Who is it for, and who is the data controller?
This notice explains how we process the personal data of the business partners who apply to and join the Faprika Partner Program, in accordance with Article 10 of Law No. 6698 on the Protection of Personal Data (KVKK, the Turkish Personal Data Protection Law) and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform.
Persons covered: partner candidates and partners (working as natural persons or sole proprietorships), and the authorized persons, shareholders and employees using the Partner Panel of partners that are legal entities. The data of prospective customers notified to us by partners is not covered by this notice; those persons are informed under Faprika's general privacy notice.
| Data controller | Information |
|---|---|
| Trade name | İnovabil Teknoloji Sanayi ve Ticaret A.Ş. (Faprika) |
| Mersis Number | 0478055847500014 |
| Address | YTÜ Teknopark Sokak İç Kapı No: 1/Z11, Başakşehir / İstanbul |
| hukuk@inovabil.com.tr | |
| KEP (registered e-mail) | inovabil@hs01.kep.tr |
| Phone | 0850 333 15 23 |
Which of your data do we process?
We process only the data needed to run the program. We do not ask for special categories of personal data (such as health, religious or biometric data); please do not share them in your application or correspondence.
| Data category | Examples |
|---|---|
| Identity | Name and surname, title, position; where an invoice or expense voucher is required, Turkish identity number or tax identification number |
| Contact | E-mail address, telephone number, city and address, KEP address |
| Professional information | Partner type, company and website, area of expertise, the customer portfolio you describe in your application, partner tier and completed trainings |
| Finance | Bank and IBAN details, account holder, earnings statements, invoices, tax deductions; for partners abroad, certificate of residence |
| Customer transactions | Records of the prospective customers you notify, the number and date of sign-ups coming through your partner link and referral code, acquired customers, objection and support correspondence |
| Transaction security | Partner Panel user account, login and activity logs, IP address, browser and device information; agreement approval record (date, time, agreement version, IP address, e-mail) |
| Legal transactions and compliance | Agreement, Partner Terms, notices and formal warnings, dispute correspondence, results of sanctions list screening |
| Marketing | Only if you give permission: your preferences for promotional and campaign messages |
For what purposes and on what legal grounds?
We base each purpose on a legal ground in KVKK Art. 5(2). Your explicit consent is requested only for promotional messages; not giving it does not affect your application or your earnings.
| Purpose | Legal ground |
|---|---|
| Receiving and evaluating your application and contacting you | Necessary for the conclusion of the agreement (Art. 5(2)(c)) |
| Concluding the Agreement and the Partner Terms; providing the Partner Panel account, training, sales materials and demo access; determining the partner tier | Conclusion and performance of the agreement (Art. 5(2)(c)) |
| Recording prospective customer notifications, monitoring the protection period, resolving conflicting notifications | Performance of the agreement (Art. 5(2)(c)), legitimate interest (Art. 5(2)(f)) |
| Calculating your earnings, preparing earnings statements, handling invoice or expense voucher procedures and making payments | Performance of the agreement (Art. 5(2)(c)), legal obligation (Art. 5(2)(ç)) |
| Fulfilling accounting, tax and commercial bookkeeping obligations; responding to requests from competent authorities | Expressly provided for by law and legal obligation (Art. 5(2)(a), 5(2)(ç)) |
| Preventing false or fraudulent notifications and withholding payment where necessary; ensuring the security of the Partner Panel and of access to customer panels | Legitimate interest (Art. 5(2)(f)) |
| Monitoring compliance with sanctions, anti-bribery and anti-money laundering rules | Legal obligation (Art. 5(2)(ç)), legitimate interest (Art. 5(2)(f)) |
| Monitoring compliance with the trademark usage and advertising rules | Legitimate interest (Art. 5(2)(f)) |
| Keeping the agreement approval and notices as evidence and protecting our rights in disputes | Establishment, exercise and protection of a right (Art. 5(2)(e)) |
| Sending notices related to the agreement, such as program, product and price changes | Performance of the agreement (Art. 5(2)(c)) |
| Sending promotional, campaign and event messages | Explicit consent (Art. 5(1)) and consent to commercial electronic messages; you can withdraw it at any time |
No decision that is based solely on automated processing and that legally affects you is made. Decisions such as suspected fraud or the rejection of a notification are reviewed by one of our employees and the reasons are communicated to you.
How do we collect your data?
We collect your data mostly directly from you, by automated or partly automated means:
the registration form at partners.faprika.com and the partner application form on faprika.com,
the Partner Panel, your partner link and your referral code (to the extent the visitor has consented to cookies),
e-mail, KEP, telephone, online meetings and trainings,
the invoices, documents and bank details you send,
for partners that are legal entities, your partner company, which provides us with the details of its authorized persons and employees,
publicly available sources such as trade registry records and sanctions lists.
To whom do we transfer your data?
