Privacy Notice (KVKK)
Privacy notice for visitors to internetten.com.tr, users of the contact and data request forms, and anyone contacting us by phone, WhatsApp or email.
Last updated:
This English translation is provided for information only. In the event of any conflict or inconsistency, the Turkish version prevails.
At Internetten Bilişim A.Ş., we take care to process your personal data in accordance with the Personal Data Protection Law No. 6698 ("KVKK" or the "Law") and related legislation.
This Privacy Notice has been prepared under Article 10 of the Law and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform. It explains for what purposes and how we process the personal data of:
- visitors to the website https://internetten.com.tr (the "Site"),
- users of the contact form or the data subject request form on the Site,
- anyone who contacts us by phone, WhatsApp or email.
Processing for job applications is described in the Candidate Privacy Notice. For cookies and similar technologies used on the Site, see our Cookie Policy.
Data Controller
| Item | Details |
|---|---|
| Company name | Internetten Bilişim A.Ş. (the "Company") |
| Tax office and number | Uluçınar Tax Office, 4781003630 |
| Address | Sultan Orhan Mah. İlyasbey Cad. 1117 Sk. No:6, 41400 Gebze / Kocaeli, Türkiye |
| [email protected] | |
| Phone | 0850 650 0 500 |
Group Companies and Scope of This Notice
This Privacy Notice covers only the processing carried out by the Company through the Site and the contact channels listed above.
Our group companies and our partnership are separate legal entities. Each is a separate data controller for the personal data it processes through its own products, services and websites. Each publishes its own privacy notices on its websites.
| Company | Products and websites |
|---|---|
| Internetten Teknoloji San. Tic. Ltd. Şti. | wi.com.tr, WiPoint, Syslog, WiMap, Metrik, carecode |
| Cetvel Yazılım A.Ş. | Cetvel, WiRadius, WiChat |
| Sign Bilişim ve Sanayi A.Ş. | Sign |
| Wislog Lojistik Ltd. Şti. (partnership) | Wislog |
The Site only links to these companies, their products and the websites of the brands distributed by the group. Processing on linked websites is outside the scope of this notice and is governed by those websites' own notices.
Personal Data Processed, Purposes and Legal Grounds
We process your personal data in line with the general principles in Article 4 of the Law. Processing is limited to the purposes and legal grounds set out below for each activity. Legal grounds refer to Article 5 of the Law.
Visiting the Site and server access logs
The Site is hosted on the Company's own server infrastructure. When you visit the Site, our servers automatically create access logs.
Data processed (transaction security): IP address, date and time of access, requested page address (URL), browser and device information (user agent), referring page (referrer).
| Purpose | Legal ground |
|---|---|
| Ensuring information security; detecting and preventing cyberattacks and misuse; keeping the Site secure and available | Legitimate interest (Art. 5(2)(f)) |
| Complying with obligations under Law No. 5651 on the Regulation of Internet Publications and Combating Crimes Committed Through Such Publications and related legislation; responding to requests from competent public authorities and judicial bodies | Legal obligation (Art. 5(2)(ç)) |
| Establishing, exercising and defending rights in potential disputes | Establishment, exercise or protection of a right (Art. 5(2)(e)) |
Form security (Cloudflare Turnstile)
We use Cloudflare Turnstile, provided by Cloudflare, Inc., to protect the forms on the Site against automated software (bots) and unwanted submissions. On form pages, Turnstile processes technical data to verify that the visitor is human.
Data processed (transaction security): IP address, browser and device information, technical signals from the browser, and the verification result.
| Purpose | Legal ground |
|---|---|
| Protecting forms against bots and spam; ensuring the security of the Site | Legitimate interest (Art. 5(2)(f)) |
The verification result is used only to decide whether the form may be submitted. It is not stored as a separate record on the Site.
Cloudflare processes this data on behalf of the Company. Cloudflare may also process it on its own behalf, under its own privacy policy, to improve Turnstile's bot detection; for that processing Cloudflare is a separate data controller. For details, see the Cloudflare Turnstile Privacy Addendum.
Contact form
Data processed:
- Identity: full name
- Contact: email address; phone number (optional)
- Request details: company name (optional), topic, message
- Consent records: your acknowledgement of this Privacy Notice; if given, your explicit consent and consent to commercial electronic messages; date and time of submission
- Transaction security: the server log and Turnstile data described above
Information submitted through the form is not stored in a database on the Site. It is sent by email to [email protected] through Google LLC's Gmail SMTP email service. When you submit the form, an automatic email confirming receipt may be sent the same way to the address you entered.
| Purpose | Legal ground |
|---|---|
| Receiving, assessing and answering your requests, questions and suggestions; providing information and quotations on the products or services you ask about | Directly related to the conclusion of a contract (Art. 5(2)(c)); legitimate interest (Art. 5(2)(f)) |
| Sending the automatic email confirming receipt | Legitimate interest (Art. 5(2)(f)) |
| Forwarding your request to the relevant group company if it concerns that company's products or services | Legitimate interest (Art. 5(2)(f)) |
| Recording communications and keeping evidence for potential disputes | Establishment, exercise or protection of a right (Art. 5(2)(e)) |
Mandatory fields are needed so that we can respond to you. Leaving optional fields blank does not prevent your request from being sent.
