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International Data Transfer Notice
Placeholder transparency notice: international transfers are documented when providers are activated. Lists categories of possible recipients without inventing destinations or claiming transfers are complete.
This text is a draft for counsel review. Screens alone do not make Picom “KVKK compliant” or “GDPR certified”.
Controller information
This notice cannot be published as active until required controller fields are configured. Missing: legalName, registeredAddress, tradeRegistry
- Legal name
- —
- Registered address
- —
- Trade registry
- —
- General contact
- info@picom.gg
- KVKK contact
- info@picom.gg
- GDPR contact
- info@picom.gg
- DPO
- —
- EU representative
- —
- TR representative
- —
Summary
- Some Secret Community processing may involve service providers that store or access data in more than one country.
- Picom does not activate a provider before transfer and processor documentation is completed.
- When transfers outside Türkiye, the EEA or another applicable jurisdiction occur, Picom records destination, recipient, data categories and safeguards.
- This notice lists categories of possible recipients; specific destinations are published when providers are activated.
- Do not read this draft as a claim that all transfer mechanisms are already in place for every provider.
- Controller contact details appear in Controller information.
Full notice
Status of this notice
This is an initial transparency notice for counsel review. International transfers are documented when relevant providers are activated. Until a provider is activated with completed transfer documentation, Picom does not rely on invented destination countries or unverified transfer claims.
Categories of possible recipients
Personal data may be shared only where necessary with categories of recipients such as:
- Hosting and infrastructure providers
- Telephone and verification providers
- Email and notification providers
- Security and fraud-prevention providers
- Customer support providers
- Professional advisers
- Competent public authorities where legally required
- Other processors acting under written instructions
What is recorded when a transfer is activated
For transfers outside Türkiye, the EEA or other applicable jurisdiction, Picom intends to determine the applicable transfer mechanism, record the destination country and recipient, record the categories of data transferred, implement required contractual safeguards, perform transfer-risk assessments where required, and apply technical safeguards such as encryption and pseudonymisation. An understandable transfer summary will be published for activated providers.
Community roles are not unrestricted recipients
Community owners and moderators are not automatically permitted to access users’ telephone numbers, verification evidence or internal risk data.