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Çiftçi AI — Explicit Consent Statement

Data controller / Service provider: HNK Tech

Application: Çiftçi AI (com.ciftciai.app)

Effective date: 14.08.2026 · Version: 1.0


What this document is for

Article 5/1 of Law No. 6698 on the Protection of Personal Data (KVKK) provides that

certain personal data may only be processed with your explicit consent. Under the

law, explicit consent must be "related to a specific subject, based on information,

and declared with free will." In practice:

checkbox that approves everything at once (bundled consent) is unlawful.

what it is used for, and who receives it. This document is that information.

keep using the application; only the feature tied to that consent will not work.

For this reason Çiftçi AI has three separate consents. Each is approved on its own

screen with its own button. Approving one does not mean you approved another, and

withdrawing one does not affect the others.

> Important: The core functions of the application (registration, weather, community,

> classified ad board, messaging, field journal) depend on none of these consents.

> They rest on the legal grounds of the establishment and performance of a contract and

> legitimate interest (KVKK art. 5/2). The three headings below cover additional features

> only.

This document should be read together with the Çiftçi AI Privacy Notice. The Privacy

Notice answers "what we process and why" as a whole; this document details only the three

consent-based subjects.


Overview of the consent headings

#Consent headingWho it concernsIf you decline
1Identity verification dataUsers applying for the worker or trader roleThe worker or trader role is not opened; you continue using the app as a farmer
2Location and field boundaryAnyone who registers a fieldSatellite, weather and fire alerts do not work
3Transfer abroad (artificial intelligence)Users of the AI advisor and disease detectionYour questions go only to the local model on our server; some questions may go unanswered

1. Explicit consent for processing identity verification data

> Who this concerns: Only users applying for the worker role or the trader

> role. If you use the application as a farmer, this consent is not requested from you.

Data to be processed

document (national ID card) (worker role only)

Purpose of processing

1. To verify that the identity you present is genuinely yours. We need to be able to

tie timesheet and wage records to a real person, and to know that a trader account

belongs to a genuine commercial identity.

2. To prevent fake accounts, fraud and identity theft. The only thing protecting

farmers and their co-workers is that the other party has been verified.

Who it is transferred to

It is transferred to no third party. Identity document images are stored

on HNK Tech servers and are viewed only by personnel authorised for

verification, only for the duration of the verification process. These images are not

sent to artificial intelligence models, are not passed through the disease detection

system, and are not shown to other users.

Transfer may occur in the event of a judicial request or a lawful written request from a

competent public authority; this rests on a legal obligation rather than on explicit

consent (KVKK art. 5/2-a).

Retention period

SituationRetention
Your application was approvedAs long as the role is active + 6 months after the account closes (objection period)
Your application was rejected6 months from the rejection notice, then destroyed
You withdrew your consentDestroyed within 30 days at the latest

Once verification is complete, identity document images may be destroyed so that only

the verification result (approved / rejected) is retained. We keep the result, not

the image.

If you do not consent

to a verified identity.

community, ad board, messaging, disease detection and the AI advisor all remain open.

only for the "verified" badge and worker/trader features.

Withdrawing consent

You can withdraw it with a single tap from **Profile > Legal > My Consents > Identity

verification data**. When you withdraw:

left aggrieved; no new ones can be created.


2. Explicit consent for processing location data and field boundaries

> Who this concerns: All users who register a field or use satellite analysis,

> weather or fire alerts.

Data to be processed

only if you grant location permission

yourself on the map (GeoJSON)

weather records

Purpose of processing

1. Satellite analysis. We send your field boundary to Google Earth Engine to compute

the satellite imagery and crop development indices for that area.

2. Weather forecasting. We send the centre coordinate of your field to the weather

service to obtain a forecast specific to that point.

3. Fire alerts. To warn you if there is a satellite-detected fire source near your

field, we compare your coordinate against a fire data service.

4. Showing content near you. Ads, farm labour listings and community posts in the

same district.

5. Tying the field journal and soil analysis to a location.

Who it is transferred to

RecipientWhat is sentWhat is not sent
Google LLC — Google Earth Engine (USA)Coordinates of the field boundary polygon and a date rangeYour name, phone number, e-mail, account identifier
Open-Meteo (Germany, EU)Only a latitude/longitude pairField boundary, identity information
NASA FIRMS (USA)Only a latitude/longitude pairField boundary, identity information
Stadia Maps (EU)The region of the map tile being displayedField boundary, identity information

Your identity information is not sent to these services. On the service side the

request amounts to the question "what is at this coordinate"; it cannot be associated

with you.

Google LLC and NASA FIRMS are based in the USA; this transfer therefore constitutes a

transfer abroad and is subject to your explicit consent under KVKK art. 9.

> **Location data is under no circumstances sold, used for advertising, or transferred to

> data brokers. Your field boundaries are not shown to other users** — only you and the

> people you share the field with can see them.

Retention period

forecast is retrieved); it is not stored permanently.

that you can make historical comparisons; if you delete the field they are deleted with it.

If you do not consent

This is the consent that affects the largest number of features. We will say it plainly:

Will not work:

Continues to work:

You can create a field without consenting; you simply cannot draw a boundary on the map

or use the satellite and weather services.

Withdrawing consent

You can withdraw it from Profile > Legal > My Consents > Location and field boundary.

You can also turn off the application's location permission in your device's operating

system settings — this immediately stops the collection of instantaneous location.

When you withdraw consent:

data** option on the same screen.


3. Explicit consent for transfer abroad — artificial intelligence providers

> Who this concerns: All users of the AI advisor and plant disease detection features.