Consent to commercial electronic messages
The contact form includes an optional checkbox for receiving commercial electronic messages. This consent falls under Law No. 6563 on the Regulation of Electronic Commerce and the Regulation on Commercial Communications and Commercial Electronic Messages. Not giving consent does not affect how we handle your request.
Data processed: full name, email address, phone number, and the date, time and channel of consent.
| Purpose | Legal ground |
|---|---|
| Sending commercial electronic messages about our products, services, events and announcements | Explicit consent (Art. 5(1)) |
| Registering consent and opt-out records with the Message Management System (İYS) and keeping them for the period required by law | Legal obligation (Art. 5(2)(ç)) |
You can opt out of commercial electronic messages at any time, free of charge and without giving a reason, using any of these:
- the opt-out link in the message,
- İYS (iys.org.tr),
- an email to [email protected].
Contacting us by phone, WhatsApp or email
You can reach us through our phone and WhatsApp line 0850 650 0 500 or at [email protected]. We process the information you share through these channels.
Data processed:
- Identity: full name
- Contact: phone number, email address
- Request details: content of the call, message or email; any files you attach; date and time of contact
- If you use WhatsApp, also: your WhatsApp profile name and, depending on your privacy settings, your profile photo
| Purpose | Legal ground |
|---|---|
| Answering your requests and questions; providing information and quotations; forwarding to the relevant department or group company where needed | Directly related to the conclusion of a contract (Art. 5(2)(c)); legitimate interest (Art. 5(2)(f)) |
| Keeping records of communications and evidence for potential disputes | Establishment, exercise or protection of a right (Art. 5(2)(e)) |
Important information about WhatsApp: WhatsApp is a service operated by companies of the Meta Platforms, Inc. group. Data you share via WhatsApp is subject to Meta's terms of service and privacy policy, and may be transferred to servers abroad.
The Company has no control over processing that Meta carries out for its own purposes. Using WhatsApp is entirely your choice; you can use phone or email instead. Please do not share sensitive information, such as identity numbers or health information, via WhatsApp.
Data subject request form
You can use the Data Subject Request form on the Site to exercise your rights under Article 11 of the Law. We then process the following data.
Data processed:
- Identity: full name; Turkish ID number or passport number
- Contact: email address, phone number, postal address
- Request details: your relationship with the Company, your request, preferred response channel, your declaration
- Transaction security: server log and Turnstile data
| Purpose | Legal ground |
|---|---|
| Receiving your application; verifying the applicant's identity; assessing and concluding the application | Legal obligation (Art. 5(2)(ç); Articles 11 and 13 of the Law and the Communiqué on the Procedures and Principles of Applications to the Data Controller) |
| Demonstrating that applications are handled in line with the law; protecting rights before the Personal Data Protection Board and the courts | Establishment, exercise or protection of a right (Art. 5(2)(e)) |
Information from the request form is not stored in a database on the Site either. It is sent by email in the same way as the contact form.
Cookies and browser storage
The Site uses only strictly necessary cookies and browser storage items. No analytics, advertising or social media tracking cookies are used. For details, see our Cookie Policy.
Method of Collection
We collect your personal data:
- electronically, when you fill in forms on the Site,
- automatically, through our servers and Cloudflare Turnstile while you visit the Site,
- orally, in writing or electronically, when you contact us by phone, WhatsApp or email.
The data is processed on the legal grounds described above.
Transfers of Personal Data
Transfers within Türkiye
| Recipient group | Purpose | Legal ground |
|---|---|---|
| Our group companies (Internetten Teknoloji San. Tic. Ltd. Şti., Cetvel Yazılım A.Ş., Sign Bilişim ve Sanayi A.Ş., Wislog Lojistik Ltd. Şti.) | If your request concerns that company's products or services, limited to the data needed to handle the request | Art. 5(2)(c); Art. 5(2)(f) |
| İleti Yönetim Sistemi A.Ş. (İYS) | Managing consent and opt-out records for commercial electronic messages | Art. 5(2)(ç) |
| Competent public authorities, judicial and administrative bodies | Complying with legal obligations; responding to requests based on their statutory powers | Art. 5(2)(ç) |
| Lawyers and legal advisers | Establishing, exercising and defending rights in potential disputes | Art. 5(2)(e) |
Transfers abroad
Some service providers we use to run the Site are based outside Türkiye. Using their services involves transferring personal data abroad.
| Service provider | Service | Data transferred |
|---|---|---|
| Google LLC (USA) | Email delivery via Gmail SMTP | Information sent through the contact, careers and data subject request forms; automatic confirmation emails |
| Cloudflare, Inc. (USA) | Form security via Cloudflare Turnstile | IP address, browser and device signals |
| Meta Platforms, Inc. group (WhatsApp) | Messaging (only if you choose WhatsApp) | Phone number, profile information, message content and shared files |
Transfers abroad take place only where one of the processing conditions described in this notice applies. They comply with Article 9 of the Law, as amended by Law No. 7499 and in force since 1 June 2024, and with the Regulation on the Procedures and Principles for the Transfer of Personal Data Abroad. Accordingly:
- Adequacy decision: If the Personal Data Protection Board (the "Board") has issued an adequacy decision for the destination country, sector or international organisation, the transfer relies on that decision.
