ScopeFocus
Last updated: September 2026
A clarification notice (aydınlatma metni) under Personal Data Protection Law No. 6698, and the information required by Articles 13 and 14 of the General Data Protection Regulation (EU) 2016/679. Both are covered here, section by section.
KVKK applies where personal data is processed in Türkiye, and to the processing of data belonging to people in Türkiye. The GDPR applies where the processing relates to offering the product to people in the European Union or the EEA, regardless of where the controller is established. Both can apply to the same person at once, and where they do the more protective rule is the one followed. Everything below names the provision in each.
Innovative Teknoloji is the data controller (veri sorumlusu under KVKK, controller under GDPR Article 4(7)) for personal data processed through ScopeFocus and TabletX. Where an organisation deploys TabletX at its own premises and decides why and how its members' results are processed, that organisation is the controller for those results and Innovative Teknoloji acts as its processor (veri işleyen; processor under Article 4(8)). Innovative Teknoloji is established in Türkiye and not in the European Union; where the GDPR applies, Article 27 requires a representative in the Union unless an exemption applies, and whether one is designated is stated in the application section below.
Processing rests on Article 5 of the Law, and on the corresponding ground in Article 6(1) of the GDPR. The two sets line up almost exactly, so each is named once below:
Data is transferred to service providers only so far as the product needs them to work, and never sold. Some of these providers process data outside Türkiye and outside the European Economic Area. Both regimes govern that. KVKK Article 9, as amended in 2024, allows a transfer abroad on an adequacy decision, failing that on one of the appropriate safeguards it lists, and failing that on one of the exceptional grounds in Article 9(6) - of which explicit consent is one. GDPR Chapter V is built the same way: Article 45 adequacy, Article 46 appropriate safeguards such as standard contractual clauses, and the Article 49 derogations. Which instrument covers each provider below is a matter for the controller's records and for counsel; this notice does not assert one.
Data is collected electronically, through the browser or the TabletX application, as you play, sign in or request a report. Results are written to the device first; they leave it only where sync or a report is requested.
ScopeFocus is used by children from about five years old, under the supervision of a parent, guardian or professional, who is responsible for the account and for consenting on the child's behalf. Under GDPR Article 8 a child can consent to an information society service on their own at 16, and a member state may set that age lower but never below 13; below whichever age applies, consent must be given or authorised by the holder of parental responsibility. The product does not ask a child for consent: a player is claimed by an account, and where a school or clinic deploys it the organisation's own lawful basis and its agreement with the guardian govern. A guardian who wants everything about a child removed can do it from the owning account, and local results can be cleared from the browser without asking anyone.
The first seven are Article 11 of KVKK and have a GDPR counterpart; the last four exist under the GDPR and are marked, because KVKK does not grant them and it would be misleading to imply otherwise.
Write to the data controller in Turkish or English, with enough detail to identify you and the request. Under KVKK Article 13 an application is answered within thirty days at the latest, free of charge unless it requires a cost. Under GDPR Article 12(3) a request is answered without undue delay and in any event within one month, extendable by two further months for complex requests, and free of charge unless the request is manifestly unfounded or excessive. Whichever deadline is shorter for you is the one that applies. If you are not satisfied: under KVKK you may complain to the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu); under GDPR Article 77 you may complain to the supervisory authority of the member state where you live, work, or where the alleged infringement took place, and under Article 79 you have a judicial remedy.
Send applications to Innovative Teknoloji. Requests to delete synced results can also be made from the profile page, and local data can be cleared from your browser at any time without asking anyone.