Bu sayfanın Türkçesi: Türkçe sürüm
Essah
Essah › Legal

Data Processing Agreement

Effective and last updated: 12 October 2026 · Version: 2026-10-12 · Print / PDF

This English text is a translation provided for convenience. Where the Turkish version differs, the Turkish version prevails for users in Türkiye.

1. Roles and scope

The organising institution is the controller for data it enters about contestants and teams (names, photos, scores); Pingel is a processor acting on its behalf. For the organiser's account and payment data, Pingel is the controller.

This agreement sets out Pingel's (processor) obligations under KVKK Art. 12 and GDPR Art. 28 for personal data the Customer (controller) uploads to or processes through the service, and forms an annex to the Service and Subscription Agreement.

2. Subject of processing

Subject: organising and presenting the live competition. Duration: the account/package term. Data subjects: contestants (including students) and jury members. Data types: names, team names, photos/avatars, scores. No special category data is processed.

3. Pingel's obligations

4. Customer's obligations

5. Sub-processors

ProviderPurposeLocation
Google Firebase / Google Cloud (Google Ireland Ltd., Google LLC)Hosting, authentication, database, server functionsEU and/or US data centres
Google Gemini API (Google LLC)AI features: the text or transcript you submit is processedUnited States
Cloudflare, Inc.Hosting, content delivery, DNS, attack protectionGlobal network (US-based)
BanksReceiving and verifying bank-transfer paymentsTürkiye

6. International transfers

Some sub-processors are outside Türkiye. Transfers rely on appropriate safeguards such as standard contracts and the providers' data processing terms under KVKK Art. 9 and GDPR Chapter V.

7. Entry into force

This agreement takes effect when the Customer electronically accepts the service agreement and remains in force for its term. Institutions needing a signed copy can request one at hasan@pingel.dev.