Privacy Policy
User

This Privacy Policy has been prepared by Metaverse Software Information Technologies Trade Limited Company, established at Üniversiteler Mahallesi İhsan Doğramacı Boulevard, ODTÜ Teknokent İkizler Building K1-4A, Çankaya/Ankara/Türkiye, acting as the data controller (hereinafter referred to as "Metaverse"), in order to inform you, within the framework of Article 10 ("Obligation of the Data Controller to Inform") and Article 11 ("Rights of the Data Subject") of the Turkish Personal Data Protection Law No. 6698 ("KVKK"), about the methods of collection, processing, use, transfer, and destruction of your personal data within the scope of the Lagomya Service.

Within the scope of the Lagomya Service, Metaverse processes your personal data in accordance with the personal data processing conditions and purposes specified under KVKK:

• in compliance with the law and the principles of honesty,
• by ensuring that the personal data you share is accurate and kept up to date,
• for specific, explicit, and legitimate purposes,
• in a manner that is relevant, limited, and proportionate to the purposes for which they are processed,
• for the periods stipulated in the relevant legislation or required for the purposes for which they are processed.

1. Collection of Personal Data, Processed Personal Data, and Purposes

1.1. Collection

Your personal data are collected directly from you while you use Metaverse's Lagomya Service (www.lagomya.com web panel and applications). The terms governing your use of the Lagomya Service are defined within the scope of the User Agreement ("User Agreement"). In addition, personal data are collected directly from you during communications established with Metaverse. Personal data are stored on the servers of third parties from whom Metaverse receives services.

1.2. Processed Personal Data and Purposes

The personal data listed below are processed for the purposes of providing, developing, ensuring the security of the Lagomya Service, and fulfilling legal obligations:

• Name, surname, email address, and phone number, for the purposes of:
  • creating a user account in the software,
  • creating a user database,
  • recovering the account in case the password is forgotten, and
  • carrying out customer service operations,
  in order to enable the use of the service, pursuant to the law, for the performance of the contract, and for the fulfillment of legal obligations;
• Avatar selection, for the technical provision of the service and enabling interaction in the virtual environment;
• IP address and Device ID, for the development of the services provided, ensuring customer satisfaction, offering new services in line with needs, and for marketing purposes;
• Possible litigation file information (identity information, address information, information and documents related to the subject of the dispute), for the purposes of tracking lawsuits and enforcement proceedings that may arise if one of the parties resorts to legal remedies against the other in the event of a dispute, tracking uncollected product fees, and tracking unauthorized software usage.

2. Legal Grounds for Processing

Data processing is based on Article 5/2 of KVKK for the purposes of purchasing services through the Platforms and benefiting from customer services and support, namely:

(a) being explicitly stipulated by law,

(c) being necessary for the establishment or performance of a contract,

(ç) being mandatory for Metaverse, as the data controller, to fulfill its legal obligations, and

(e) being necessary for the establishment, exercise, or protection of a right.

The processing of such data is not subject to your consent. Therefore, you are not entitled to request the deletion or destruction of your personal data until the end of the service period and the legally required retention periods.

3. Processing Based on Explicit Consent

3.1. Effective and Proper Execution of the Lagomya Service.

Mood selection data are processed solely based on your explicit consent, which is given voluntarily. These data are processed by Metaverse and/or its suppliers for the purpose of personalizing the user experience within the Lagomya Service.

The processing of mood selection data is based on Article 6/2. Within the scope of the Lagomya Service to be provided to you by Metaverse (services provided by contracted suppliers), the mood data you share are processed as your Special Category Personal Data directly under your explicit consent. Only persons authorized by Metaverse will be able to access your Special Category Personal Data shared within the service. Under no circumstances will your Special Category Personal Data be shared with third parties other than the aforementioned persons.

However, we would like to state that due to the nature of the psychological counseling or coaching, mentoring, or similar personal and professional development-oriented counseling services provided, Metaverse and/or its suppliers will not be able to continue providing these services if you withdraw your explicit consent.

You have the right to withdraw your consent at any time, without stating any reason, regarding the processing of your personal data based on explicit consent by Metaverse and/or its suppliers for these purposes. Upon communicating your statement of withdrawal of consent to Metaverse, Metaverse and/or its suppliers will immediately cease processing your data for this purpose.

Withdrawal of your consent will not affect the lawfulness of the processing carried out based on your consent prior to this withdrawal. Metaverse will continue to retain the information provided prior to the withdrawal of consent for as long as permitted or required by the applicable law.

3.2. Commercial Communication

Communication for the improvement of the products and services offered, customer satisfaction, offering new products and services in line with customer needs, and other commercial purposes. Your email address requested during your membership on the Platforms, as well as your IP and Device ID information, may also be processed for the purpose of commercial communication provided that you have explicit consent. The processing of your data for the improvement of the offered products and services, customer satisfaction, offering new products and services in line with customer needs, and other commercial purposes is based on your explicit consent in accordance with Article 5/1 of KVKK.

You may give your explicit consent for commercial communication when registering on the Platforms.

You may withdraw your explicit consent for the processing of your personal data for the purposes stated herein at any time. Withdrawal of consent will not affect the lawfulness of the processing carried out based on your consent prior to the withdrawal. The information provided prior to the withdrawal of consent will be retained for the specified retention periods.

