Data Processing Notice
This notice explains, as Turkish data protection law (KVKK, article 10) requires, how scale190 (Creative Intelligence) processes your personal data while you use the service.
1. Data controller
Controller: Derya Uludağ, Kordonboyu Mah. Turgut Özal Blv. Dumankaya B Blok No: 65 İç Kapı No: 43, Kartal / İstanbul. Contact: privacy@scale190.com.
2. Personal data we process
- Identity and contact: your e-mail address and account name.
- Account and preferences: language, theme and account settings.
- Meta advertising data (if you connect Meta): ad account details, campaign and ad details, daily performance metrics, ad images, videos and copy, the Meta access token and your Meta user ID.
- Security: session cookies and sign-in records.
- Usage records: tabs opened, features used, AI, credit and storage usage.
3. Why we process it
- To provide the service: analysing ad performance and creatives, and producing findings, recommendations, reports and alerts.
- To create and secure your account and answer support requests.
- To improve the service: measuring how features are used.
- To meet legal obligations.
4. Legal bases and how we collect it
Your data is collected from what you enter when creating an account, from Meta with read access (ads_read) when you connect it, and automatically while you use the service.
Legal bases: entering into and performing the service contract (KVKK art. 5/2-c), legal obligation (art. 5/2-ç), legitimate interest in keeping the service secure and improving it (art. 5/2-f); your explicit consent for the transfer abroad (art. 9).
5. Who receives it and transfers abroad
We do not sell your data. To run the service it is transferred to these providers, who process it on our behalf:
- Railway (hosting);
- Supabase (database, file storage, authentication);
- OpenAI, Anthropic, Google (AI analysis);
- a product analytics provider (usage measurement);
- Resend (e-mail delivery, when used).
These providers are outside Turkey, so your data is transferred abroad. By creating an account you give your explicit consent to that transfer. You can withdraw that consent by deleting your account (Profile → Delete account) or by writing to privacy@scale190.com; the service cannot be provided without it.
We may disclose information to authorities where the law requires it.
6. Retention
Your data is kept while your account is open. When you delete your account, the account, your ad data, analyses and files are deleted for good; backups are deleted within our infrastructure providers' standard retention period.
After you delete your account, usage statistics that do not identify you (counts and counters) may remain; they can no longer be linked to your account.
7. Your rights
You can ask whether your personal data is processed and for information about it, learn the purpose and whether it is used accordingly, know the third parties it is transferred to in Turkey or abroad, ask for incomplete or wrong data to be corrected and for data to be deleted or destroyed under the conditions of the law, ask for those actions to be notified to the recipients, object to a result against you produced solely by automated analysis, and claim compensation for damage caused by unlawful processing.
Write to privacy@scale190.com; we answer free of charge within 30 days.