This notice is prepared by Luminar, as data controller, to inform you about the processing of your personal data under Law No. 6698 on the Protection of Personal Data ("KVKK"). It applies to services offered through the Luminar website and mobile application.
If you access Luminar from outside Turkey, Turkish data protection law may still apply to processing connected to our services. This notice is provided in English for convenience; the Turkish version on the Turkish locale page is the authoritative reference where required by law.
1. Data controller
The data controller under KVKK is the Luminar platform. Your personal data is processed by Luminar as data controller for the purposes and legal bases described below. Current contact details are published in official announcements and platform contact channels.
2. Purposes of processing
- Membership and account management: Account creation, authentication, session security, and profile management
- Service delivery: Operating writing, reading, publishing, library, and discover features
- Community features: Running comments, gossip, follows, notifications, and moderation
- AI assistants: Operating Ilhami (Text AI) and Tuval (Visual AI); processing prompts and context to generate responses
- Security and abuse prevention: Rate limits, session security, technical logs, and protecting platform integrity
- Legal obligations: Retention, notification, and responses to lawful authority requests
- Support and communication: Handling user requests, complaints, and appeals
3. Categories of personal data processed
- Identity and contact: Email address, display name (username)
- Account security: Password (stored only in encrypted/hashed form), session tokens
- Profile information: Optional avatar, cover image, bio
- Creative content: Book drafts, chapters, cover images, publishing metadata
- User transaction data: Reading progress, likes, comments, follows, collections, and gossip interactions
- Transaction security: IP address, device/browser information, access and error logs (limited retention)
- AI inputs: Ilhami/Tuval prompts and session context (for service delivery only)
- Subscription and billing (if applicable): Plan information and payment provider references; card details are not stored directly by Luminar
4. Collection methods and legal bases
Your personal data is collected electronically through the website, mobile app, API, support channels, and automatic technical records.
Data is processed under the following legal bases under KVKK Articles 5 and 6:
- Performance of a contract (KVKK Art. 5/2-c): Account creation, delivery of platform services, operation of AI assistants
- Legal obligation (KVKK Art. 5/2-ç): Legal retention, official authority requests, and records required by law
- Legitimate interest (KVKK Art. 5/2-f): Platform security, abuse prevention, and service quality improvement (without harming your fundamental rights and freedoms)
- Explicit consent (KVKK Art. 5/1): Optional notification preferences or additional processing that requires separate consent
5. Transfer of personal data
Your personal data may be transferred to the following recipient groups only to the extent necessary to perform the service and with appropriate safeguards:
- Infrastructure providers: PostgreSQL hosting (database), Cloudflare R2 (file storage)
- AI provider: OpenAI — Ilhami and Tuval prompt/context data for response generation only; not used for model training
- Payment service providers (if applicable): Authorized payment institutions for subscription transactions
- Email and notification providers: Account verification, security, and service notifications
- Authorized public institutions: When legally required and upon proper request
Where data is transferred abroad, safeguards under KVKK Article 9 and related regulations (standard contracts, undertakings, or explicit consent where applicable) are provided.
6. Retention period
Personal data is retained for as long as the processing purpose requires and for statutory limitation periods. When you delete your account, personal data is deleted or anonymized within a reasonable period; backup copies may remain in systems for a limited technical period. Security logs, abuse investigations, and legal obligations may require longer retention.
7. Data subject rights (KVKK Art. 11)
Under Article 11 of KVKK, 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 accordingly
- Know third parties to whom data is transferred domestically or abroad
- Request correction if data is incomplete or inaccurate
- Request deletion or destruction under KVKK Art. 7 conditions
- Request notification of correction/deletion to third parties to whom data was transferred
- Object to results against you arising solely from automated analysis
- Claim compensation for damage due to unlawful processing
8. How to submit a request
You may submit requests regarding your rights through in-platform support channels or the contact section, together with information to verify your identity.
Your request will be concluded free of charge within thirty days at the latest. If the process requires an additional cost, the fee set by the Personal Data Protection Board may apply.
9. Data security measures
Luminar applies technical and organizational measures — including encryption, access controls, secure session management, rate limits, and regular security reviews — to prevent unlawful processing and unauthorized access to your personal data.
10. Changes to this notice
This notice may be updated in line with legal or service changes. The current text is always published on this page. For more detail, see our Privacy Policy.