Metaverse may analyze your personal data mentioned above through automated systems within the scope of your explicit consent and derive conclusions from these data.

4. Transfer of Personal Data to Third Parties

Metaverse may transfer or disclose your personal data specified above, without requiring your consent, in order to comply with obligations arising from the law and/or to perform its responsibilities under the service agreement and/or where it is mandatory to fulfill its legal obligations, to:

• third parties such as banks, audit firms, lawyers, law offices, financial advisors, suppliers—especially the psychologists providing services—limited to and proportionate with the service received and solely for the fulfillment of obligations, and
• law enforcement units, public institutions, relevant ministries and directorates, and public institutions and legal entities including the Social Security Institution assigned pursuant to labor and social security legislation, as well as other public authorities authorized by law.

Domestic data transfers within Türkiye shall be limited to the cases stipulated under Article 8/2(a) of KVKK, namely where processing is required by law pursuant to Article 5/2(a), necessary for the establishment and/or performance of a contract pursuant to Article 5/2(c), required for the fulfillment of a legal obligation pursuant to Article 5/2(ç), or necessary for the establishment, exercise, or protection of a right pursuant to Article 5/2(e).

With respect to personal data you share during communications with service providers, the data controllers are the relevant service providers themselves. Likewise, transactions you carry out through channels outside Metaverse during the provision of the service (for example, payment transactions) and records related to the provision of the service form part of the legal relationship between the service provider and the service recipient; therefore, Metaverse does not act as the data controller regarding the data processed and stored within this scope.

Information regarding third parties and/or categories of third parties to whom your data are disclosed in Türkiye is always available for your information and review.

5. Access to Personal Data

Metaverse shares your personal data obtained during registration and related to the psychological counseling process with servers located in Türkiye belonging to the company Natro. In addition, Metaverse's corporate email network operates on servers belonging to Natro. Accordingly, all email communications conducted via Metaverse workplace email addresses are stored in encrypted form on Natro's servers.

These transfers are carried out pursuant to Article 8/2 of KVKK.

6. Protection, Retention Period, and Destruction of Personal Data

Metaverse is obliged to take, and takes to the maximum extent, all necessary physical, technical, and administrative measures to ensure an adequate level of security in order to prevent unlawful processing of personal data, prevent unlawful access to personal data, and ensure the preservation of personal data.

Unless otherwise stated in the Information Notice, your personal data are retained until the end of the 10 (ten) year retention period following the termination of the service relationship. For detailed information, please review the Information Notice.

Your personal data processed for marketing purposes are limited to the duration of the service. Upon the expiration of the service period, Metaverse will not use your personal data to contact you for marketing purposes.

At the end of these periods, your personal data will be deleted, destroyed, or anonymized during the first disposal period.

Metaverse has prepared separate and specific information notices ("Information Notice") for users, employees, employee candidates, suppliers, and managers. These information notices have been delivered to or made accessible by each relevant data subject group. At the end of these periods, your personal data will be deleted, destroyed, or anonymized during the first disposal period.

7. Your Rights

As a data subject, pursuant to applicable legislation, you have the right to: (a) request information as to whether your personal data are processed and how they are processed (Art. 11(a), (b)), (b) learn the purpose of processing and whether they are used in accordance with such purpose (Art. 11(c)), (c) know the third parties to whom your personal data are transferred (Art. 11(ç)), (d) request correction of your personal data (Art. 11(d)), (e) request the deletion of your personal data if the reasons requiring their processing cease to exist (Art. 7, Art. 11(e)), (f) request notification of correction or deletion operations to third parties to whom personal data have been transferred (Art. 11(f)), (g) object to any result arising against you as a result of analysis of your personal data (Art. 11(g)), (h) request restriction of processing (Art. 7), and (i) request compensation for damages incurred due to unlawful processing of personal data (Art. 11(ğ)).

The above-mentioned rights are limited by law and may only be provided by us under certain conditions (please particularly review Articles 10 and 13 of KVKK).

You may submit your requests regarding the rights listed above to kvkk@metaverse.com.tr. Metaverse will conclude your request as soon as possible and at the latest within 30 (thirty) days from receipt of the relevant documents.

Data Controller: Metaverse Software Information Technologies Trade Ltd. Co.
MERSIS No: 3958-6264-9135-7424
Address: Üniversiteler Mahallesi İhsan Doğramacı Boulevard, ODTÜ Teknokent İkizler Building K1-4A, Çankaya/Ankara/Türkiye
Email: kvkk@metaverse.com.tr

Upon request, Metaverse may update your personal data as well as this Privacy Policy and the Information Notice at any time. You can always access the Terms of Use, the current Information Notice, and the Privacy Policy at www.lagomya.com.

© 2026 Metaverse Software Information Technologies Trade Ltd. Co. All Rights Reserved.

Right to File a Complaint with the Personal Data Protection Authority

To exercise your right to file a complaint with the Authority (KVKK Articles 13, 14, and 15):

Authority: Personal Data Protection Board
Address: Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4, 06520 Balgat-Çankaya/Ankara
Phone: +90 312 216 5000
Website: http://www.kvkk.gov.tr/