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Privacy policy

Privacy Policy

Effective Date: [EFFECTIVE DATE]
Last Updated: [LAST UPDATED DATE]

This Privacy Policy explains how [COMPANY LEGAL NAME], established under the laws of [COUNTRY/JURISDICTION] and located at [REGISTERED ADDRESS] (“Univerax,” “we,” “us,” or “our”), collects, uses, discloses, retains, and protects personal data in connection with Univerax.com and its related websites, applications, marketplace functions, and services (collectively, the “Platform”).

This Privacy Policy applies to visitors, registered users, buyers, customers, authors, sellers, service providers, experts, and other individuals who interact with the Platform.

Additional or more specific privacy notices may apply to particular users, countries, features, or processing activities. Users in Türkiye should also review the applicable KVKK Privacy Notice. Where the GDPR or another regional privacy law applies, supplementary regional information may also be provided.

1. Who Is Responsible for Your Personal Data?

Unless a separate notice states otherwise, the controller responsible for the processing described in this Privacy Policy is:

Legal Entity: [COMPANY LEGAL NAME]
Registered Address: [REGISTERED ADDRESS]
Privacy Contact: [PRIVACY EMAIL]
Data Subject Request Method: [PRIVACY REQUEST FORM OR EMAIL]
Data Protection Officer or Representative: [DPO/REPRESENTATIVE DETAILS, IF APPLICABLE]

Independent sellers, authors, and service providers may separately act as controllers for personal data they receive or process for their own purposes, such as delivering a service, communicating with a customer, issuing invoices, or complying with professional obligations.

Where an independent seller or provider determines why and how it processes personal data, its own privacy notice and legal responsibilities may apply. Univerax does not automatically act as the controller for every independent processing activity performed by a seller or provider.

2. Personal Data We May Collect

The personal data collected depends on how you interact with the Platform, the role you select, the features you use, and the requirements of a particular transaction.

2.1 Account and Profile Information

We may collect:

First and last name;

Username;

Email address;

Password in protected form;

Telephone number;

Profile photograph;

Country, region, language, and time zone;

Account preferences;

Account type and marketplace role;

Profile biography, skills, portfolio, and professional information; and

Account creation, verification, status, and login records.

Passwords should be stored using appropriate cryptographic protection rather than in readable form.

2.2 Identity and Verification Information

Where identity, seller, provider, payment, tax, or compliance verification is required, we may collect:

Date of birth;

Nationality or country of residence;

Government-issued identity document information;

Business name and registration details;

Tax-related information;

Professional licenses, certifications, or qualifications;

Verification photographs or other verification data; and

Results or status received from verification providers.

We will seek to limit verification data to what is necessary for the relevant purpose and legal obligation.

2.3 Transaction and Order Information

We may collect:

Products or services viewed, requested, ordered, licensed, or purchased;

Order and transaction identifiers;

Seller, author, or provider involved in the transaction;

Price, currency, discounts, commissions, taxes, and fees;

Order status and delivery information;

License type;

Refund, cancellation, dispute, and chargeback records;

Invoice and billing information; and

Records showing acceptance of transaction-specific terms.

2.4 Payment-Related Information

Payments may be processed by independent payment gateways or regulated financial service providers.

Depending on the payment method and provider, we may receive:

Payment status;

Transaction reference;

Amount and currency;

Masked payment-card information;

Payment method type;

Billing information;

Fraud, risk, or verification results;

Refund and chargeback status; and

Provider payout or settlement information.

Full payment-card details may be collected directly by the relevant payment provider rather than Univerax. The actual payment architecture and provider responsibilities should be reviewed in the payment provider’s terms and privacy notice.

2.5 Seller, Author, and Service Provider Information

If you apply to sell products or provide services, we may collect:

Store or professional profile information;

Portfolio, experience, skills, and service categories;

Product listings and digital files;

Pricing, availability, and delivery preferences;

Bank account, payout, or settlement information;

Business, tax, and invoice details;

Identity and compliance documentation;

Provider earnings and fee records;

Customer service and performance records; and

Listing, moderation, complaint, and enforcement history.

2.6 Service Requests and Booking Information

For consulting, training, private lessons, development, design, creator services, appointments, or other professional services, we may collect:

Service request details;

Project requirements and specifications;

Requested date, time, duration, and time zone;

Delivery location or online meeting details;

Proposals and quotations;

Provider acceptance or rejection;

Customer-supplied materials;

Completion, revision, cancellation, rescheduling, and no-show records; and

Communications relating to the service.

Users should not submit health data or other sensitive information unless it is strictly necessary, lawfully requested, and supported by an appropriate secure process.