We transfer your data only for the purposes above and only to the extent necessary, in accordance with KVKK Art. 8, to the recipients below. We do not sell your data.
| Buyer | Reason |
|---|---|
| Our service providers (hosting, e-mail, SMS, customer relationship software, security) | To run the program technically on our behalf and on our instructions; the current list is on the Sub-processors page |
| Banks and payment institutions | Payment of your earnings |
| Financial advisors, independent auditors and lawyers | Accounting, audit and legal support, under a duty of confidentiality |
| Acquired customers | Informing the customer you work with of your name and contact details as its partner |
| Competent public authorities and institutions, courts, enforcement offices | Where there is a legal request or obligation |
| Our successor in a merger, demerger or transfer of business | Assignment of the agreement (Partner Program Agreement Art. 17.1) |
Transfers abroad (KVKK Art. 9). The servers of some of our service providers may be located abroad; for partners established outside Türkiye, correspondence and payments naturally go to the partner's country. We base these transfers primarily on an adequacy decision of the Personal Data Protection Board (the Board) or, where there is none, on the standard contracts announced by the Board (notified to the Authority within 5 business days of signing). Where neither is available, we transfer data only occasionally and only in the cases listed in Art. 9(6); for example, sending your earnings to your bank account abroad is necessary for the performance of the agreement between us (Art. 9(6)(b)).
How long do we keep it?
We keep your data for as long as the purpose requires and the law provides. When the period expires, we delete, destroy or anonymize the data.
| Data | Retention period |
|---|---|
| Application not accepted | 1 year from the application date |
| Agreement, approval record, Partner Terms, notices, prospective customer records | 10 years from the termination of the agreement (limitation period under the Turkish Code of Obligations) |
| Earnings, invoice, payment and tax records | 10 years from the beginning of the year following the year concerned (Turkish Commercial Code Art. 82, Tax Procedure Law Art. 253) |
| Partner Panel login and activity logs | 2 years from the date of the record; if there is an investigation or dispute, until it is concluded |
| Permission for promotional messages | Until the permission is withdrawn; consent and opt-out records for the period required by the commercial electronic message legislation |
Your rights and how to apply to us
Under KVKK Art. 11, you have the right to:
learn whether your personal data is processed and, if so, request information about it,
learn the purpose of processing and whether the data is used in line with that purpose,
know the third parties in Türkiye or abroad to whom the data is transferred,
request rectification if the data is incomplete or inaccurately processed,
request erasure or destruction if the reasons requiring processing no longer exist,
request that rectification, erasure and destruction be notified to the third parties to whom the data has been transferred,
object to a result against you arising from analysis exclusively by automated systems,
claim compensation if you suffer damage due to unlawful processing.
You can submit your application in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller in one of the following ways:
by a petition bearing your wet signature, in person or through a notary public, to the address above,
by KEP to inovabil@hs01.kep.tr,
with a secure electronic signature or mobile signature to hukuk@inovabil.com.tr,
from the e-mail address you previously notified to us and that is registered in our system, to hukuk@inovabil.com.tr.
Your application must include your name and surname, your Turkish identity number (if you are a foreign national, your nationality and passport number), your address for notifications, your e-mail or telephone number and your request. We conclude your application free of charge within 30 days at the latest; if the process involves an additional cost, only the fee in the tariff set by the Board is charged. If your application is rejected, if you find our response insufficient or if no response is given in time, you may lodge 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.
Additional information for partners outside Türkiye
If you are located in the European Economic Area or the United Kingdom and the EU General Data Protection Regulation (GDPR) or the UK GDPR applies to you, the information above is also deemed to have been provided to you under Articles 13 and 14 GDPR.
Legal bases: conclusion and performance of the contract (Art. 6(1)(b)), legal obligation (Art. 6(1)(c)), legitimate interest (Art. 6(1)(f): protecting the program against fraud, panel security, trademark and compliance monitoring, protecting our rights) and consent for promotional messages (Art. 6(1)(a)).
Your additional rights: access to your data, rectification, erasure, restriction of processing, data portability, objection to processing based on legitimate interest and withdrawal of your consent. You may lodge a complaint with the data protection authority in the country where you live or work.
Transfer to Türkiye: we collect most of your data directly from you. Where your partner company provides us with the data of its authorized persons and employees, this transfer is based, under Partner Program Agreement Art. 11.5, on the standard contractual clauses adopted by EU Commission Decision 2021/914 (Module 1) and the UK addendum. You can request a copy at hukuk@inovabil.com.tr.
Provision of data: the data requested for the application, the agreement and payment is mandatory; if it is not provided, we cannot evaluate the application or make payments.
Amendments
We may update this notice as the legislation or the program changes. The current version is published on this page; we also notify you of significant changes in the Partner Panel and at your registered e-mail address. Version 1.0, published on 11 November 2026.