KVKK Privacy Notice

1. Data controller

Pursuant to Turkish Personal Data Protection Law No. 6698 (the “Law”), your personal data may be processed by eMind (eMind Teknoloji A.Ş.) (“eMind”) in its capacity as data controller, within the scope described below. iPrice is a product of emind.

Trade name	eMind Teknoloji A.Ş.
Address	Esentepe Mah., Büyükdere Cad., No:171 Metrocity İş Merkezi, A Blok, Kat: 16, 34394 Şişli, İstanbul
KVKK request e-mail	[email protected]

2. Categories of personal data processed

The following categories of personal data may be processed through our website, our demo and contact forms, and communications relating to the iPrice service.

• Identity: first name and surname.
• Contact: work e-mail address and, optionally, telephone number; e-mail correspondence you send us and its content.
• Demo request: website address, optionally the list of products you would like tracked, your product-news choice (yes/no), and the page and language from which the form was submitted.
• Transaction security: IP address, browser and device information (user agent), country information and time of the request; this information is kept in the security and audit log of the request. The IP address is also used briefly to limit spam and abuse.
• Marketing: your choice regarding product news, and the record and date of that choice. This category is processed only where you have given explicit consent.

The iPrice service processes product information (price, stock, campaigns) from publicly available product pages; this information is not personal data. For details, please see the Privacy Policy.

3. Purposes of processing personal data

• To receive and evaluate your demo and contact requests and to respond to you,
• To carry out quotation, contract and onboarding processes relating to the provision of the service,
• To manage customer relations and handle support requests,
• To carry out information security processes and to prevent unauthorised access and misuse,
• To fulfil our legal obligations and to protect our rights in potential disputes,
• Where you have given explicit consent, to send promotional communications about products, announcements and events.

4. Legal grounds for processing

Your personal data is processed on the basis of the following legal grounds set out in the second paragraph of Article 5 of the Law.

• Art. 5/2-c: Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the conclusion or performance of that contract,
• Art. 5/2-ç: Processing is mandatory for the data controller to comply with a legal obligation,
• Art. 5/2-f: Processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject (e.g. information security, improvement of the service),
• Explicit consent: Promotional and marketing communications are based solely on your explicit consent; you may withdraw your consent at any time.

You may withdraw your explicit consent to product news at any time by writing to [email protected]. Your consent choice and its date are recorded.

5. Transfer of personal data

Your personal data may be transferred, limited to the purposes above and in accordance with Articles 8 and 9 of the Law, to the following groups of recipients.

• Service providers: our business partners that provide hosting (servers) and e-mail delivery infrastructure; demo requests are notified by e-mail to our authorised staff through our e-mail service provider,
• Content delivery and security service: our site is delivered through Cloudflare; Cloudflare may process the IP address and request data relating to requests to the site,
• Authorised public bodies and institutions: public bodies and institutions, where they so request under legislation,
• Advisors: our legal, financial and technical advisors (under a duty of confidentiality).

Because our site is delivered through Cloudflare, the IP address and request data may be processed by Cloudflare; this may involve a transfer abroad.

Where our service providers’ infrastructure is located abroad, the transfer is carried out under Article 9 of the Law by one of the methods provided for in the legislation, such as an adequacy decision, appropriate safeguards (standard contractual clauses, etc.) or explicit consent. Your data is not sold to third parties.

6. Method of collection

Your personal data is obtained by automated or partly automated means through the demo and contact forms on our website, e-mail correspondence, and telephone and online meetings. Server records (IP, logs) are generated automatically while you use the site and the service.

7. Retention periods

Your personal data is retained until the purpose of processing ends or until you request its deletion; it may remain in database backups for up to 30 more days. Records for which legislation prescribes a period are retained for that period.

Data	Retention period
Demo and contact form content, access records (IP, logs)	Until the purpose of processing ends or you request deletion
Customer and contract records	The statutory limitation period after the contract ends (generally 10 years)
Marketing communication preferences	Until consent is withdrawn

8. Your rights as a data subject (Art. 11)

Under Article 11 of the Law, you may exercise the following rights by applying to the data controller.

• To learn whether your personal data is being processed,
• To request information if it has been processed,
• To learn the purpose of processing and whether the data is used in accordance with that purpose,
• To know the third parties to whom the data is transferred, in Türkiye or abroad,
• To request correction if the data is incomplete or inaccurately processed,
• To request deletion or destruction under Article 7 of the Law,
• To request that correction, deletion and destruction be notified to the third parties to whom the data has been transferred,
• To object to a result against you arising from the analysis of the processed data exclusively by automated systems,
• To claim compensation for damage if you suffer harm due to unlawful processing.

9. How to apply

You may submit your requests concerning your rights, together with information that identifies you, through the channels below.

• E-mail: [email protected]
• Written application: to Esentepe Mah., Büyükdere Cad., No:171 Metrocity İş Merkezi, A Blok, Kat: 16, 34394 Şişli, İstanbul, marked “KVKK Information Request”, with a wet signature or by the other methods prescribed by legislation.

Depending on the nature of the request, your application will be concluded free of charge within 30 days at the latest. If the process requires a separate cost, a fee may be charged according to the tariff determined by the Personal Data Protection Board. If you find the response to your application inadequate, your right to lodge a complaint with the Personal Data Protection Board is reserved.

Related texts: Privacy Policy · Cookie Policy