Privacy Notice (Personal Data Protection)

Last updated: 12 October 2026 · Türkçe

This is an English translation provided for convenience. In case of any discrepancy, the Turkish version prevails.

1. Data controller

Your personal data is processed by the following person as the data controller under Turkish Personal Data Protection Law No. 6698 (KVKK):

Data controller: Alper Kahraman (HOLLUK)
Address: İstanbul Anadolu Yakası Organize Sanayi Bölgesi 6. Sokak No:10, 34953 Aydınlı, Tuzla / İstanbul, Türkiye
Email: destek@holluk.com
Website: www.holluk.com

HOLLUK is currently a software venture run by an individual (sole proprietor). When a company is incorporated, this notice will be updated with the company details.

2. Personal data we process

Category	Data	Source
Identity	Full name	Trial form, license
Contact	Email, phone	Trial form, license, support, WhatsApp
Customer	Company name, license type, license term, license number	License
Device	Machine ID (hash), program version, computer name (only for shared/floating licenses)	HOLLUK program
Usage	Trial start date, last-used date, personal download code	HOLLUK program, trial form
Transaction security	IP address and request time (trial and license requests)	License server
Support	Chat messages (not stored; only forwarded to generate a reply), daily message count, email correspondence	Support chat, email
Communication preference	Consent to / refusal of marketing messages, and its date	Trial form
Site visits	Aggregate visit statistics that use no cookies and do not identify you	Website

What is the machine ID? A SHA-256 hash generated from the Windows machine ID and the volume serial number of the C: drive. The raw values are not sent to the server. The HOLLUK program does not send your files, drawing or part names, or their contents to the server. The log files the program keeps on your computer stay on your computer.

3. Purposes of processing

To provide the trial version, send the setup file and manage the trial period.
To issue licenses, bind a license to a computer, and check its term and validity.
To send reminder emails when a trial or license is about to expire.
To provide technical support for installation and use; for this purpose, to contact you by email, phone or WhatsApp and to answer questions in the support chat.
To see which download record a trial installation came from and whether the program is being used; to detect unauthorized distribution and misuse.
To see, in aggregate, which program versions are in use and to identify the need for updates.
To keep the systems secure, limit excessive requests and fix errors.
To comply with legal obligations and to protect rights in possible disputes.

We do not send you commercial electronic messages with campaign or promotional content without your consent.

4. Collection method and legal grounds

Data is collected partly by automated means through the trial form on the website, the support chat, email and WhatsApp correspondence, and the information the HOLLUK program sends to the server during trial and license checks. Legal grounds (KVKK Article 5(2)):

(c) Establishment or performance of a contract: providing the trial version and the license, sending the setup file, reminder emails, technical support.
(ç) Legal obligation: retention and notification obligations arising from legislation.
(e) Establishment, exercise or protection of a right: license infringement and disputes.
(f) Legitimate interest: matching trial installations with download records, keeping the last-used date, detecting unauthorized distribution, system security. The machine ID is kept as a hash, not in raw form.
Consent (Law No. 6563 on Electronic Commerce): only for sending commercial electronic messages with campaign and promotional content.

5. Transfer of data

Your personal data is not sold and is not shared with third parties for advertising. To operate the service, data is transferred to the service providers below only to the extent the service requires. These providers' servers are located outside Türkiye:

Provider	Purpose	Data transferred	Location
Neon	Database	Form, trial, license and security records	Germany
Microsoft Azure	License and trial server	Machine ID, version, IP, license details	France
Vercel	Website, form and visit statistics	Form data, aggregate visit data	Germany
Brevo	Form notifications and email delivery	Name, company, phone, email, language	EU
Anthropic (Claude)	Support chat replies	Recent chat messages (email address is not sent)	USA
WhatsApp (Meta)	Support correspondence	Phone number, message content	EU / USA
Google Drive	Encrypted backup	License records (encrypted)	Outside Türkiye

For every cross-border transfer, the transfer mechanisms set out in KVKK Article 9 are applied as appropriate to the scope of the transfer. Data may also be disclosed to legally authorized public institutions and bodies, upon request and to the extent required by law.

6. Retention periods

Data	Retention period
Trial form, download code, trial and last-use records	2 years after the trial ends
Machine ID	2 years after the trial or license ends
IP and request records	1 year (then the IP and machine ID are deleted)
Computer name (floating license)	For as long as the seat is in use
License customer records	During the license term and 2 years after it ends
Invoices and accounting documents	The period required by the applicable legislation
Support email and WhatsApp correspondence	2 years after the last message
Support chat messages	Not stored (daily message count: 90 days)
Marketing consent and refusal records	3 years after the consent ends

When the period expires, the data is deleted, destroyed or anonymized. Deletion requests are assessed within the conditions of the KVKK and statutory retention obligations.

7. Your rights and how to apply

Under KVKK Article 11, you have the right to: learn whether your data is processed; request information about it; learn the purpose of processing and whether it is used accordingly; know the third parties to whom it is transferred; request its correction, deletion or destruction, and that these actions be notified to those it was transferred to; object to a result against you arising from automated analysis; and claim compensation for damage caused by unlawful processing.

How to apply: You can submit requests under the KVKK in writing, in line with the application procedures in the legislation, to the address above or to destek@holluk.com. Identity verification may be requested if needed. Applications are concluded free of charge within 30 days at the latest.