Privacy Policy
Privacy Policy
Effective Date: 08/08/2025
Last Updated: 08/08/2025
HW Club Danışmanlık Ticaret İthalat İhracat Limited Şirketi (“Company”, “Tilky”, “we” or “us”) values the privacy and security of personal data obtained through its website located at www.tilky.app (“Website”) and its mobile application named “Tilky” (“Mobile App”).
This Privacy Policy has been prepared in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”), applicable regulations, and the requirements of global application marketplaces, including the Apple App Store and Google Play Store.
1. Personal Data We Collect
To provide our services, the following categories of personal data may be processed:
Identity Information
Name, surname, username
Contact Information
Email address, phone number
User-Provided Financial Information
Financial information voluntarily entered by the user for personal tracking and planning purposes, including information related to movable and immovable assets (such as houses, land, and vehicles), cash assets, savings, investment-related values, goals, and plans.
Tilky does not collect or store bank account numbers, credit card numbers, CVV codes, or similar payment credentials.
All payments and subscriptions are processed securely by the relevant application marketplaces (Google Play / Apple App Store).
Transaction Security Data
IP address, device information, operating system, application version, access date and time, and in-app interaction data
Visual Data
Profile photo, if uploaded by the user
Cookies And Similar Technologies
Data collected through cookies and similar technologies during the use of the Website and Mobile App
Tilky does not intentionally collect, classify, or process special categories of personal data (such as religious beliefs, sexual orientation, or association memberships).
2. Purposes Of Processing Personal Data
Personal data may be processed for the following purposes:
Providing and operating the Mobile App and its features
Managing user accounts and authentication processes
Enabling users to organize their assets and link them to personal goals
Ensuring the security of the Website and Mobile App
Improving service quality and user experience
Fulfilling legal obligations
Tilky does not provide investment advisory services. All information presented in the App is intended solely for personal tracking, analysis, and planning purposes.
3. Sharing Of Personal Data
Tilky does not sell personal data.
Personal data may be shared only with:
Technical and infrastructure service providers (such as hosting and cloud service providers) strictly for the operation and maintenance of the App
Authorized public institutions and authorities, where required by applicable law
Personal data is not shared for advertising, marketing, or profiling purposes.
4. Data Security
Tilky implements appropriate technical and administrative measures to protect personal data, including secure server infrastructure, access controls, and encryption mechanisms.
Users are responsible for keeping their account credentials confidential.
5. Purpose And Limitations Of The Service
Tilky provides digital tools that help users better understand their financial situation and manage their assets in relation to their personal goals.
The services provided by Tilky do not constitute investment advice. Users are solely responsible for any decisions made based on the information obtained through the App.
6. Transfer Of Personal Data Abroad
Some technical services may be provided by third-party service providers whose data centers are located abroad (such as cloud infrastructure providers). In such cases, personal data may be transferred abroad in compliance with Article 9 of the KVKK and with appropriate safeguards in place.
7. Method And Legal Basis For Collecting Personal Data
Personal data may be collected through:
Use of the Website and Mobile App
User registration and account creation
Communication with the user
Cookies and similar technologies
Personal data is processed based on legal grounds such as compliance with legal obligations, necessity for the performance of a contract, legitimate interest, and explicit consent where required.
8. Children’s Privacy
Tilky is not intended for individuals under the age of 18. We do not knowingly collect personal data from individuals under 18. If such data is identified, it will be promptly deleted.
9. Your Rights
Pursuant to Article 11 of the KVKK, users have the right to:
Learn whether their personal data is processed
Request information regarding the processing of their personal data
Request correction or deletion of personal data
Object to processing that results in an unfavorable outcome
Request compensation in case of unlawful processing
Requests may be submitted, together with identity-verifying documents, in writing to
Yalıkavak Mah. Atatürk (Yalıkavak) Cad. No: 52/80 Bodrum / Muğla, via notary, or through our registered email (KEP) address: hwclubdanismanlik@hs01.kep.tr.
10. Data Retention Period
Personal data is retained for the period required by applicable legislation or as long as necessary for the purposes for which it is processed. Upon expiration of such periods, personal data is securely deleted, destroyed, or anonymized.
11. Cookies And Similar Technologies
Cookies are used on the Website and Mobile App to improve user experience. Users may manage cookie preferences through their browser settings. For more information, please review our Cookie Policy.
12. Contact
For any questions or requests regarding this Privacy Policy, you may contact us via:
Email: destek@tilky.app
Address: Yalıkavak Mah. Atatürk (Yalıkavak) Cad. No: 52/80 Bodrum / Muğla
Registered Email (KEP): hwclubdanismanlik@hs01.kep.tr
Contact Us
We’d Love To Hear From You.
Whether it’s feedback, partnerships or just to say hi.
hello@tilky.app