KVKK Information Notice (Personal Data Processing)

English courtesy translation of the Article 10 notice required under Turkish Law No. 6698 (KVKK). The Turkish version is the operative legal document.

1. Data controller

Under the Turkish Personal Data Protection Law No. 6698 ("KVKK"), in connection with the marketing website at www.sitetransformer.com (the "Website"), your personal data is processed by the following company as data controller:

LGY YAZILIM DANIŞMANLIK VE BİLGİ TEKNOLOJİLERİ SANAYİ TİCARET LİMİTED ŞİRKETİ (the "Company")

• Registered office: Maslak Mah. Bilim Sok. Sun Plaza No:5 K:13, Maslak, Sarıyer, İstanbul, Türkiye
• Trade registry: Istanbul Chamber of Commerce, Registry No. 717459-0
• MERSIS No.: 0608049877800018
• Tax office / number: Maslak Tax Office, 6080498778
• Contact: [email protected]

This notice covers the marketing Website only. The Site Transformer service at console.sitetransformer.com is governed by its own notice and agreements.

2. Personal data processed

The Website has no contact form or account registration (registration takes place on console.sitetransformer.com), so the data processed via the Website is limited:

• Transaction security / technical data: IP address, approximate location derived from IP, device and browser information, operating system, referring URLs, navigation/log records, timestamps, cookie identifiers.
• Identity and contact data: the name, email address and message content you provide when you email us.
• Marketing / consent data: your email address and communication-consent preferences where you opt in to receive commercial electronic messages.
• Live chat data (if enabled): information you provide through a chat tool we may add in the future.

We do not intend to collect special categories of personal data through the Website.

3. Purposes of processing

• providing, operating, improving and measuring the performance of the Website;
• ensuring information and service security and preventing misuse and fraud;
• responding to and managing your requests, questions and applications;
• sending commercial electronic messages and conducting marketing, based on your explicit consent;
• fulfilling legal obligations and pursuing/defending legal claims.

4. Method of collection and legal grounds

Your personal data is collected automatically via cookies and similar technologies during your visit, through your own declaration when you email us, and via our hosting/CDN/analytics providers.

Processing relies on the following grounds under KVKK arts. 5 and 6:

• Explicit consent (art. 5/1): analytics cookies and sending commercial electronic messages;
• Conclusion/performance of a contract (art. 5/2-c): responding to your requests and pre-contractual discussions;
• Compliance with a legal obligation (art. 5/2-ç);
• Establishment, exercise or protection of a right (art. 5/2-e): pursuing legal claims;
• Legitimate interests of the controller (art. 5/2-f): security, operation and improvement of the Website, provided your fundamental rights and freedoms are not harmed.

5. Transfers of personal data

Your personal data may be transferred, limited to the purposes above, to our service providers (hosting, CDN, DNS, analytics and — if enabled — live chat providers), to professional advisers, and to authorized public bodies and courts where required by law.

Transfers abroad: some of the providers hosting and serving the Website (e.g. Amazon Web Services, Cloudflare, Google) process data on servers outside Türkiye, so your personal data may be transferred abroad. Such transfers are carried out under KVKK art. 9 (as amended): first, on the basis of an adequacy decision by the Board where one exists; failing that, on one of the appropriate safeguards in the Law (in particular a standard contract notified to the Board within the statutory period, or binding corporate rules); or on one of the exceptional grounds in art. 9 (which may include your explicit consent for a specific transfer).

6. Your rights under KVKK art. 11

By applying to the data controller, you have the right to: learn whether your personal data is processed; request information if it is; learn the purpose of processing and whether it is used accordingly; know the third parties to whom it is transferred at home or abroad; request correction if it is incomplete or inaccurate; request erasure or destruction under art. 7; request that corrections/erasures/destructions be notified to third parties to whom the data was transferred; object to a result against you arising solely from automated analysis; and claim compensation for damage caused by unlawful processing.

7. How to apply

To exercise these rights, submit your request, in line with the Communiqué on Application Procedures to the Data Controller, by one of the following methods:

• in writing with a wet signature to the Company's registered address above;
• using a secure electronic signature or mobile signature;
• from the email address you have previously notified to us and which is registered in our system, to [email protected].

Your application should include your name and surname (and signature if in writing), Turkish ID number (passport/nationality details for foreigners), an address/email for notification, and the subject of your request. Your request will be concluded free of charge as soon as possible and within thirty days at the latest; if the process entails an additional cost, a fee from the Board's tariff may apply.

If your application is refused, you find the response insufficient, or no timely response is given, you may file a complaint with the Personal Data Protection Board within thirty days of learning the response and in any case within sixty days of the application date (www.kvkk.gov.tr).