2.7 Communications and Support Information

We may collect:

Messages between users where Platform communication tools are used;

Support requests and ticket records;

Complaints and dispute communications;

Emails and other communications sent to Univerax;

Attachments supplied for support or dispute resolution; and

Records of notifications sent through the Platform.

We may access or review communications where reasonably necessary for delivery, user support, safety, fraud prevention, moderation, dispute resolution, or compliance with law.

2.8 Reviews and User Content

We may collect and display:

Ratings and reviews;

Comments and replies;

Listings and product descriptions;

Profile information and portfolio content;

Images, videos, documents, and digital files;

Community or social content; and

Reports concerning other users or content.

Information intentionally published through a public profile, listing, review, or community feature may be visible to other users or the public.

2.9 Device, Log, and Security Information

When you use the Platform, we may automatically receive:

IP address;

Browser type and version;

Device type and operating system;

Language and time-zone settings;

Referring and exit pages;

Access date and time;

Session and authentication events;

Pages or features accessed;

Error and performance logs;

Security, fraud, and abuse indicators; and

Cookie or similar-technology identifiers.

2.10 Cookie and Similar Technology Data

The Platform may use cookies, local storage, pixels, software development kits, or similar technologies for purposes such as:

Essential Platform operation;

Authentication and session continuity;

Security and fraud prevention;

Language and preference storage;

Shopping-cart functionality;

Analytics, where implemented and lawfully enabled;

Optional integrations; and

Advertising or marketing, where implemented and consented to as required.

The categories and specific technologies actually in use should be described in the Cookie Policy and managed through the applicable cookie preference interface.

3. How We Obtain Personal Data

We may obtain personal data:

Directly from you;

From your activity on the Platform;

From another user involved in a transaction or service request;

From sellers, authors, or service providers;

From payment and payout providers;

From identity or compliance verification providers;

From fraud-prevention and security services;

From publicly accessible sources where lawful;

From third-party services you choose to connect; and

From authorities or other parties where permitted or required by law.

If another person provides us with your personal data, that person must have an appropriate legal basis and provide any legally required notice.

4. Why We Process Personal Data

We may process personal data for the following purposes.

4.1 Providing the Platform

Creating and managing accounts;

Authenticating users;

Maintaining profiles and preferences;

Providing search, discovery, listing, ordering, booking, and communication features;

Enabling digital downloads or access;

Supporting service requests and project delivery;

Processing orders, subscriptions, refunds, and payouts; and

Providing customer support.

4.2 Managing Marketplace Transactions

Connecting buyers with sellers or providers;

Presenting transaction information;

Recording contract acceptance;

Coordinating payments and settlements;

Managing commissions and fees;

Supporting delivery and completion;

Handling cancellations, refunds, chargebacks, complaints, and disputes; and

Maintaining transaction and accounting records.

4.3 Safety, Security, and Fraud Prevention

Detecting unauthorized access;

Protecting accounts and payments;

Preventing fraud, spam, abuse, manipulation, or illegal activity;

Investigating security incidents;

Enforcing Platform rules;

Moderating content and listings; and

Protecting users, Univerax, and third parties.

4.4 Legal and Regulatory Compliance

Complying with tax, accounting, consumer, electronic commerce, payment, sanctions, and other legal requirements;

Responding to lawful requests from courts, regulators, or authorities;

Establishing, exercising, or defending legal claims;

Maintaining records required by law; and

Supporting identity, seller, provider, or business verification where required.

4.5 Improving and Developing the Platform

Troubleshooting errors;

Measuring performance;

Understanding how Platform features are used;

Developing and testing new functionality;

Improving search, recommendations, usability, and accessibility; and

Conducting aggregated or statistical analysis.

Where possible, we may use aggregated or anonymized data that no longer identifies an individual.

4.6 Communications

Sending account, security, order, booking, payout, support, and legal notices;

Responding to inquiries;

Informing users about material Platform changes; and

Sending marketing communications where permitted and subject to the required choice or consent.

Marketing choices do not prevent necessary security, transaction, contractual, or legal communications.

5. Legal Bases for Processing

The legal basis depends on the processing activity, applicable law, and your relationship with Univerax.

Where the GDPR or a similar legal framework applies, processing may be based on:

Performance of a contract or steps requested before entering into a contract;

Compliance with a legal obligation;

Legitimate interests, where those interests are not overridden by individual rights;

Consent, where legally required and validly obtained;

Establishment, exercise, or defense of legal claims; or

Protection of vital interests or performance of a task in the public interest, in limited cases where legally applicable.

Potential legitimate interests may include operating and securing the Platform, preventing fraud, improving services, protecting legal rights, supporting users, and maintaining appropriate business records.

Where processing is based on consent, you may withdraw that consent without affecting processing that occurred lawfully before withdrawal.