> This is the section that should be read most carefully.

Data to be processed and transferred

conversation

(at province level), season information

How it works — the technical flow

Çiftçi AI first asks your question to the **local artificial intelligence model on its

own server** (Ollama). If the local model cannot produce an answer, or the confidence

level of the answer it produces is low, the question is **forwarded to an artificial

intelligence provider located abroad. So not every question goes abroad — but you

cannot know in advance which question will.** Because of this uncertainty we ask for your

consent to cover the possibility that it may.

Who it is transferred to

ProviderHeadquartersTransferred
Google LLC (Gemini)USAQuestion text, plant photograph
OpenAI, L.L.C.USAQuestion text, plant photograph
Anthropic, PBCUSAQuestion text, plant photograph

What is sent and what is not

Not sent:

Sent: Only the question itself, the plant photograph, and the agricultural context

needed for the answer to be correct. The request is not associated with you by name.

> Take care when uploading a plant photograph: If your face, your identity document,

> your vehicle plate or the sign of your home or business happens to appear in the photo,

> that image will also have gone abroad. We recommend photographing only the diseased part

> of the plant. Location metadata (EXIF) is stripped from photographs before they are sent.

The legal status of transfer abroad

Under KVKK art. 9, personal data may be transferred abroad only if (a) the data subject

has given explicit consent, (b) the destination country provides adequate protection, or

(c) safeguards such as a written undertaking or standard contract have been provided.

The USA has not been declared a "country with adequate protection" by the Personal

Data Protection Board. We therefore base this transfer on your explicit consent.

What this means in concrete terms: your data is processed on the servers of a company

subject to US law. There is a possibility that US authorities may, within the framework of

their own legislation, request access to that data. Exercising the rights KVKK grants you

against these companies may not be as straightforward as it is in Türkiye.

Contracts have been concluded with the providers at the enterprise / API level so that

your data is not used for model training. However, HNK Tech **cannot

physically audit** the implementation on those companies' own servers and cannot present

this to you as an absolute guarantee. We state this openly in the interest of honesty.

Retention period

or close your account.

policy for abuse monitoring (typically up to 30 days), then deleted. That period is under

the provider's control.

If you do not consent

warning **"This question requires a provider abroad; it cannot be answered because you

have not given consent"** — it does not silently return an empty answer.

where the external models are strongest.

satellite, weather, community, ad board, messaging, timesheets.

Withdrawing consent

You can withdraw it from Profile > Legal > My Consents > Transfer abroad. From the

moment you withdraw, no new question or photograph is sent abroad. Requests already sent

cannot be recalled — this is not technically possible; the provider's own deletion period

applies.


Warning about artificial intelligence advice

None of these consents contains any undertaking as to the accuracy of the agricultural

advice given by the artificial intelligence. Information produced by Çiftçi AI is **for

informational purposes**; it does not replace the advice of an agricultural engineer, a

veterinarian, or an official authority. Always consult a qualified expert for your

decisions on pesticide application, fertilisation and animal health. This warning is also

displayed inside the application.


Managing your consents

Where

Profile > Legal > My Consents

On this screen you see each of the three consents separately:

The effect of withdrawal — it has no retroactive effect

Under KVKK, explicit consent can be withdrawn at any time. However, withdrawal of

consent operates prospectively: processing carried out up to the date of withdrawal

was based on a valid consent at the time and is therefore lawful, and does not become

unlawful retrospectively.

A concrete example: you gave consent for transfer abroad on 1 March and withdrew it on

1 June. Questions that went abroad between March and June were processed lawfully. After

1 June no new question is sent.

How long a withdrawal request takes to process

OperationTime
Stopping the consent-based processingImmediately (the moment you press the button)
Destruction of the relevant data from the systemWithin 30 days at the latest
Response to a written applicationWithin 30 days at the latest (KVKK art. 13)

If you cannot access the application, you can send a request to

[email protected] from the e-mail address or phone number registered to your

account.

Consent records

Under our legal obligation we must be able to prove that you gave and withdrew consent

(KVKK art. 12). We therefore record the following for every consent action:

This record is the evidence of the consent itself; even if you withdraw the consent, **the

record itself is not deleted** — because if it were, we could not prove that we obtained

the consent properly and stopped processing on time. The record is kept on the basis of a

legal obligation (KVKK art. 5/2-a) and retained for the duration of the limitation period.


If the consent text changes

If the scope of this text expands (a new data type is added, or transfer to a new recipient

begins), your existing consent is not deemed valid for that new scope. You will be

informed again inside the application and a new consent will be requested. If you do not

approve it, only the new feature stays closed; your existing use is unaffected.

For updates that do not change the scope — such as a typographical correction or a clearer

explanation — consent is not requested again; the version number and date are updated.


Age limit

Çiftçi AI is intended for users aged 18 and over; it is not directed at anyone under 18.

If you are found to be under 18, your account is closed and your data is destroyed.


Your rights under KVKK art. 11

In relation to your personal data, you have the right to:

the data was transferred,

You can submit your applications to [email protected] or to the registered

electronic mail (KEP) address —. Your application will be concluded within

30 days at the latest (KVKK art. 13). If you are not satisfied with the outcome, you

retain the right to lodge a complaint with the Personal Data Protection Board (KVKK art. 14).


Contact

Data controller: HNK Tech

E-mail: [email protected]

Registered e-mail (KEP): —

Address: Akyurt / Ankara, Türkiye

MERSİS No: —

Tax Office / Number: —

VERBİS Registration No: kayıt yükümlülüğü bulunmamaktadır


Sürüm 1.1 · Çiftçi AI