Privacy Policy

Miella Studio ("Company", "Agency", or "We") is committed to protecting the privacy of users ("User" or "You") who visit our online platforms at the highest level. This Privacy Policy has been specially prepared by our legal and technical experts to ensure full compliance with global data protection standards, especially the Personal Data Protection Law No. 6698 ("KVKK") and the 2026 Artificial Intelligence Regulations (AI Act), as well as national and international regulations.

1. Categories of Personal Data Collected

During your interaction with our platform, your personal data is processed in the following data categories:

• Identity and Contact Data: Name, surname, email address, phone number.
• Third-Party Platform (Meta/Instagram) Data: Instagram username, direct message (DM) content, interaction date and time details that you transmit to us via Miella Studio's Meta Graph API integration (App Dashboard).
• Transaction Security and Technical Data: IP address, browser information, log records, device type, and connection timestamps.

2. Purposes and Legal Grounds for Processing Personal Data

Your data is processed for the following purposes based on the legal grounds of "establishment or performance of a contract", "legal obligation of the data controller", and "legitimate interest, provided that it does not harm the fundamental rights and freedoms of the data subject" within the scope of KVKK Article 5/2:

• Provision of our services, management of sales and marketing operations.
• Instant (within the 24-hour rule) and uninterrupted response to your Instagram messages via our customer relationship management (CRM) system.
• Ensuring the security of our platform, detection and prevention of cyber attacks.
• Reporting and information transfer in accordance with legislation, if requested by legal authorities.

3. Artificial Intelligence (AI) Systems and Data Transparency (2026 Update)

Within the scope of this disclosure obligation, we would like to emphasize that; your personal data (message content, etc.) generated during communication between you and our Company is NOT USED in the training data sets of any Artificial Intelligence (AI) system, Large Language Model (LLM), or providers such as OpenAI, Anthropic, Meta Llama, etc. The automations integrated through our systems are solely "Rule-based" systems and are not subject to profiling without your explicit consent.

4. Data Transfer to Third Parties and International Sharing

As a rule, your personal data is not shared with third parties. However, if you contact us via Instagram, since the infrastructure of Meta Platforms Inc. is used, your data is processed subject to Meta's own Privacy Policies, and data flow occurs through service providers with servers located abroad within the scope of KVKK Article 9.

5. Data Retention and Destruction Policy

Your personal data is stored for the period required by the processing purpose and taking into account the legal statute of limitations (generally 10 years) stipulated in the Turkish Code of Obligations, Turkish Commercial Code, and relevant tax legislation. After the expiration of legal periods, your data is irreversibly deleted or anonymized within the framework of our periodic destruction rules.

6. Data Security and Technological Measures

End-to-End Encryption, TLS/SSL certificates, modern Firewall walls, and Zero Trust architecture standards are actively implemented in our system infrastructure. Third-party API connections (Meta Graph API) are provided with official and approved (having passed the App Review process) tokens.

7. Rights of the Data Subject and Application Mechanism

Pursuant to KVKK Article 11, as a data owner; you have the right to learn whether your data is processed, to request the deletion (Right to be Forgotten) or correction of your processed data. Approval processes regarding data restrictions on Meta systems (Error 230 - User Consent) are entirely managed from your Instagram privacy settings. To exercise your relevant right, you can reach us in writing at `kvkk@miellastudio.com`.

Last Update: 05.04.2026 | Document Version: v2.0-2026