Legal
Privacy Policy
Last updated: March 16, 2026 · Effective date: March 16, 2026
1. Data Controller
This Privacy Policy has been prepared by Doksanbir Reklam Prodüksiyon Yazılım Yayıncılık ve Danışmanlık A.Ş. ("Draw", "we", "us"), which provides services through the draw.tr and draw.page domain names. Our company address is: Bahçelievler Mah. Doktor Cevdet Kara Cad. E blok No B24/A Gölbaşı/Ankara. Email: info@91.com.tr As Draw, we attach great importance to the privacy of your personal data and process this data within the scope of the Personal Data Protection Law No. 6698 (KVKK) and the European General Data Protection Regulation (GDPR).
2. Data We Collect
The following data may be collected when you use our services: Account Data: Name, email address, password (hashed), profile photo. Usage Data: Number of presentations created, features used, session duration, click and interaction data. Device and Technical Data: IP address, browser type, operating system, screen resolution, language preference. Payment Data: When a live payment provider is enabled, card information is processed by the relevant payment institution. Draw only stores limited payment metadata such as transaction ID, amount, currency, and the last four digits of the card. Demo payment mode does not process actual payments. Communication Data: Support requests, feedback, and email correspondence.
3. Purpose of Data Use
We process the personal data we collect for the following purposes: • Account creation, authentication, and service delivery • Processing payments and billing • Providing customer support and responding to requests • Product improvement and debugging • Security, fraud prevention, and maintaining system integrity • Fulfilling legal obligations • Sending service updates and important notifications (your separate consent will be obtained for marketing purposes)
4. Third-Party Services
We work with the following third-party providers to deliver our services: Google Firebase: Authentication, database, and file storage. (firebase.google.com/support/privacy) Payment Provider: The authorized payment institution whose name and privacy link are also displayed on the payment screen when live payments are enabled. Vercel: Application hosting and CDN. (vercel.com/legal/privacy-policy) Cloudflare R2: File and media storage. These providers process data under their own privacy policies. You can review the links above for information about these providers.
5. Cookies
Draw uses cookies to provide its services and improve the user experience. For detailed information about the types of cookies we use and your management options, please review our Cookie Policy.
6. Data Retention Period
Your account data is retained in our system as long as your account is active. If you delete your account, your data will be permanently deleted within 30 days; backup copies may be retained for up to 90 days unless required by legal obligations. Usage log data is stored for a maximum of 12 months, and payment records are stored for 10 years as required by tax regulations.
7. Your Rights
Under KVKK and GDPR, you have the following rights: • To access your personal data and request a copy • To request correction of inaccurate or incomplete data • To request deletion of your data ("right to be forgotten") • To restrict or object to data processing • Data portability (to receive your data in a machine-readable format) • To withdraw consent for electronic commercial communications at any time To exercise these rights, you can write to info@91.com.tr. Your requests will be answered within 30 days.
8. Data Security
We implement industry-standard security measures to protect your personal data: • All data transfers are protected with TLS/SSL encryption • Passwords are securely protected in a one-way manner by Google Firebase Authentication • Production systems are subject to regular security audits • Employee access to data is restricted based on the "need-to-know" principle In case of a suspected security breach, you can immediately notify us at info@91.com.tr.
9. International Data Transfers
Your data may be processed on servers located in Turkey, as well as in the European Union and the United States. These transfers are carried out within the framework of appropriate safeguards under Article 9 of KVKK and Chapter V of GDPR.
10. Policy Updates
This Privacy Policy may be updated from time to time. You will be notified of significant changes via your registered email address. The current version of the policy will continue to be published at www.draw.tr/gizlilik. Last updated: March 16, 2026
11. Contact
For questions and requests regarding privacy: Email: info@91.com.tr Address: Doksanbir Reklam Prodüksiyon Yazılım Yayıncılık ve Danışmanlık A.Ş., Bahçelievler Mah. Doktor Cevdet Kara Cad. E blok No B24/A Gölbaşı/Ankara Phone: 0540 911 91 91 Your right to lodge a complaint with the Personal Data Protection Authority (kvkk.gov.tr) is reserved.