Privacy Policy

Draft. This text is a draft and is awaiting approval by the company's lawyer. Fields marked [DOLDURULACAK] ("to be completed") will be filled in before publication.

Last updated: 13 November 2026

This is the English version of our Turkish privacy policy, Gizlilik Politikası. If the two texts differ, the Turkish text prevails.

This page explains which of your data we read when you apply to 51 Capital and use this site, why we read it, who sees it, how long we keep it and how you can have it deleted. If anything is unclear, write to us.

1. In short

• When you connect your channel we read three things from YouTube: your channel's general information, its viewing statistics and its revenue statistics.
• We ask for read-only permission. With this connection we cannot upload or delete videos or change any setting.
• Only you and the 51 Capital evaluation team see your data.
• We do not sell your data, we do not use it for advertising, and we do not combine it with other creators' data.
• You can disconnect at any time. When you do, we delete your channel data at once.
• Your data is stored on servers outside Türkiye. Section 7 has the details.

2. Who we are

51 Capital is a growth programme for YouTube creators run by 51 Digital. The company responsible for the personal data processed on this site (the data controller) is:

• Trade name: Elli Bir Dijital İletişim Yayın ve Reklam Hizmetleri Limited Şirketi
• MERSİS number (Turkish central registry number): [DOLDURULACAK: MERSİS number]
• Address: Noramin İş Merkezi, Maslak, Sarıyer, İstanbul, Türkiye
• KEP address (registered e-mail): [DOLDURULACAK: KEP address]
• E-mail: 51capital@51digital.com

In this text "we" and "51 Capital" mean this company. The notice required by the Turkish Personal Data Protection Law No. 6698 ("KVKK") is published separately as the KVKK Aydınlatma Metni (in Turkish).

3. What data we collect

3.1 When you sign in with your Google account

Google gives us your name, your e-mail address, the address of your profile picture and the identifier of your Google account. We never see your password; you sign in on Google's own page.

3.2 When you connect your YouTube channel

51 Capital uses YouTube API Services. On Google's consent screen you will see three permissions. All three are read-only. Below is what we read with each one and why.

Channel information (youtube.readonly)

• Data we read: your channel's ID, title, handle, profile image, country and creation date; its total subscriber, video and view counts. The ID, title, thumbnail, publication date and duration of your 25 most-viewed videos of the last 12 months.
• Why we read it: to show you that you connected the right channel; to build the channel card and the table of most-viewed videos in your report.

Viewing statistics (yt-analytics.readonly)

• Data we read: for the last 13 full months, monthly views, watch time, subscribers gained and subscribers lost; for the whole channel and split into long videos, Shorts and live streams. For the last 12 months, views and watch time of your 25 most-viewed videos, and the breakdown of views by traffic source and by your 10 top countries.
• Why we read it: to show your channel report; to check the application criterion; to let our team evaluate your application.

Revenue statistics (yt-analytics-monetary.readonly)

• Data we read: for the last 13 full months, the monthly estimated revenue reported by YouTube, in US dollars.
• Why we read it: to show you your monthly revenue in your report; to confirm that monetisation is enabled on your channel; to let our team evaluate your application.

Every figure we read is YouTube's own figure. We only take sums and averages of these figures. We do not produce scores, forecasts or any other derived metric from them.

To keep the connection working we also store the access tokens issued by Google. They are stored encrypted and are never sent to your browser.

What we do not read with this connection: your video files, comments, the identities of your viewers, or other services in your Google account (such as Gmail or Drive).

3.3 Your application and your offer

• The note you write when you apply, and the status and dates of your application.
• The inputs and the result of the criterion check: the views of the last 3 full months, the threshold and the result.
• The boxes you ticked, when you ticked them and the version of the text on that day.
• If we sent you an offer: its content, when you opened the page, and your answer.

3.4 When you fill in a form or write to us

• Application form: your name, e-mail address, channel address and, if you write one, your note.
• Contact form: your name, e-mail address, your channel address if you gave it, and your message.
• The content of any e-mail you send us.

3.5 E-mails we send you

We keep a copy of every e-mail we send: recipient address, subject, content, date and delivery status.

3.6 Technical data

• The cookie that keeps you signed in. See the Cookie Policy (in Turkish).
• To prevent abuse, a hash derived from your IP address that changes every day. We do not write the IP address itself to our database.
• Connection logs that our hosting provider keeps for a limited time for the operation and security of the site: IP address, browser type and time of request.
• A record of who looked and when, every time our evaluation team views your channel data.
• A simple cookie-free counter: how many times each page was opened on each day, and how many applications were started. It holds nothing that identifies you.

3.7 Measurement tools (only if you agree)

If you accept in the cookie preferences, Google Analytics and Meta Pixel run on the marketing pages. They never run on the application page, in your panel or on any screen that shows channel data. See the Cookie Policy.

4. What we use your data for

1. To show your channel report. The report shows the last 12 months of your channel in YouTube's own figures.
2. To check the application criteria. We compare the views of the last 3 full months with the threshold published on the site, and we check whether monetisation is enabled on your channel. This check is automatic and is the only automatic decision on the site. If you think the result is wrong, write to us and our team will look at it.
3. To evaluate your application. Our evaluation team looks at your report and decides whether we can make you an offer. The terms of an offer are set by our team; an offer is not computed automatically from this data. At the offer stage we may ask you for "Viewer" access in YouTube Studio to confirm revenue figures. You grant that access yourself in YouTube Studio and can remove it at any time; it is separate from the connection on this site.
4. To communicate with you. We send you information about your application and your offer by e-mail and answer your questions. We do not send marketing e-mails; if we ever want to, we will ask for your separate permission first.
5. To keep the site secure. We manage your session, prevent abuse and log access.
6. To meet our legal obligations and, where necessary, to protect our rights.

