Who is responsible
The controller of your data is Torcul, in Türkiye. Email: info@torcul.com.
What we process
- Your manuscript and the files made from it, when you use the product, to make the files you ask for. They are deleted six hours after upload and are not used for anything else.
- The licence record, if you buy a licence: the key, Paddle's order and customer numbers, the date and the amount, your email address, the sentence you agreed to before paying and when, the first download of a paid file, and any refund or chargeback Paddle reports. When the key opens a book, the record adds the book's title and a fingerprint of its text that cannot be turned back into the text.
- Your email address, only to confirm your purchase, to send your key again if you lose it, and to tell you if the service is going to close. It is not shared, sold or used for marketing.
- Request logs: the time, path, response code and size of each request, without your internet address, kept for fourteen days. To limit abuse, your internet address is held in memory for sixty seconds.
- Mail you send us, for as long as it takes to deal with it.
There is no account, no analytics, no advertising and no tracking. The free tools run in your browser, and the files you open in them are not uploaded. What your own browser keeps stays on your device: your light or dark choice and, if you bought a licence, the key. This site sets no cookies of its own. Cloudflare may set security cookies to tell people from bots, and Paddle's checkout sets its own when you pay.
Why, and on what basis
- To provide the files and the licence you asked for (GDPR Article 6(1)(b); KVKK Article 5(2)(c)).
- To keep the service secure and available, and to establish or defend a claim about a purchase, such as a refund (GDPR Article 6(1)(f); KVKK Article 5(2)(e) and (f)).
- An email address is needed to buy a licence, because the key is sent to it.
- No automated decision with a legal or similarly significant effect is made about you.
Who receives it
- Paddle (Paddle.com Market Ltd, United Kingdom) sells the licence as merchant of record. Paddle collects your payment details itself, as a controller in its own right, under its privacy notice, and sends us your email address, the order number and its customer number.
- Service providers who process data on our behalf: server hosting, network and security, email delivery, the mailbox, and encrypted backup storage.
- Public authorities, where the law requires it.
These providers are in the United Kingdom and the United States. The European Commission recognises the United Kingdom as protecting personal data to the EU standard. It recognises the same of American companies certified under the EU-U.S. Data Privacy Framework, and the ones we use are. We run the service from Türkiye, for which there is no such decision.
How long
- Your manuscript and the files made from it: six hours.
- Request logs: fourteen days.
- Internet addresses, to limit abuse: sixty seconds, in memory.
- The licence record: as long as the service runs, because it keeps your book opening. The email address on it goes sooner if you ask.
- Copies of the mail we send, at the delivery provider: thirty days.
- Mail you send us: as long as it takes to deal with it.
Your rights
You may ask what we hold about you, and ask for it to be corrected, deleted, restricted or given to you in a portable form, or object to its use. The GDPR gives you these rights in the European Union and the United Kingdom, and KVKK Article 11 in Türkiye.
Write to info@torcul.com and we answer within thirty days. You may also complain to the data protection authority where you live or work. In Türkiye, that is the Personal Data Protection Authority (KVKK).
Changes
When this notice changes, the date below changes with it.