The Convince The Convince Information notice

Aydınlatma / Article 10 notice

Information Notice

This notice tells you who processes your personal data in The Convince, why, and which rights you have.

Issued under Türkiye’s KVKK and, where they apply, UK/EU GDPR · 30 September 2026

1. Data controller

The data controller for The Convince is OWLBIT LTD.

  • Email: zai@97.team
  • Phone: +90 212 909 00 97
  • Correspondence: Çamtepe Mah. Mahmut Tevfik Atay Bulvarı, Gaziantep Teknopark 4/C Blok No: Z04/b, Şahinbey / Gaziantep, Türkiye

A longer, narrative description of the same processing is in the Privacy Policy. If the two texts ever differ on a KVKK point, this Notice prevails for that point.

2. Personal data we process

  • Audio-visual data: live camera frames and microphone audio during a session.
  • Derived biometric-style signals: pulse-from-face estimates, expression and gaze metrics, voice-tone metrics. These are used to run the session, not to identify you as a unique person.
  • Voice-to-text: words you speak in a session, when transcription is on.
  • Session output: scores, summaries, and reports you choose to generate or export.
  • Support data: name, email, phone, and message if you write to us.
  • Technical data: crash and connection logs; IP address seen by this legal website or by the processing host.

We do not require an account. We do not process payment card data inside the product (if you pay through a store or platform, that provider handles billing).

3. Purposes

  • To provide the communication-assistant session you start.
  • To calibrate a short personal baseline and show live feedback.
  • To prepare a session summary if you ask for one.
  • To answer support requests and keep the service secure.
  • To meet legal duties (for example a lawful authority request).

4. Legal bases

Where KVKK applies, we rely on:

  • KVKK Art. 5/1 — your explicit consent for camera and microphone (the permission dialogue on your device).
  • KVKK Art. 5/2-c — processing that is necessary to perform the service you requested.
  • KVKK Art. 5/2-f — our legitimate interest in security, support, and product stability, provided it does not override your fundamental rights.
  • KVKK Art. 5/2-a and 5/2-ç — legal obligation and establishment of a right, where a law requires us to keep or disclose data.

Where UK/EU GDPR applies, the matching bases are consent (Art. 6(1)(a)), contract (Art. 6(1)(b)), legitimate interests (Art. 6(1)(f)), and legal obligation (Art. 6(1)(c)). Camera and microphone stay off until you allow them on your device.

5. How we collect it

Directly from your device when you run a session, and directly from you if you email or call support. We do not buy lists. We do not scrape third-party profiles to build a file on you.

6. Recipients

Personal data is not sold. It may be seen only by:

  • authorised staff of OWLBIT LTD who need it for support or operations;
  • the processing host operated for the app (analysis of the live session);
  • infrastructure vendors (hosting, transport, crash diagnostics) under contract;
  • Google (Gemini API), only after you allow the session, and only the question and answer text, the five warm-up texts, the measured numbers for that answer (heart rate, heart-rate variability, blink rate, gaze aversion, micro-expression, facial asymmetry, pitch, voice tremor and quality, pause ratio, speech rate), and your notes on whether you believed the answer — not camera images, face video, audio recordings, or the name you type;
  • public authorities or courts if the law requires it;
  • professional advisers in a genuine dispute.

7. Transfers abroad

Analysis and AI processing may take place on servers outside Türkiye (including services operated by Google). We use encrypted connections and, where KVKK or GDPR requires it, an appropriate transfer tool (adequacy, standard clauses, or your explicit consent for the session you start).

8. Retention

  • Camera images and audio recordings: not stored.
  • Session report (name, questions, answer text, measurements, and result): on the processing host until you delete it from the Profile tab.
  • Support mail: up to 24 months.
  • Security and crash logs: up to 90 days.

9. Your rights

Under KVKK Art. 11 (and GDPR where it applies) you may:

  • learn whether your data is processed, and request information;
  • learn the purpose and whether it is used in line with that purpose;
  • know the third parties in Türkiye or abroad to whom data is transferred;
  • request correction of incomplete or inaccurate data;
  • request deletion or destruction under the conditions in Art. 7;
  • request that correction or deletion be notified to recipients;
  • object to a result against you that is produced exclusively by automated analysis;
  • claim compensation if you suffer damage because of unlawful processing.

You may withdraw camera and microphone consent in your device settings. Related features then stop.

10. How to apply

Send your request to zai@97.team with enough detail for us to find the session or email thread (date, device, and what you want done). We will answer within 30 days, or explain if we need more time as the law allows.

If you live in Türkiye you may also complain to the Personal Data Protection Authority (KVKK Kurulu) if we do not resolve your request. If UK/EU GDPR applies, you may complain to your local supervisory authority.