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entrocode
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1. Scope

This policy sets out the general framework for how ENTROCODE TEKNOLOJİ ANONİM ŞİRKETİ (“Entrocode”, “we”) processes personal data in connection with the entrocode.com website and the mobile apps and other digital services we publish now or in the future.

Processing specific to a particular app is described separately in the supplements listed under App-specific supplements below. Where a supplement differs from this policy, the supplement prevails for that app.

This policy has been prepared with regard to the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and its secondary legislation and, where applicable, the EU General Data Protection Regulation (EU) 2016/679 (“GDPR”). It serves as the privacy notice required by Article 10 of the KVKK.

2. Data controller

The data controller for your personal data is ENTROCODE TEKNOLOJİ ANONİM ŞİRKETİ, whose identity and contact details are shown on this page. For any question or request about personal data, contact us at info@entrocode.com.

3. Personal data we process and how we collect it

Website. entrocode.com does not use cookies and contains no analytics, advertising or tracking tools. All content, including fonts, is served from our own server; no third-party resources are loaded. When you visit the site, our server infrastructure may process technical connection data such as IP address, date and time of the request, the requested address and browser information, so that the site runs securely and reliably.

Contact. When you reach us by email or phone, we process the information you share with us, such as your name, contact details and the content of your message.

Clients and business relationships. We process identity, contact and transaction details of representatives of the clients, suppliers and partners we have contractual relationships with.

Mobile apps and digital services. The data processed in our apps depends on what each app does. The categories of data, purposes, device permissions and third-party services used by each app are described in that app’s supplement and in its privacy disclosure on the app store.

Personal data is collected electronically through our website, email, phone and apps, by automated or partly automated means, or when you provide it to us directly.

  • Responding to your requests and communicating with you — KVKK Art. 5(2)(c) formation or performance of a contract and Art. 5(2)(f) legitimate interest; GDPR Art. 6(1)(b) and (f).
  • Performing our contracts, providing services and support — KVKK Art. 5(2)(c); GDPR Art. 6(1)(b).
  • Complying with legal obligations (e.g. tax and commercial law) — KVKK Art. 5(2)(ç); GDPR Art. 6(1)(c).
  • Keeping our site and services secure and preventing abuse — KVKK Art. 5(2)(f); GDPR Art. 6(1)(f).
  • Processing that requires your explicit consent — only with your consent; KVKK Art. 5(1); GDPR Art. 6(1)(a). You can withdraw consent at any time.

We do not sell your personal data, and we do not use it for purposes other than those set out in this policy.

5. Transfers

Your personal data may be shared, only for the purposes above and to the extent necessary, with suppliers who provide us with hosting, email and cloud infrastructure, with public authorities legally entitled to request it, and with our advisers in legal disputes.

Our website is hosted in data centres in Germany, and our email is provided through a cloud-based service provider. Any resulting transfers outside Türkiye are carried out in line with the safeguards set out in Article 9 of the KVKK and Chapter V of the GDPR.

6. Retention

We keep personal data for as long as the purpose of processing requires and for the periods required by applicable law. When that period ends, we delete, destroy or anonymise the data. Server-side technical connection logs are kept only briefly, for security and operational purposes.

7. Security

We take appropriate technical and organisational measures to prevent unlawful processing of, unauthorised access to and loss of personal data. These include encrypted connections (HTTPS), role-based access, the principle of least privilege and regular backups.

8. Your rights

Under Article 11 of the KVKK you have the right to learn whether your personal data is processed and, if so, to request information about it; to learn the purpose of processing and whether data is used accordingly; to know the third parties in Türkiye or abroad to whom it is transferred; to request correction of incomplete or inaccurate data and, where legal conditions are met, its deletion or destruction; to request that these actions be notified to third parties to whom the data was transferred; to object to an outcome against you arising solely from automated analysis; and to claim compensation for damage caused by unlawful processing.

If the GDPR applies to you, you also have the rights of access, rectification, erasure, restriction of processing, data portability, objection and withdrawal of consent.

9. Making a request

You can send your request by email to info@entrocode.com or in writing to our registered address. We will resolve your request free of charge as soon as possible and within thirty days at the latest, depending on its nature (KVKK Art. 13).

If you are not satisfied with our response, you may apply to the Turkish Personal Data Protection Board (KVKK) or, if you are in the European Union, to the data protection authority of your country.

10. Children

Unless an app’s supplement says otherwise, our website and apps are not directed at children, and we do not knowingly collect personal data from children.

11. App-specific supplements

For each mobile app and digital service we publish, a supplement describing the categories of data processed, device permissions, third-party services used and retention periods will be added to this section. Supplements form an integral part of this policy.

There are currently no app supplements in effect.

12. Changes

We may update this policy from time to time. The current version is always published on this page, with the date of the latest update shown at the top.