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KVKK 明确同意
摘要
针对国际数据传输、营销和分析的单独同意声明。
Introduction
Under Article 5/1 of the Turkish KVKK, separate and granular consent declarations are provided below for processing activities that require explicit consent. Each consent is given independently. Declining one does not affect the others and does not prevent you from using the core Service (covered by contract performance). Consents may be withdrawn at any time via the channels below.
The subject, purpose and scope of each consent are clearly stated. Bundled (“accept all”) consent is not collected — each is confirmed separately.
Consent 1 — International Transfer
Subject: Hosting of my personal data in the United States (Flexton LLC's domicile) and in EU-West data centres (database, email, error monitoring) as part of the Qoro platform's operating infrastructure, and sharing with the sub-processors located in those regions.
Safeguards: Transfers are carried out under KVKK Art. 9 using a commitment / cross-border agreement, SCC 2021/914, or your explicit consent. Data Processing Agreements are in place with sub-processors (/legal/dpa Exhibit A).
This consent is obtained during registration. Once granted, it will be stored as a separate record in a future release.
Consent 2 — Marketing Communications
Subject: Emails from Flexton LLC regarding Qoro and related product/feature announcements, educational content and campaign notifications.
Channel: Email (primary). Additional consent is collected if push or in-app notifications are used.
Out of scope: Transactional messages (order confirmations, invoices, security alerts, password resets) are not subject to this consent — they are covered by contract performance.
The Qoro Service functions fully even without this consent. If granted, every email includes a one-click unsubscribe link.
This consent is off by default at registration and is presented as a separate checkbox.
Consent 3 — Analytics & Performance Cookies
Subject: Use of cookies and similar technologies for usage analytics and error monitoring (e.g. error-tracking tool).
Out of scope (necessary): Session, CSRF, security (Cloudflare Turnstile) and payment-functionality cookies are processed under legitimate interest and are not subject to consent.
Cookie consent is collected via the Cookie Banner at the bottom of the page. It can be changed later from the control panel on /legal/cookies.
Withdrawing Consent
You can withdraw your consents as follows:
- Marketing consent:Via the “Unsubscribe” link at the bottom of each email or the notification preferences in your account settings.
- Analytics cookie consent: By reopening the Cookie Banner or deleting the
qoro_cookie_consentkey from your browser storage. - International transfer consent: Written request to hello@qoro.cc. Note: because the overseas infrastructure is core to the Service, withdrawal may require closing the account.
Withdrawal has prospective effect; it does not affect the lawfulness of past processing based on that consent.
How to Manage
A Privacy Centre (/admin/settings/privacy) where you can manage all consents in one place will go live with Blok G-II. Until then, the channels above apply. All consent records are stored against your account (timestamp, version, IP, User-Agent) and are auditable.