EPlusHubPrivacy Policy
- EPlusHub is developed and operated by KOD48, the data controller for the data described here.
- We process your account details and the project, finance and document data your organisation enters, to provide the service.
- We do not sell your data or show ads; the app contains no advertising or tracking tools.
- Our servers are in Germany; emails are sent through a US-based service.
- You can delete your account from inside the app at any time.
1. Scope and data controller
This policy applies to the EPlusHub app ("App"), developed by KOD48 and published on the App Store and Google Play, and to eplushub.kod48.com. Data controller: Öznur Özdemir – KOD48 (sole proprietorship), Milas / Muğla, Türkiye, email: kodkirksekiz@gmail.com.
Schools, associations and institutions use the App to manage Erasmus+ and similar grant projects. For third-party data your organisation enters (for example details printed on receipts), your organisation is the data controller and KOD48 processes that data on its behalf and instructions as a data processor.
2. Data we process
| Data | Examples |
|---|---|
| Account | Full name, email address. Your password is stored only as a one-way hash; we cannot read it. |
| Memberships and roles | Your role in each organisation and project; invitations you send and receive (the invitee's email address). |
| Organisation and project details | Name, address, phone and logo of the organisation; project name, number, dates, budget, partner organisations, mobilities (country, dates). |
| Finance records | Date, description, amount, currency, exchange rate used, supplier, payment method, who paid, notes. |
| Documents | Photos or PDFs of receipts and invoices. These may contain information about other people. |
| Activity records | Who added, changed, deleted, checked or locked which record and when; membership and role changes. |
| Technical logs | Logs kept on the server for sign-in and security (such as IP address and timestamps). |
We do not collect your location, contacts or advertising ID; the App has no analytics, advertising or behavioural tracking. The camera and photo library are accessed only when you choose to attach a receipt, and only for the document you select.
3. Purposes
- Creating your account, signing you in and protecting it.
- Storing your organisations, projects, finance records and documents, sharing them with your team and producing reports.
- Emailing you about invitations, role changes, removal from a team and account deletion.
- Keeping records traceable to who entered or changed them.
- Answering support requests and meeting legal obligations.
4. Legal grounds
Under Article 5 of Turkey's Personal Data Protection Law No. 6698 ("KVKK"), we process your data because it is necessary to perform a contract (providing the service), to comply with legal obligations, and for legitimate interests (security, activity records) provided your fundamental rights are not harmed.
5. Who sees your data and with whom it is shared
- Within your organisation: data is visible only to authorised members of the relevant organisation and project, as far as their role allows. The organisation owner can see the organisation's activity log.
- Hosting: the App's database and files are hosted on servers of Leaseweb Deutschland GmbH in Germany.
- Email delivery: notification emails sent by the App (invitations, role changes, removal from a team, account deletion confirmation) are delivered through Resend, Inc. (USA). For this, the recipient's email address and the email content, i.e. the names of the recipient and of the person who made the change and the organisation and project names, are transferred. Finance records, documents and receipts are never sent by email.
- Exchange rates: rates are fetched from the Central Bank of the Republic of Türkiye; no personal data is sent.
- App stores: downloading the App is subject to Apple's and Google's own terms.
- Legal requirements: lawful requests from competent authorities.
We do not sell your data or use it for advertising.
6. International transfers
Because our servers are in Germany and our email service is in the USA, your data is transferred abroad. Our assessment of the legal basis for these transfers under KVKK Article 9 is ongoing. The App is currently used only by a limited test group; before it opens to general use, this section will be updated to state the basis explicitly.
7. Retention
- Your account and memberships are kept while your account exists and are deleted when you delete it.
- Finance records and documents belong to your organisation; they stay with the organisation after you delete your account, with the link to your name removed.
- The organisation's activity log and membership records may keep your name and email as they were at the time of an action, as the organisation's audit trail.
- When an organisation is deleted, all of its projects, finance records and documents are deleted.
- The system is backed up automatically every day. Backups are kept for at most 14 days; deleted data also leaves the backups at the end of that period.
8. Security
All traffic between the App and the server is encrypted (HTTPS). Server-side rules limit who can see and change what. Joining a team requires a personal, email-bound, single-use invitation code that expires. Passwords are stored as hashes.
9. Your rights
Under Article 11 of the KVKK you may ask whether your data is processed, request information about it, learn the purpose of processing and whether it is used accordingly, know the third parties it is transferred to in Türkiye or abroad, ask for correction of incomplete or inaccurate data, ask for deletion or destruction under Article 7 and for these actions to be notified to recipients, object to a result against you arising solely from automated analysis, and claim compensation for damage caused by unlawful processing.
Send requests from the email address registered in the App to kodkirksekiz@gmail.com. We answer within 30 days at the latest.
10. Children
The App is intended for staff who manage projects at organisations; it is not intended for anyone under 18.
11. Changes
When we update this policy, the new version is published on this page with its date.
12. Contact
kodkirksekiz@gmail.com. See also the KVKK information notice and account deletion.