1. Data Controller#
Remotiva is a Neptuniva product. Neptuniva is the brand under which Berkay Aksoy offers his software products. In these texts, "Neptuniva", "we", "us" or "our" refer to Berkay Aksoy.
| Data controller | Berkay Aksoy (Neptuniva) |
|---|---|
| Address | Kültür Mah. Çakmaklar Cad. Bolu Teknokent No: 2/44 Merkez/Bolu |
| Phone | +90 533 915 08 05 |
| support@remotiva.app |
This notice concerns personal data processed through the remotiva.app website and web account area, the Remotiva desktop (macOS) and mobile (iOS, Android) apps and their server services. More detailed information is available in the Privacy Policy. If the data controller changes (for example, if the service is transferred to a company to be established under the Neptuniva name), you will be notified of this.
2. Categories of Personal Data Processed#
| Identity | First name, last name; for invoicing, tax number or, for sole proprietorships, Turkish ID number; company name |
|---|---|
| Contact | Email address, phone number, billing address, country |
| Customer transactions | Plan and subscription information, order, coupon and refund records, support requests and messages |
| Financial | Order amount, tax, currency, payment transaction references, last four digits of the card, app store transaction identifiers, billing details (the card number is not processed by us) |
| Transaction security | Password hash, two-step verification key (encrypted) and backup code hashes, Google or Apple account identifier, session records, IP address, browser information, sign-in attempts and other security events |
| Device and usage | Device identifier, Remotiva ID, device name, type, operating system and app version, last IP address, last seen time, pairing records, enabled modules, online and sleep status, optional technical diagnostic logs |
| Legal transactions | Acceptance records of the Preliminary Information Form and the Distance Sales Agreement (time, IP, browser information, document version and content), time of acceptance of the terms |
| Visual | Profile photo obtained from Google or Apple |
The content of remote sessions (screen images, audio, mouse and keyboard input, transferred files, clipboard content, network bridge traffic) is transmitted directly between devices; it is not viewed, stored or processed by Neptuniva. No special categories of personal data are processed.
3. Purposes of Processing Personal Data#
- Carrying out membership and account operations, authentication and session management
- Providing the service, including device registration, pairing and establishing remote connections
- Applying plan limits and carrying out subscription, sales, payment, refund and invoicing processes
- Fulfilling distance contract and preliminary information obligations and keeping the related records
- Carrying out information security processes and preventing unauthorized access and misuse
- Determining price and currency by country
- Answering support requests, fixing errors and improving the service
- Sending service-related notifications such as password resets and support replies
- Fulfilling obligations arising from legislation, responding to requests from competent authorities and protecting rights in legal disputes
4. Method of Collection and Legal Bases#
Your personal data is collected electronically, by automated or partly automated means, through the website, the web account area, the desktop and mobile apps and our servers; as well as from Google or Apple when you sign in with these providers, from Apple and Google for app store purchases, and from PayTR for card payments.
This data is processed on the basis of the following legal grounds in Article 5(2) of the KVKK:
- (c) Establishment or performance of a contract: Account, device, connection, subscription, payment, support and notification operations.
- (ç) Fulfilment of a legal obligation: Invoices, tax and commercial records, distance contract records, providing information to competent authorities.
- (e) Establishment, exercise or protection of a right: Keeping contract acceptance records and transaction records.
- (f) Legitimate interest: Information security, prevention of misuse, country-based pricing, troubleshooting and improving the service, provided that your fundamental rights and freedoms are not harmed.
Where processing based on explicit consent is required, your explicit consent will be obtained separately.
5. Transfer of Personal Data#
Your personal data may be transferred to the following parties, limited to the purposes above and in accordance with Articles 8 and 9 of the KVKK:
- Hosting service provider: Hetzner Online GmbH (Germany); all server data.
- Payment institution: PAYTR Ödeme ve Elektronik Para Kuruluşu A.Ş. (once web payment is offered); full name, email, phone, address, IP address, order and amount information for collecting and refunding card payments.
- Email delivery service: Resend (USA); email address, name and email content for password reset and support reply emails.
- App stores and identity providers: Apple Inc. and Google LLC; account identifiers, transaction identifiers and IP address in connection with sign-in and purchase verification.
- Competent public authorities and institutions and judicial bodies: To the extent they are legally authorized and request it.
- Persons providing legal and financial advisory services: To the extent necessary to fulfil legal and financial obligations and protect rights.
6. International Transfers#
Because our servers are located in Germany and some of our email, authentication, app store and profile photo service providers are established in the USA, your personal data is transferred abroad. These transfers are made in accordance with Article 9 of the KVKK, relying on one of the appropriate safeguards provided for in the law, in particular the standard contracts announced by the Personal Data Protection Board, or on occasional transfer cases such as the transfer being necessary for the performance of the contract concluded with you.
7. Retention Period#
Your personal data is kept for the period required by the purpose of processing and the periods provided for in legislation. Account data is kept as long as your account is open; order, payment and invoice records for 10 years as required by tax and commercial legislation; security events for 12 months; application server logs for 14 days. Distance contract acceptance records are kept for the period required by the relevant legislation and the limitation period. Data whose period has expired is deleted, destroyed or anonymized in accordance with the Regulation on the Deletion, Destruction or Anonymization of Personal Data.
8. Your Rights as a Data Subject#
Under Article 11 of the KVKK, by applying to Neptuniva you have the right to:
- learn whether your personal data is processed,
- request information if your personal data has been processed,
- learn the purpose of processing your personal data and whether it is used in line with its purpose,
- know the third parties in Türkiye or abroad to whom your personal data is transferred,
- request correction of your personal data if it has been processed incompletely or inaccurately,
- request deletion or destruction of your personal data under the conditions set out in Article 7 of the KVKK,
- request that the actions taken under items 5 and 6 be notified to the third parties to whom your personal data has been transferred,
- object to a result against you arising from analysis of the processed data exclusively by automated systems,
- claim compensation for damage if you suffer damage due to unlawful processing of your personal data.
These rights are available to you.
9. How to Apply#
In accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, you may submit requests concerning your rights, including your first and last name, your signature (for written applications), your Turkish ID number or, if you are a foreign national, your nationality and passport or ID number, your address for notifications, your email address if any, your phone number and the subject of your request, by one of the following means:
- in writing to Kültür Mah. Çakmaklar Cad. Bolu Teknokent No: 2/44 Merkez/Bolu,
- from the email address registered to your Remotiva account to support@remotiva.app.
Your application will be concluded free of charge as soon as possible according to its nature and within 30 days at the latest. If the action requires an additional cost, the fee in the tariff set by the Personal Data Protection Board may be charged. We may request additional information to verify your identity.
10. Complaint to the Board#
If your application is rejected, you find the response insufficient, or no response is given in time, you may file a complaint with the Personal Data Protection Board within 30 days of learning of the response and, in any case, within 60 days of the application date.