- Appropriate safeguards: Without an adequacy decision, the Company relies primarily on the appropriate safeguards listed in Article 9(4) of the Law, above all the standard contract published by the Board. Standard contracts are notified to the Personal Data Protection Authority within five business days of signature.
- Occasional transfers and explicit consent: If appropriate safeguards cannot be provided, the cases listed in Article 9(6) of the Law may be relied on. This route is available only for occasional transfers, meaning transfers that are irregular, happen once or a few times and are not continuous. Chief among these cases is your explicit consent, given after being informed of the possible risks. Where required, this consent is obtained through the consent checkbox on the relevant form.
Possible risks of transfers based on explicit consent:
- The destination country may not offer a level of data protection, or an independent supervisory authority, equivalent to that in Türkiye.
- Authorities in that country may be able to access your personal data.
- It may be harder for you to exercise your rights under the Law.
You may withdraw your explicit consent at any time. Withdrawal does not affect the lawfulness of processing carried out before it.
Retention and Destruction
We keep your personal data for as long as needed for the purpose of processing and as required by the relevant legislation. The periods below take into account the processing purposes, statutory retention obligations and limitation periods.
| Data / activity | Retention period | Rationale |
|---|---|---|
| Server access logs | 2 years from the date of the log entry | Information security; Law No. 5651 and related legislation |
| Requests and correspondence that do not lead to a commercial relationship (contact form, phone, WhatsApp, email) | 2 years from the last contact | Following up requests; evidence in potential disputes |
| Requests and correspondence that lead to a commercial relationship | 10 years from the end of the commercial relationship | Turkish Commercial Code No. 6102, Art. 82; Turkish Code of Obligations No. 6098, Art. 146 |
| Consent records for commercial electronic messages | 3 years from the end of the validity of the consent | Regulation on Commercial Communications and Commercial Electronic Messages |
| Data subject request records | 10 years from the conclusion of the request | Demonstrating compliance with the Law; general limitation periods under the Turkish Code of Obligations |
| Turnstile verification data | Not stored by the Company | Processed by Cloudflare, Inc. under its own policies |
When the retention period ends or the grounds for processing no longer exist, personal data is deleted, destroyed or anonymised. This happens during periodic reviews, or on your request, in line with the Regulation on the Deletion, Destruction or Anonymisation of Personal Data. If a legal dispute or official investigation is ongoing, the relevant data may be kept until it is concluded.
Your Rights under Article 11 of the Law
By applying to the Company, you have the right to:
- (a) learn whether your personal data is processed,
- (b) request information about the processing, if your personal data has been processed,
- (c) learn the purpose of processing and whether your data is used in line with that purpose,
- (ç) know the third parties in Türkiye or abroad to whom your personal data is transferred,
- (d) request correction of your personal data if it is incomplete or inaccurate,
- (e) request deletion or destruction of your personal data under the conditions in Article 7 of the Law,
- (f) request that actions taken under (d) and (e) be notified to third parties to whom your personal data has been transferred,
- (g) object to a result against you that arises from analysis of your data exclusively by automated systems,
- (ğ) claim compensation if you suffer damage because your personal data was processed unlawfully.
How to Apply
You may submit requests in Turkish, in line with the Communiqué on the Procedures and Principles of Applications to the Data Controller, using one of these methods:
- In writing: Hand-deliver your signed (wet-ink) application to Sultan Orhan Mah. İlyasbey Cad. 1117 Sk. No:6, 41400 Gebze / Kocaeli, or send it by registered mail with return receipt or through a notary.
- With a secure electronic signature or mobile signature: Send your application signed with one of these signatures to [email protected].
- From your registered email address: Write to [email protected] from an email address you have previously given to the Company and that is registered in the Company's systems.
- Online: Use the Data Subject Request form on the Site.
Your application must include:
- your full name and, for written applications, your signature,
- your Turkish ID number if you are a Turkish citizen; if you are a foreign national, your nationality and passport number or, if any, your identity number,
- your residential or business address for official notifications,
- your email address, phone and fax number for notifications, if any,
- the subject of your request.
Please attach any information and documents relevant to your request.
We will conclude your request as soon as possible and no later than 30 days, depending on its nature, free of charge. If the process involves an additional cost, a fee may be charged according to the tariff set by the Board. We may accept your request or refuse it with reasons. We will send our response in writing or electronically. We may ask for additional information or documents to verify your identity.
If your request is refused, you find our response insufficient, or we do not respond in time, you may file a complaint with the Personal Data Protection Board (Art. 14 of the Law). The deadline is 30 days from the date you learn of our response, and in any event 60 days from the date of your application.
Changes
We may update this Privacy Notice to reflect changes in legislation or in our processing activities. The current version is always published on the Site, with the date of the last update shown on the page.