We do not use your data:

• To show you ads, to target ads or to track you on other sites.
• To sell it, or to transfer it to advertising platforms, data brokers or other companies.
• To combine it with other creators' data or to produce comparisons between channels.
• To produce a score, a forecast or a profile about you.
• To determine credit-worthiness or for lending purposes.

If we ever need to go beyond these purposes, we will tell you first and ask you to accept this policy again.

5. YouTube API Services and Google user data

• 51 Capital uses YouTube API Services to read channel data. By connecting your channel you also agree to be bound by the YouTube Terms of Service.
• You can read how Google handles your data in the Google Privacy Policy.
• 51 Capital's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. We do not transfer this information to any other app.
• You can withdraw your permission in two ways: with the "Bağlantıyı kes ve verilerimi sil" ("Disconnect and delete my data") button in your panel, or on your Google account's permissions page. The same page is reached through the Google security settings address: security.google.com/settings/security/permissions.
• Deleting the data we hold does not affect your data on YouTube. To delete something on YouTube you need to use YouTube or YouTube Studio.

6. Who sees your data

• You. You see your report, your application and your offer in your panel.
• The 51 Capital evaluation team. The team can see your channel data only after you tick the box "Kanal verilerimi 51 Capital'in değerlendirme ekibinin görmesini kabul ediyorum" ("I agree that the 51 Capital evaluation team may see my channel data") on the application page. Every view is logged.
• Our service providers. Your data sits on the servers of the providers listed in section 7. They process it only on our behalf and on our instructions.
• The technical staff who operate the system. They may access your data only for security reasons, such as investigating a bug or abuse, and only as far as necessary.
• Authorities. Where the law requires it, we give the requested information to competent public authorities and courts.

We do not share channel data with other units of 51 Digital (including 51 Brands and 51 Management), with brands, with investors or with advertisers. If such sharing ever becomes necessary, we will ask for your separate permission first.

7. Where your data is kept, and transfers abroad

We do not keep your data on our own servers but with the service providers below. Their servers are outside Türkiye, so your data is transferred abroad.

• Supabase. Database: your account details, channel data, application and encrypted access tokens. Server location: Frankfurt, Germany.
• Railway. The servers that run the site and the application. Server location: Amsterdam, the Netherlands.
• E-mail delivery. The e-mails we send you. Provider and server location: [DOLDURULACAK: e-mail delivery provider, country].
• Google Analytics and Meta Pixel. Only if you accept in the cookie preferences: visit and ad measurement. The data goes to servers of Google and Meta outside Türkiye.

We make this transfer in line with Article 9 of the KVKK, on the following basis: [DOLDURULACAK: the transfer mechanism chosen by the lawyer. Example: the standard contract published by the Turkish Personal Data Protection Board, signed with the providers and notified to the Authority].

8. How long we keep it

For as long as we keep your data, we confirm with Google at least every 30 days that your permission still exists. If it does not, we delete the data.

After a deletion, the following remains:

• Your application record: your e-mail address, your channel's ID, the result of your application and its dates. If we sent you an offer, the record of that offer. We keep these records for [DOLDURULACAK: period].
• The record of the e-mails we sent you: recipient address, type of e-mail and date. Subject and content are deleted.
• Records showing when the team accessed your data. These records contain no channel figures and are kept for [DOLDURULACAK: period].

Other periods:

• We keep messages sent through the contact form for [DOLDURULACAK: period]. Write to us if you want one deleted earlier.
• We keep an application form filled in without connecting a channel for [DOLDURULACAK: period].
• The session cookie is valid for 30 days. It is deleted when you sign out.

9. How we protect your data

• The site works only over an encrypted connection (HTTPS).
• We store the access tokens issued by Google encrypted with AES-256-GCM. They are never written to logs and never sent to your browser.
• We ask for read-only permission; the permission we hold cannot be used to change anything on your channel.
• Only team members we have authorised can enter the admin panel. Every view of channel data is logged.
• Each creator's data is kept separately; we do not produce aggregate figures across channels.

No system is entirely free of risk. If a security problem affects your data, we will inform you and the competent authority as the law requires.

10. Your choices and your rights

• Disconnect and delete your data. On the "Hesap" ("Account") page of your panel, press "Bağlantıyı kes ve verilerimi sil". It takes effect at once and you receive a confirmation e-mail. This does not affect your data on YouTube.
• Remove the permission at Google. You can remove 51 Capital's access at any time on your Google account's permissions page.
• Send us a deletion request. If you cannot enter the panel, write to 51capital@51digital.com or use the contact form. We carry out your request within 7 days at the latest.
• Your rights under the KVKK. For access, correction, deletion and your other rights, see the KVKK Aydınlatma Metni.
• Your cookie choice. You can change it at any time through the "Çerez ayarları" ("Cookie settings") link at the bottom of the page.

11. Cookies

We use a few cookies that the site needs in order to work. Google Analytics and Meta Pixel run only if you accept them. The Cookie Policy lists what each cookie does.

12. Age limit

51 Capital is for creators aged 18 or over. We do not knowingly collect data from anyone under 18. If we notice that we have, we delete it.

13. Changes to this policy

When we update this policy we change the date at the top of the page. If a change means using your data for a new purpose, we will tell you beforehand and ask you to accept the new text.

14. Contact us

For questions, requests and complaints about privacy:

• E-mail: 51capital@51digital.com
• Contact form: capital.51digital.com/iletisim
• Postal address: Noramin İş Merkezi, Maslak, Sarıyer, İstanbul, Türkiye