For users in Türkiye, the applicable legal processing conditions will be explained more specifically in the separate KVKK Privacy Notice.

6. When We Share Personal Data

We may disclose personal data only as reasonably necessary for the purposes described in this Policy.

6.1 Other Marketplace Users

Information may be shared between buyers and the relevant seller or provider to:

Evaluate a service request;

Complete an order;

Deliver a product or service;

Arrange a booking;

Communicate about requirements;

Issue legally required transaction documents; or

Resolve a complaint or dispute.

Users must use received personal data only for lawful and transaction-related purposes.

6.2 Service Providers and Processors

We may engage service providers for:

Hosting and cloud infrastructure;

Payment and payout processing;

Email and notification delivery;

Identity and compliance verification;

Security and fraud prevention;

Customer support;

Data storage and backups;

Technical monitoring;

Analytics, if activated;

Communication or meeting tools, if activated; and

Professional legal, accounting, audit, or consulting support.

These providers should receive only the information reasonably necessary for their functions and be subject to appropriate contractual and security obligations.

6.3 Payment and Financial Service Providers

Payment-related information may be shared with the gateway, bank, card network, electronic money institution, fraud-prevention service, or other financial participant involved in the transaction.

The payment provider available for a transaction may vary. Where PayTR or another gateway is selected, that provider may process personal data under its own legal responsibilities and privacy information.

6.4 Legal and Safety Disclosures

We may disclose personal data where reasonably necessary to:

Comply with law or a valid legal request;

Protect the rights, property, or safety of users, Univerax, or others;

Investigate fraud, abuse, or security incidents;

Enforce agreements and policies; or

Establish, exercise, or defend legal claims.

6.5 Corporate Transactions

If Univerax is involved in a merger, acquisition, restructuring, financing, asset transfer, or similar transaction, personal data may be disclosed to relevant professional advisers and transaction parties, subject to appropriate confidentiality and legal safeguards.

7. International Data Transfers

The Platform may use infrastructure, service providers, or recipients located outside the country in which a user resides.

Where personal data is transferred internationally, Univerax will use a transfer mechanism required by applicable law. Depending on the jurisdiction, this may include:

An adequacy decision;

Standard contractual clauses or standard contracts;

Binding corporate rules;

Another legally recognized safeguard; or

A permitted statutory exception in limited circumstances.

International transfers from Türkiye must be assessed under the applicable provisions of the Turkish Personal Data Protection Law, including the available adequacy and appropriate-safeguard mechanisms.

International transfers covered by the GDPR may require an approved transfer mechanism and, where appropriate, supplementary safeguards.

The countries, recipients, and transfer mechanisms actually used must be confirmed from Univerax’s technical infrastructure and vendor arrangements.

8. Data Retention

We retain personal data only for as long as reasonably necessary for the relevant purpose, including to:

Maintain an active account;

Complete and document transactions;

Provide purchased products or services;

Handle support, refunds, chargebacks, and disputes;

Prevent fraud and abuse;

Comply with tax, accounting, consumer, payment, and other legal obligations;

Enforce agreements; and

Establish, exercise, or defend legal claims.

Retention periods may differ by data category and jurisdiction.

When determining a retention period, we may consider:

The nature and sensitivity of the data;

The purpose of processing;

Whether the purpose can be achieved through other means;

Contractual and limitation periods;

Statutory recordkeeping requirements;

Security and fraud risks; and

Pending disputes or legal proceedings.

When personal data is no longer required, it will be deleted, destroyed, anonymized, or otherwise handled in accordance with applicable law and the relevant retention and deletion procedures.

Account deletion may not result in immediate deletion of all information where continued retention is required for completed transactions, financial records, fraud prevention, disputes, backups, or legal compliance.

9. Data Security

We use reasonable administrative, technical, and organizational measures designed to protect personal data against unauthorized access, loss, alteration, disclosure, or destruction.

Measures may include, where appropriate:

Access controls and authorization management;

Protected password storage;

Encryption in transit and, where appropriate, at rest;

Logging and monitoring;

Backup and recovery controls;

Vulnerability and security management;

Vendor assessments;

Staff confidentiality measures; and

Incident-response procedures.

No online service or storage system can guarantee absolute security. Users are responsible for protecting their credentials and promptly reporting suspected unauthorized access.

10. Your Privacy Rights

Depending on your location and applicable law, you may have rights to:

Learn whether your personal data is processed;

Request access to your personal data;

Request correction of incomplete or inaccurate data;

Request deletion or destruction;

Request restriction of processing;

Object to certain processing;

Receive certain data in a portable format;

Withdraw consent where processing is based on consent;

Request information about recipients;

Challenge certain solely automated decisions;

Submit a complaint to a competent data-protection authority; and

Exercise other rights available under applicable law.

