Privacy Notice on the Protection of Personal Data

1. Identity of the Data Controller

Data Controller: İrşad Tograk (Tughlan)

Contact Email: i.toghraq@tughlantech.com

Location: İstanbul, Türkiye

2. Personal Data Collected

When you complete the contact/consultation form on the Site, the following personal data is processed:

• Full name
• Email address
• Phone number
• Company/organization name (if this field is present on the form)
• The content of the message/request you submit through the form

3. Purposes of Processing

Your personal data is processed solely for the following purposes:

• To contact you,
• To understand the type of service you are requesting and your needs, so we can offer you the most suitable solution/proposal,
• To have general information about you in order to provide a more qualified and personalized consultancy/service experience,
• To evaluate your request and respond to you.

Your data is not used for any other purpose, such as marketing, profiling, or any different commercial purpose.

4. Transfer of Personal Data

The personal data obtained through the form is not shared with, sold to, or rented to any third party. Your data is evaluated solely by the Data Controller for the purposes described above.

The only exception is where a competent public authority (courts, prosecutors, or other relevant public bodies) lawfully requests personal data under applicable legislation, in which case information may be shared strictly to the extent necessary to comply with that legal obligation.

5. Method and Legal Basis of Collection

Your personal data is collected electronically, directly from you, through the contact form on the Site.

Your data is processed based on the following legal grounds under Article 5 of the KVKK:

• Your explicit consent (given when you complete and submit the form after reading this notice and checking the consent box),
• Where your request forms part of pre-contractual discussions toward a service relationship, the legal ground of being directly related to the establishment of a contract.

6. Retention Period

Your personal data is retained for as long as necessary to evaluate and conclude your request; if a service relationship is established, for the duration of that relationship, and thereafter for any statutory limitation periods required under applicable law. Upon expiry of these periods, your data is deleted, destroyed, or anonymized.

7. Your Rights as a Data Subject (KVKK Art. 11)

Under Article 11 of the KVKK, you may apply to the Data Controller to:

• Learn whether your personal data is being processed,
• Request information about it if it has been processed,
• Learn the purpose of processing and whether it is used in accordance with that purpose,
• Know the third parties, domestic or foreign, to whom your data has been transferred,
• Request correction of your data if it is incomplete or inaccurate,
• Request the deletion or destruction of your data under the conditions set out in the KVKK,
• Request that any correction or deletion be notified to third parties to whom your data has been transferred,
• Object to a result that is to your detriment arising solely from automated analysis of your data,
• Claim compensation for damages arising from unlawful processing of your data.

8. How to Exercise Your Rights

You may submit your requests in writing to i.toghraq@tughlantech.com. Your request will be evaluated and answered within the period prescribed by the KVKK (at the latest, within 30 days).