PRIVACY & COOKIE POLICY

1. Data Controller

The data controller responsible for your personal data is Niafix Ltd., incorporated in the United Kingdom. You can contact us at [email protected].

2. Data We Collect and Purposes of Processing

To provide Platform functionality and deliver a better experience, we collect only the minimum data necessary:

• Registration and Account Information: The email, username, password (stored in encrypted form), and full name you provide during registration are processed to create your account, verify your identity, and enable communication with you.
• Date of Birth (BirthDate): Processed to enforce our Platform's minimum age requirement of 13 (Age Limit) and to fulfil our legal obligations.
• Usage Metrics (Linked to User ID): Your reading and writing habits, pages visited, and interactions within the Platform are stored on our servers linked to your User ID. This data is processed to improve the Platform experience, algorithmically surface popular content, and provide personalised recommendations (under UK GDPR Article 6(1)(f) — Legitimate Interests).
• System and Error Logs: Technical errors and system logs encountered on the Platform are retained on our servers to ensure technical stability and resolve issues. These logs are processed for system security, prevention of cyber attacks, and optimisation of technical performance.
• Device Information and IP Address (Traffic and Consent Data): Each time you access the Platform, register, or accept agreements, your IP address, device type (mobile/desktop), operating system, browser information, and transaction timestamps are automatically logged by our systems.
  • Purpose and Legal Basis: This data is processed to prevent cyber attacks, ensure account security, and fulfil our legal cybersecurity obligations. In particular, your IP address and device information at the moment you accept the Terms of Service and Privacy Policy are stored in our database as part of a digital audit trail proving that the agreement was legally entered into and confirmed. This processing is carried out under Legitimate Interests for the protection of our legal rights and verification of contractual intent between the parties.

3. Data Retention and Security

• Your data is stored on our servers for as long as your Perabook membership remains active. If you delete your account, your personal data and usage metrics will be permanently deleted or anonymised within a reasonable period, except for data we are legally required to retain.
• Your passwords are stored using secure cryptographic algorithms with salting and hashing; no one, including company personnel, can view your password in plain text.

4. Sharing with Third Parties and International Data Transfers

• No Sale to Third Parties: As Niafix Ltd., we never sell or trade your personal data or usage metrics to third-party advertising companies.
• Infrastructure and Cloud Providers (AWS Frankfurt): We use world-class infrastructure to ensure the Platform runs continuously, quickly, and securely. Collected personal data, your book content, JWT cookies, and system logs are hosted on our cloud servers and AWS S3 storage services in the highly secure data centres of Amazon Web Services (AWS) in the Germany (Frankfurt) region (AWS Frankfurt Region).
• Cross-Border Data Transfers and GDPR Compliance: Because our company is based in the United Kingdom and our data hosting servers are located within the European Union (Germany), data of users in Turkey is technically considered an international cross-border transfer. The Germany (Frankfurt) data centres where your data is hosted are fully protected under GDPR (General Data Protection Regulation), one of the world's strictest data protection standards. By registering on the Platform, you expressly consent to your data being securely stored and transferred within the AWS Frankfurt infrastructure as required by this technical setup.
• Legal Obligations: If a lawful request is received from authorised judicial or administrative authorities (courts or law enforcement in the United Kingdom, Germany, or Turkey), necessary data may be shared to fulfil our legal obligations.

5. Cookies and Authentication Technologies

• Essential Cookie Usage (JWT): Perabook uses JWT (JSON Web Token) technology via cookies to enable you to log in on the Platform, verify your identity, and keep your account secure.
• Technical Necessity: These cookies fall under "Strictly Necessary / Essential Cookies" used solely for security and core Platform functionality (logging in, maintaining sessions).
• Acceptance and Terms of Use: Because the Perabook Platform depends on this technical infrastructure, JWT cookies are mandatory and cannot be disabled. By registering and logging in, you are deemed to have technically and legally accepted these essential security cookies being stored in your browser. If you block these cookies entirely in your browser settings, you will not be able to use Platform features that require authentication (writing books, managing your profile, etc.).
• No Advertising Cookies: Our Platform does not use marketing or targeting cookies belonging to third-party advertising networks that track you across the internet.

6. Your Rights (UK GDPR & KVKK)

Under applicable law, you have the following rights:

• To learn whether your personal data is being processed and to request information
• To request correction if your data is incomplete or inaccurate
• To request deletion or destruction of your data from our systems
• To object to a result against you arising from automated analysis of your data

To exercise your rights, you may submit a written request from the email address registered to your account to [email protected].

7. Updates to This Privacy Policy

Niafix Ltd. may update this Privacy Policy from time to time in line with technical changes in data processing, integration of new infrastructure providers (services outside AWS, etc.), or updates to legal regulations such as UK GDPR / KVKK.

• When a significant change is made to the Policy, you will be notified via the Platform or through your registered email address.
• Continued use of the Platform after the effective date of the updated policy means you accept processing of your data under the new terms. If you do not accept the changes, you have the right to terminate data processing by closing your account.