These rights are not absolute. A request may be limited or rejected where an applicable exemption exists, continued processing is legally required, or the requester’s identity cannot be appropriately verified.

11. How to Submit a Privacy Request

You may submit a privacy request through:

Privacy Email: [PRIVACY EMAIL]
Request Form: [PRIVACY REQUEST FORM URL]
Postal Address: [PRIVACY REQUEST POSTAL ADDRESS]
KEP Address: [REGISTERED ELECTRONIC MAIL/KEP ADDRESS, IF APPLICABLE]

Please describe your request clearly and identify the account or information concerned.

We may request reasonable information to verify your identity and authority before processing a request. We will respond within the period required by applicable law.

Authorized representatives may submit requests where legally permitted and supported by appropriate proof of authority.

12. Account Controls

Where available, users may manage certain information directly through account settings, including:

Profile details;

Contact information;

Password and security settings;

Notification preferences;

Public profile content; and

Marketing choices.

Some transaction, payout, verification, or compliance records may not be editable or removable through account controls.

13. Marketing Communications

We may send marketing communications only where permitted by applicable law.

Where consent is required:

Marketing consent will be requested separately;

Consent will not be a condition of basic account creation unless legally justified;

Choices should not be preselected; and

Users may withdraw consent through the available unsubscribe or preference mechanism.

Unsubscribing from marketing does not stop necessary account, security, transaction, support, or legal notices.

14. Cookies and Tracking Choices

Essential cookies may be used where necessary to provide a service expressly requested by the user, maintain sessions, secure the Platform, or preserve shopping-cart functions.

Non-essential analytics, functional, advertising, or marketing technologies should be activated only in accordance with applicable consent requirements.

Where a cookie preference tool is available, users should be able to:

Accept optional technologies;

Reject optional technologies;

Make category-based choices; and

Change their preferences later.

Further information will be provided in the Cookie Policy after the active cookies and integrations have been technically audited.

15. Public Information

Information published in listings, seller or provider profiles, portfolios, reviews, comments, or public community features may be visible to other users, search engines, or the public.

Before publishing information, users should consider whether it contains:

Personal contact details;

Confidential information;

Third-party personal data;

Sensitive information;

Client materials; or

Information they do not wish to make public.

Removing public content does not necessarily remove copies previously saved, lawfully shared, indexed, or retained for legal and security purposes.

16. Children’s Privacy

The Platform is not intended for children below [MINIMUM AGE] unless a particular service expressly permits their participation and all legally required parental or guardian permissions and safeguards are in place.

Univerax does not knowingly seek unnecessary personal data from children.

If you believe a child has provided personal data contrary to applicable requirements, contact us at [PRIVACY EMAIL].

The permitted age and parental authorization process must be determined according to the countries and services in which the Platform operates.

17. Sensitive Personal Data

The Platform is not designed for users to submit sensitive personal data unless such information is necessary for a specifically supported and lawful purpose.

Sensitive data may include health information, biometric data, genetic data, political or religious beliefs, trade-union membership, sexual-life information, or other specially protected categories under applicable law.

Users should not include such information in public profiles, ordinary messages, reviews, or general service requests.

If a future service requires sensitive data, Univerax should provide a specific collection process, notice, legal basis, access restriction, and security assessment before collecting it.

18. Automated Systems and Recommendations

Univerax may use automated systems to support search, recommendations, security, fraud detection, moderation, or Platform operations.

Unless separately disclosed, these tools are intended to support Platform functions and not to make a decision producing legal or similarly significant effects solely through automated processing.

If Univerax implements solely automated decisions with legally significant effects, affected users will receive the information and rights required by applicable law.

19. Third-Party Links and Services

The Platform may contain links to or integrations with third-party websites and services.

This Privacy Policy does not govern a third party’s independent processing activities. Users should review the privacy information of the relevant third party before providing personal data or connecting an account.

20. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in law, technology, Platform features, or processing activities.

The updated Policy will state its effective date. Where required by law or where a change materially affects users, we will provide an appropriate notice.

If a new processing activity requires consent, updating this Privacy Policy alone will not replace the required consent process.

21. Contact

Questions or concerns about this Privacy Policy may be submitted to:

Legal Entity: [COMPANY LEGAL NAME]
Registered Address: [REGISTERED ADDRESS]
Privacy Email: [PRIVACY EMAIL]
Support Email: [SUPPORT EMAIL]
Privacy Request Form: [PRIVACY REQUEST FORM URL]
Data Protection Officer or Representative: [DPO/REPRESENTATIVE DETAILS, IF APPLICABLE]

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