zabiris Go, the Zabiris Assistant and Zabiris Kids are the data controllers for their own customers' data; informing those people and obtaining their consent where needed is the business's obligation. Zabiris processes this data only on the business's instructions and to provide the service, and does not use it for any other purpose. Requests we receive from a business's customers are forwarded to the business concerned.
9. Your rights under the KVKK
Under Article 11 of the KVKK you may apply to the data controller to:
- learn whether your personal data is being processed;
- request information about the processing if it has been processed;
- learn the purpose of processing and whether the data is used in line with that purpose;
- know the third parties in Turkey or abroad to whom the data has been transferred;
- request correction if the data is incomplete or inaccurate;
- request deletion or destruction of the data under the conditions in Article 7 of the KVKK;
- request that correction, deletion or destruction be notified to third parties to whom the data was transferred;
- object to a result against you arising exclusively from automated analysis of the processed data;
- claim compensation for damage suffered due to unlawful processing.
You can send your request in writing or from an email address that allows us to verify your identity (such as the email address registered with our services). Requests are concluded within 30 days at the latest, depending on their nature, and as a rule free of charge. If your request is rejected or you find the answer insufficient, you may lodge a complaint with the Turkish Personal Data Protection Board (KVKK Kurulu).
10. Summary by product
Each product's detailed section is in the Privacy Policy.
Software for businesses
| Product | Zabiris's role | Main data |
|---|---|---|
| Zabiris Kids | Controller for the business account; processor for child and parent data | Business account; child's name/age, parent's name/phone; visit and amount records |
| Zabiris Go | Controller for the business account; processor for ordering customers' data | Business account; customer name, phone, delivery address; order records; platform API keys |
| Zabiris Assistant | Controller for the business account; processor for customer data | Business account; customer name, phone, address; conversations with the assistant |
Apps and games
| Product | Zabiris's role | Main data |
|---|---|---|
| riBi | No personal data is processed | None, information stays only on the device |
| Water Garden Pro | Data controller | On Google/Apple sign-in: name, email, profile picture; game progress and scores; device and usage data; advertising identifier; purchase records; problem reports |
11. Terms of use
Description of the services
Zabiris develops industry-specific software as well as mobile apps and games. Zabiris Kids is provided as a cloud service at zabiris.com/kids; Zabiris Go as the zabiris.com/go web panel and an iOS/Android mobile tracking app; the Zabiris Assistant as a module running on the business's own number; riBi and Water Garden Pro through the App Store and Google Play.
Subscriptions and payment (software for businesses)
- Zabiris Kids starts with a 30-day free trial; after the trial, a paid monthly or annual plan is required. Current prices are published on the Zabiris Kids page. Zabiris Kids shows no advertising.
- Setup and pricing for Zabiris Go and the Zabiris Assistant are set per business; please contact us for details.
- Subscription fees are paid in advance; monthly plans can be cancelled at any time.
- The remaining period of annual plans is not refunded. Prices exclude VAT; an invoice is issued.
Apps and games
- Downloads, in-app purchases, subscriptions (e.g. Water Garden Pro VIP) and refunds for riBi and Water Garden Pro are subject to the Apple App Store's or Google Play's own terms; payments are processed by the store.
Data ownership
All data a business enters into the system belongs to the business. Even if a subscription is cancelled, you may request an export of your data within a reasonable period (at least 30 days).
Liability
Zabiris takes the utmost care to keep the service running. Zabiris cannot be held responsible for outages or changes caused by third-party platforms' own systems (Trendyol, Getir, WhatsApp, the App Store, Google Play, etc.).