Data Processing Notice

TechLiberty Software Solutions ("TechLiberty", "Company", "data controller") has prepared this Data Processing Notice pursuant to Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform, in order to inform you about the processing of your personal data.

1. Identity of the Data Controller

The data controller's details are as follows:

Company Name: TechLiberty Software Solutions
Address: Küplüce Mahallesi 4. Zeytinlik Sokak No:13/A Özdemir Apt. 34676 Üsküdar, Istanbul, Turkey
Email: info@techliberty.co
Website: www.techliberty.co
VERBİS Registration: TechLiberty monitors its obligation to register with the Data Controllers' Registry (VERBİS) under the KVKK.

2. Personal Data Collected

The following personal data is processed through our website:

Contact Form: Full name, email address, phone number, message content
Newsletter Subscription: Email address
Technical Data: IP address, browser type and version, operating system, date and time of access, pages visited (via Google Analytics, only with your consent)

Our website uses Google reCAPTCHA v3 to detect bots and prevent abuse. This service causes Google LLC to process technical data (IP address, browser information, mouse movements). Google's privacy policy applies: https://policies.google.com/privacy

3. Purposes of Processing

Your personal data is processed for the following purposes:

• Receiving, evaluating, and responding to your contact requests
• Providing information and service proposals regarding the services you request
• Sending newsletters (only with your explicit consent)
• Ensuring the security and functionality of the website
• Preventing spam and abuse (reCAPTCHA v3)
• Analyzing website traffic and user experience (Google Analytics, only with your consent)
• Fulfilling legal obligations arising from the KVKK and applicable legislation

4. Legal Basis for Processing

Your personal data is processed on the following legal bases under Article 5 of the KVKK:

• Explicit consent (Art. 5/1): Processing based on your consent for newsletter subscriptions and Google Analytics cookies
• Establishment or performance of a contract (Art. 5/2-c): Requests submitted through the contact form; preparation of service proposals and conducting business discussions
• Legitimate interest of the data controller (Art. 5/2-f): Ensuring website security, spam and intrusion detection (reCAPTCHA), maintaining system logs
• Explicitly provided by law (Art. 5/2-a): Fulfilling obligations arising from tax, commercial, and communications legislation

5. Transfer of Personal Data

Your personal data may be transferred to the following recipient groups in accordance with Articles 8 and 9 of the KVKK:

• Bulut Altyapı Sağlayıcısı (AB/Almanya): Web sitemizin ve veritabanının barındırıldığı sunucu altyapısı, Avrupa Birliği (Almanya) merkezli, KVKK ve GDPR uyumlu bir bulut altyapı sağlayıcısı tarafından sunulmaktadır. Kişisel verileriniz, Avrupa Birliği'nde konumlanan veri merkezlerinde güvenli biçimde depolanmaktadır. GDPR kapsamındaki veri işleme sözleşmesi (DPA) imzalanmıştır.
• Google LLC (USA): The reCAPTCHA v3 service (mandatory under legitimate interest) and Google Analytics (only with your explicit consent). International transfers are conducted pursuant to your explicit consent or decisions of the Personal Data Protection Board under Article 9 of the KVKK.
• SMTP Service Provider: Only the recipient address and message content are transferred for the purpose of email delivery.

Your personal data is not shared with third parties beyond the purposes and recipients specified above.

6. Retention Period

Your personal data is retained for the period required by the processing purpose and in accordance with legal retention obligations:

• Contact form data: Up to 3 years from conclusion of the request (legal retention obligation for commercial correspondence records)
• Newsletter subscription: Until a request for cancellation; deleted within a reasonable period after unsubscription
• Technical/log data: Up to 2 years (for security and system management purposes)
• Google Analytics data: Data retention is set to 26 months in the Google Analytics account settings

Upon expiry of the retention period or cessation of the processing purpose, your personal data will be deleted, destroyed, or anonymized in accordance with Article 7 of the KVKK and the Regulation on Deletion, Destruction, or Anonymization of Personal Data.

7. Rights of the Data Subject (KVKK Article 11)

Under Article 11 of the KVKK, you have the following rights regarding your personal data:

a) The right to learn whether your personal data is being processed
b) The right to request information if your personal data has been processed
c) The right to learn the purpose of processing your personal data and whether it is being used in accordance with that purpose
d) The right to know the third parties to whom your personal data has been transferred, domestically or internationally
e) The right to request correction if your personal data is incomplete or inaccurate
f) The right to request deletion or destruction under the conditions set forth in Article 7 of the KVKK
g) The right to request notification of corrections or deletions to the third parties to whom your data has been transferred
h) The right to object to a result that is unfavorable to you arising from analysis exclusively through automated systems
i) The right to claim compensation for damages in the event of loss due to unlawful processing of your personal data

To exercise these rights, you may submit a written request to info@techliberty.co together with documents verifying your identity. Your requests will be concluded in the shortest time possible and no later than 30 days pursuant to Article 13 of the KVKK. There is no fee charged for requests, subject to the fee schedule determined by the Personal Data Protection Board.

To exercise your rights under the KVKK or for questions about this Data Processing Notice, please contact us at info@techliberty.co.