PRIVACY POLICY
(Specific to the website www.galpan.com)
1. INTRODUCTION
This Privacy Policy has been prepared by Ularte Sınai Yapı ve Ticaret A.Ş. (“Company”), acting as the data controller, for the purpose of informing natural persons who visit the website www.galpan.com (“Site”) regarding the collection, use, storage, and transfer of their personal data in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK”), secondary legislation, and decisions of the Personal Data Protection Board.
This policy has also been created in consideration of the provisions of the Law No. 5651 and the Law No. 6563 on the Regulation of Electronic Commerce, and other relevant legislation.
2. INFORMATION ON THE DATA CONTROLLER
Title: Ularte Sınai Yapı ve Ticaret A.Ş.
Address: Büyükdere Cad., No:160, 1. Levent, 34330 İstanbul / Türkiye
Phone: +90 212 281 99 05
Fax: +90 212 281 99 06
E-mail: kvkk@ularte.com
Web: www.galpan.com
3. PERSONAL DATA COLLECTED AND METHODS OF COLLECTION
Personal data collected through the Site by automatic or non-automatic means are as follows:
• Identity Data: Name-surname
• Contact Data: E-mail address, phone number
• Message Content: Messages sent through the contact form
• Internet Data: IP address, cookie data, browser type, session duration
These data are collected through contact forms, e-mails, cookies, and website access logs.
4. PURPOSES OF DATA PROCESSING
Personal data are processed in accordance with the principles set out in Article 4 of the KVKK and for the following purposes:
• Responding to visitor requests and concluding applications
• Improving user experience on the website
• Archiving electronic records
• Fulfillment of legal obligations
• Execution of information security processes
• Ensuring compliance with legislation and obtaining evidence in potential disputes
5. LEGAL BASIS
Personal data are processed based on the following legal grounds under Article 5 of the KVKK:
• Article 5/2-a: It is expressly provided for by law
• Article 5/2-c: It is necessary for the establishment or performance of a contract
• Article 5/2-ç: It is necessary for compliance with a legal obligation
• Article 5/2-e: It is necessary for the establishment, exercise or protection of a right
• Article 5/2-f: It is necessary for the legitimate interests of the data controller
In cases where explicit consent is required, data processing will not commence without obtaining the data subject’s explicit consent.
6. DATA TRANSFERS
Personal data may be transferred, limited to the purposes of processing and in accordance with Articles 8 and 9 of the KVKK, to:
• Authorized public institutions and organizations (BTK, courts, law enforcement, etc.)
• Domestic service providers offering technical, software, and cloud services
• Third parties providing legal consultancy and audit services
In the event of a transfer of personal data abroad, such transfer shall not be made without the explicit consent of the data subject, unless a decision of adequacy is granted by the Board.
7. RETENTION PERIODS
The Company retains personal data for the period required by the purposes of processing. Personal data whose retention period has expired shall be deleted, destroyed, or anonymized in accordance with Article 7 of the KVKK and relevant secondary regulations.
• Contact form data: Retained for the statute of limitations related to the application (generally 3 years)
• Cookie data: Retained between 6 months and 2 years depending on the purpose of use and browser settings
8. COOKIE POLICY
Cookies are used on the website to improve user experience, ensure security, and generate analytical data. You may control your cookie preferences via your browser settings. For detailed information, please refer to the separate Cookie Policy document.
9. DATA SECURITY MEASURES
Our Company takes the necessary administrative and technical measures to prevent unlawful access to personal data and to ensure their secure storage pursuant to Article 12 of the KVKK. These include:
• Access authorization restrictions,
• Firewalls and network security systems,
• Database logging systems,
• Awareness training for employees who process personal data
10. RIGHTS OF THE DATA SUBJECT
Pursuant to Article 11 of the KVKK, the data subject has the right to:
• Learn whether their personal data are processed
• Request information if their data have been processed
• Learn the purpose of processing and whether they are used in accordance with such purpose
• Learn the third parties to whom personal data are transferred domestically or abroad
• Request rectification if personal data are incomplete or incorrectly processed
• Request deletion or destruction under Article 7 of the KVKK
• Object to any adverse result arising from the analysis of processed data exclusively through automated systems
• Request compensation in case of damage due to unlawful processing
11. METHOD OF APPLICATION
To exercise your rights stated above, you may apply to the Company via:
• Written application to the address: “Büyükdere Cad., No:160, 1. Levent, 34330 İstanbul / Türkiye”
• Electronic mail to the address: kvkk@ularte.com
Applications shall be responded to within 30 (thirty) days in accordance with Article 13 of the KVKK.
12. EFFECTIVENESS AND UPDATES
The Company reserves the right to unilaterally revise this document due to legal requirements or changes in internal policy. The updated version shall enter into force on the date it is published on www.galpan.com.
This document has been prepared to ensure transparency in personal data processing activities conducted by the Company in digital environments and to fulfill the obligation of disclosure pursuant to Law No. 6698.