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Privacy Notice

This notice explains, under article 10 of Turkish Personal Data Protection Law No. 6698 (“KVKK”) and the Communiqué on the Procedures and Principles of the Obligation to Inform, which personal data we process when you visit our website and fill in the contact form.

1. Data controller

Your personal data is processed by [TeginSoft legal name] (“TeginSoft”) as the data controller.

  • Address: [registered address]
  • MERSIS number: [MERSIS no]
  • VERBIS registration number: [VERBIS registration no or exemption]
  • Registered e-mail (KEP): [KEP address]
  • E-mail for requests: [kvkk@domain]

2. Personal data we process

Contact form

  • Identity: your name.
  • Contact: your e-mail address; optionally your company name and phone number.
  • Customer transaction: the service you are interested in, your message, the language you used, the status of your enquiry and our team’s internal notes on it.
  • Legal transaction: the date and time you confirmed reading this notice.
  • Marketing (source data): the channel and campaign that brought you to the site (source, medium, campaign name, referring domain, landing page and time). When measurement runs, the source of the session in which you sent the form is recorded; the source of your first visit is added from your browser only if you allowed analytics cookies.
  • Transaction security: the result of the Cloudflare Turnstile check that blocks automated submissions.

Site visits and measurement

  • Pages visited, language, visit times, referring domain and path, campaign parameters (UTM values and ad click ids), device type, browser and operating system name, country code, and interaction events such as a form submission.
  • A random session id specific to your browser tab; if you allowed analytics cookies, also an anonymous visitor id and the source of your first visit.
  • Your IP address and browser string (user agent) are processed in memory only; the raw IP address and the full user agent are never written to our database. From them we derive a one-way hash with a secret key that changes every day and is destroyed at the end of the day, so the hash cannot be linked across days. The country code is looked up in a local database on our server; your IP address is not sent to third parties for this.
  • If your browser sends a Do Not Track or Global Privacy Control signal, no measurement takes place.

The cookies and browser storage we use are described in the Cookie Policy.

3. Purposes

  • To answer your enquiry, hold pre-contract discussions, prepare offers and follow up your request.
  • To notify our team of your enquiry by e-mail and send you an automatic confirmation.
  • To measure which advertising and communication channels bring visitors and enquiries, and to assess the cost and effectiveness of campaigns.
  • To keep the site secure, prevent abuse and automated (bot) submissions, and detect errors.
  • To keep changes in our content management system accountable and to meet legal obligations.

4. Collection method and legal bases

We collect your personal data electronically, partly by automated means, through the contact form, a first-party measurement script on our site and the requests your browser sends to our servers. The legal bases below are [pending legal review]:

  • Contact form data: KVKK art. 5(2)(c) (necessary for entering into or performing a contract) and art. 5(2)(f) (legitimate interest of the controller).
  • Consent-based analytics (an anonymous visitor id and the source of your first visit kept in your browser for 90 days): KVKK art. 5(1) (explicit consent). You can withdraw consent at any time with the “Cookie preferences” link at the bottom of every page.
  • Cookieless measurement without consent (a tab-specific session id and a hash that changes daily): KVKK art. 5(2)(f) (legitimate interest). Running this mode without consent is also pending legal review; if it is not confirmed, measurement will only take place with consent.
  • Security, error logs and audit records: KVKK art. 5(2)(ç) (legal obligation) and art. 5(2)(f) (legitimate interest).

The checkbox on the contact form confirms that you have read this notice; it is not a declaration of explicit consent.

5. Transfers

We do not sell your personal data or share it with advertising networks, and the site uses no third-party analytics or advertising trackers. Data is transferred only to the recipients below and only for the stated purpose:

  • Hosting provider [provider name, country]: the servers that run the site and the database.
  • E-mail (SMTP) provider [provider name, country]: delivering enquiry notifications and confirmations.
  • Cloudflare, Inc. (USA): bot check on the contact form (Turnstile). During the check your browser communicates with Cloudflare directly; our server sends Cloudflare only the verification token, not your IP address.
  • Competent public authorities and courts, on request and within legal obligations.

Transfers to recipients abroad are made under KVKK article 9 [standard contractual clauses, notification and other appropriate safeguards — pending legal review].

6. Retention

We keep personal data for as long as the purpose requires, then delete, destroy or anonymise it. Raw measurement data is kept for 13 months and audit records for 24 months; the period for enquiries is [to be determined — pending legal review]. All periods are listed in the Privacy Policy.

7. Your rights under KVKK article 11

By applying to the data controller you may:

  • learn whether your personal data is processed,
  • request information about the processing,
  • learn the purpose of the processing and whether the data is used accordingly,
  • know the third parties in Turkey or abroad to whom the data is transferred,
  • request the correction of incomplete or inaccurate data,
  • request the deletion or destruction of the data under the conditions in KVKK article 7,
  • request that the third parties to whom the data was transferred are notified of a correction, deletion or destruction,
  • object to a result against you that arises from analysis exclusively by automated systems,
  • claim compensation for damage caused by unlawful processing.

8. How to apply

Send your request in line with the Communiqué on the Procedures and Principles of Application to the Data Controller, stating your identity and your request clearly: in writing to the address above, to our registered e-mail (KEP) address, or to [kvkk@domain] from an e-mail address registered in our records. We will respond free of charge within 30 days at the latest; if the request involves an additional cost, the fee set by the Personal Data Protection Board may be charged. If your request is rejected, the answer is insufficient or we do not answer in time, you may complain to the Personal Data Protection Board.

Last updated: [date]