Disclosure Text

This disclosure text has been prepared by Harmonytics OÜ ("Company") as the data controller within the scope of the Psikas project ("Psikas"), in accordance with the Personal Data Protection Law No. 6698 ("KVKK"), to inform you about the personal data processed.

 

This Disclosure Text concerning the collection, processing, and transfer of your personal and sensitive data within the scope of the Psikas project has been prepared in accordance with the Personal Data Protection Law No. 6698 ("KVKK") and the relevant legislation, with the purpose of informing you on the following matters:

  • Which personal data are collected,
  • The purposes for collecting personal data,
  • With whom personal data are shared,
  • Whether personal data are transferred abroad,
  • How personal data are stored and protected,
  • The scope of your rights regarding your personal data.

1. Processed Personal and Sensitive Data

Psikas processes personal and sensitive data through pre-interview chats based on the legal grounds specified in Article 5/2 of the KVKK. Sensitive data will not be processed without explicit consent. The data processing processes carried out with AI-based systems are conducted based on the user’s explicit consent.

Categories of Personal Data and Purposes of Processing

Data CategoryData ProcessorPersonal DataPurpose of ProcessingRetention Period
Contact InformationClient Support UnitName, Surname, Phone Number, Email AddressService contract and legal obligationsRetained for 10 years.
Health DataClient Support UnitMental health status, sleep patterns, expectationsReferrals to appropriate psychologistsRetained during the referral process.
Technical DataClient Support UnitIP Address, Device ID InformationLegal obligations and service quality improvementRetained for 10 years.

 

Use of AI and Consent Requirement

Psikas uses AI-based systems to analyze your personal data. These data are processed by AI for diagnostic criteria formation and service quality improvement purposes. Without your explicit consent, sensitive data such as health information will not be transferred to AI service providers. In the context of AI usage, your data will not be shared with third parties unless anonymized, and only the stated purposes will guide any processing of your data.

 

Important Note: Users may request to delete their data. However, Psikas does not guarantee the deletion of data from OpenAI's servers. Therefore, users will be informed that their data may be stored on OpenAI's servers and that its deletion may not be controlled.

 

2. Transfer of Personal Data

Your personal data may be transferred within the country or abroad in the following cases and for the following purposes:

  • To relevant public institutions and organizations,
  • To Psikas’ business partners within the framework of the processes benefiting from Psikas services,
  • To your relevant consultant,

Data sharing with AI service providers will be based on your explicit consent and will be limited to specific service purposes.

Data Sharing Process and Security Measures

  • Data Sharing Process: External AI service providers use user data in anonymized form and only for service provision purposes. The sharing of non-anonymized data will not take place without users' explicit consent.
  • Security Measures: In data sharing, technical and administrative measures are taken to ensure the security of the data, and these measures are applied in accordance with data security standards. During data sharing with AI service providers, high-level encryption and similar security measures are also implemented.

3. Protection and Security of Personal Data

Psikas takes the following measures to protect your personal data:

  • Encryption,
  • Access control,
  • Backup.

4. Explicit Consent Declaration

Users give explicit consent for the processing of their personal and sensitive data within the scope of the services provided by Psikas. Particularly, your explicit consent is sought for the processing of your health data and their analysis by AI systems. Giving this consent is entirely voluntary, and you may withdraw it at any time. However, withdrawal of consent may result in the restriction of the services provided.

 

Withdrawal of Explicit Consent

Data subjects have the right to withdraw their explicit consent regarding the processing of their personal data at any time. Once the explicit consent is withdrawn, the processing of personal data will cease, but your data will continue to be stored in accordance with legal obligations and legitimate interests.

 

5. Automated Decision-Making and Profiling

Psikas uses AI systems to analyze the information provided by users and offer recommendations based on diagnostic criteria. However, this process does not operate as a fully automated decision-making mechanism and is intended solely for guidance purposes. Final decisions are made by professional psychologists, and user profiling is conducted based on explicit consent.

There is no direct binding decision-making mechanism on users, and their rights to object to these processes are reserved.

 

6. Your Rights

As a data subject, you have the following rights concerning your personal data, in accordance with the applicable legislation:

  1. Right to Know If Personal Data Is Processed: The right to request information about whether your personal data is being processed and how it is being processed (KVKK Art. 11/(a), (b)).
  2. Right to Know the Purpose of Processing: The right to know for what purposes your personal data is being processed and whether it is being used in accordance with the purpose (KVKK Art. 11/(c)).
  3. Right to Know the Third Parties: The right to know the third parties to whom your personal data is transferred (KVKK Art. 11/(ç)).
  4. Right to Request Correction: The right to request the correction of personal data if it is incomplete or inaccurately processed (KVKK Art. 11/(d)).
  5. Right to Request Deletion: The right to request the deletion of personal data in case the reasons requiring the processing of personal data cease to exist (KVKK Art. 7, Art. 11/(e)).
  6. Right to Request Notification: The right to request that, in case your personal data is corrected or deleted, this process is notified to third parties to whom the data has been transferred (KVKK Art. 11/(f)).
  7. Right to Object: In Psikas, users' data is analyzed through automated systems, and recommendations are provided. However, since these processes do not affect final decisions and are intended solely for guidance, they do not result in binding outcomes for users. Nevertheless, if a result unfavorable to you arises from the analysis of your processed data by these systems, you have the right to object to this situation (KVKK m. 11/(g)).
  8. Right to Request Restriction: The right to request restriction of the processing of your personal data (KVKK Art. 7).
  9. Right to Request Compensation: The right to request compensation in case you suffer damage due to the unlawful processing of personal data (KVKK Art. 11/(ğ)).

To exercise your rights mentioned above, you can submit a request by clicking [Contact Form].

 

7. Contact

For any questions or comments regarding this Disclosure Text, you can contact us:

8. Changes

This Disclosure Text may be updated over time. Notifications of changes will be provided, and the updated text will be published on Psikas’ official website.