DATA BREACH NOTIFICATION POLICY

Ultimate Global Compliance Edition – GDPR / KVKK / CPRA / LGPD / ISO 27001

Profylee (“Platform”, “Company”) recognizes the protection of personal data and system security as a top priority. This Data Breach Notification Policy (“Policy”) outlines the procedures for detecting, assessing, responding to, and reporting personal data breaches; as well as notifying users and regulators in compliance with international standards.

This Policy is prepared in accordance with GDPR Articles 33–34, KVKK, CPRA/CCPA, LGPD, OECD Privacy Principles, NIST Incident Response Framework, and ISO/IEC 27001 + 27701 requirements.

1. PURPOSE AND SCOPE

The purpose of this Policy is to ensure:

1. Timely detection of data breaches
2. 
   
3. Quick and effective mitigation of risk
4. 
   
5. Proper notification to regulatory authorities
6. 
   
7. Transparent communication with affected users
8. 
   
9. A clear, documented incident response process
10. 
    

This Policy applies to all Profylee modules, including:

1. AI-Powered Digital Identity
2. 
   
3. Works (Freelance Marketplace)
4. 
   
5. Flow & Pool (Hiring Pipeline)
6. 
   
7. Message
8. 
   
9. Wallet
10. 
    
11. Analytics & Insight
12. 
    
13. Showcase, Publish, Wall
14. 
    
15. Calendar (Google API) integrations
16. 
    
17. OpenAI anonymized AI processing
18. 
    

2. DEFINITIONS

Personal Data Breach:

Unauthorized access, disclosure, loss, theft, alteration, destruction, or compromise of personal data.

Unauthorized Access:

Any access performed without the data subject’s consent or valid legal basis.

Data Subject:

Any Profylee user (Client, Freelancer, individual user, company representative).

Supervisory Authority / Regulator:

GDPR Data Protection Authority (DPA), KVKK Authority, California Privacy Protection Agency, ANPD (Brazil), etc.

3. BREACH DETECTION & INITIAL ASSESSMENT

Profylee uses multiple mechanisms to detect possible data breaches:

1. Continuous log and event monitoring
2. 
   
3. Anomaly detection systems (IDS/IPS)
4. 
   
5. Suspicious login pattern alerts
6. 
   
7. Unauthorized data transfer detection
8. 
   
9. CDN / server-side irregular traffic monitoring
10. 
    
11. User or third-party reports
12. 
    

Upon suspicion of a breach, Profylee initiates an Immediate Preliminary Assessment.

4. INCIDENT RESPONSE TEAM (IRT)

In the event of a suspected or confirmed breach, the following team is activated:

1. Data Protection Officer (DPO)
2. 
   
3. Security & DevOps Team
4. 
   
5. Legal & Compliance Team
6. 
   
7. Communications Team
8. 
   
9. Executive Leadership
10. 
    

The IRT coordinates containment, investigation, communication, and remediation.

5. BREACH CLASSIFICATION

Profylee categorizes breaches into three levels:

1) Low-Level Incident

No personal data exposure; minimal/no risk.

(E.g., harmless system log anomalies.)

2) Medium-Level Incident

Potential exposure of personal data; moderate risk.

3) High-Level Incident

Confirmed or likely exposure of personal data to unauthorized parties.

→ Requires mandatory regulatory and user notification.

6. NOTIFICATION OBLIGATIONS

6.1. Notification to Supervisory Authorities

GDPR

High-risk personal data breaches must be reported to the relevant Data Protection Authority within 72 hours of detection.

KVKK (Turkey)

Breach must be reported to the KVKK Authority as soon as possible (commonly 72 hours).

CPRA/CCPA (California & U.S.)

Breaches affecting California residents must be notified as required under CPRA/CCPA.

LGPD (Brazil)

The ANPD must be notified within a “reasonable time” (typically 2–5 working days).

6.2. Notification to Users

Profylee notifies affected users without undue delay when:

1. Sensitive personal data is compromised
2. 
   
3. Account access or password integrity is at risk
4. 
   
5. Identity theft or fraud risk exists
6. 
   
7. Wallet or payment data is affected
8. 
   
9. Credentials, tokens, or session keys are exposed
10. 
    

The notification includes:

1. Nature of the breach
2. 
   
3. Categories of affected data
4. 
   
5. Potential risks to the user
6. 
   
7. Measures taken by Profylee
8. 
   
9. Recommended protective steps
10. 
    
11. Contact point for further information
12. 
    

Notification channels:

1. Email
2. 
   
3. In-platform notification
4. 
   
5. SMS (if necessary)
6. 
   
7. Public notice (in large-scale breaches)
8. 
   

7. INCIDENT RESPONSE ACTIONS

Upon detection of a breach, Profylee immediately:

1. Suspends access to affected systems
2. 
   
3. Resets passwords, API keys, tokens
4. 
   
5. Secures all log data as forensic evidence
6. 
   
7. Applies patches and blocks malicious traffic
8. 
   
9. Temporarily restricts user actions (if needed)
10. 
    
11. Notifies third-party providers (OpenAI, PayTR, Paddle, Google API, hosting providers)
12. 
    
13. Conducts forensic analysis to determine the scope
14. 
    

8. ROOT CAUSE ANALYSIS (RCA)

Profylee investigates:

1. How the breach occurred
2. 
   
3. Whether unauthorized access was intentional or accidental
4. 
   
5. Whether third-party providers were involved
6. 
   
7. Whether a configuration vulnerability existed
8. 
   
9. Whether the issue resulted from human error
10. 
    
11. What data categories were affected
12. 
    

Findings are documented in an RCA report.

9. POST-BREACH REMEDIATION

Following an incident, Profylee applies:

1. Systems hardening
2. 
   
3. Enhanced MFA / 2FA requirements
4. 
   
5. Strengthened encryption measures
6. 
   
7. Improved log and access monitoring
8. 
   
9. Security patching and code review
10. 
    
11. Staff training for security awareness
12. 
    
13. Legal action when necessary
14. 
    

10. DOCUMENTATION & RECORD KEEPING

As required under GDPR Article 33(5) and KVKK:

Profylee records every breach, including:

1. Date/time of incident
2. 
   
3. Nature and scope of the breach
4. 
   
5. Affected data categories
6. 
   
7. Mitigation steps taken
8. 
   
9. Notifications sent
10. 
    
11. RCA results
12. 
    
13. Remediation actions
14. 
    

Records are maintained for a minimum of 3 years.

11. USER RESPONSIBILITIES

Users must:

1. Use strong passwords
2. 
   
3. Avoid sharing credentials
4. 
   
5. Protect access to devices
6. 
   
7. Immediately report suspicious account activity
8. 
   
9. Avoid uploading harmful or unlicensed content
10. 
    
11. Secure third-party-linked accounts
12. 
    

12. POLICY UPDATES

Profylee may update this Policy based on:

1. Legal changes
2. 
   
3. Security requirements
4. 
   
5. Industry standards
6. 
   
7. Platform updates
8. 
   

Significant updates will be communicated to users.

13. CONTACT INFORMATION

For reporting a security incident or asking questions:

📩 [contact@example.com]