# Privacy Policy

> How JustOnAir processes personal data.

**Effective date: 6 October 2026**

The business named in the Legal Notice is the controller for the processing described below. We comply with the GDPR and with KVKK (Law No. 6698).

For personal data contained in our customers' content and viewer data, the customer is the controller and we are a processor. Requests about that data should go to the customer concerned.

## Data we process

| Data | Purpose | Legal basis |
|---|---|---|
| Name, email, company | Account and communication | Contract |
| Login and security data, IP addresses | Security, fraud prevention | Legitimate interest |
| Purchase and usage records | Billing, accounting | Contract, legal obligation |
| Abuse reports and moderation records | Enforcing our policies, legal compliance | Legitimate interest, legal obligation |
| Correspondence | Support | Legitimate interest |

We do not receive card details. We do not sell personal data. We do not use it for advertising.

## Recipients
- Our service providers (listed on our Sub-processors page).
- Our payment provider, Polar Software Inc.
- Authorities, where the law requires it.

## Transfers
Data is hosted in the EU. Some service providers are in the United States, and the Service is operated from Türkiye. Transfers rely on EU Standard Contractual Clauses, the EU–US Data Privacy Framework, or KVKK Article 9 safeguards, as applicable.

## Retention
- Account data: kept while the account is open, then deleted within 90 days of closure.
- Logs: kept for up to 30 days.
- Billing records: kept as long as tax and commercial law requires.
- Moderation records: kept for up to 2 years after the matter is closed.

## Your rights
Under the GDPR and Article 11 of KVKK, you have the right to:
- access your data;
- have it corrected;
- have it deleted;
- restrict its processing;
- receive it in a portable form;
- object to its processing.

Contact privacy@justonair.com. You may also complain to your supervisory authority, or to the Turkish Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu).

## Cookies
We use only a strictly necessary sign-in cookie. We do not use tracking cookies.

## Contact
privacy@justonair.com