Privacy Policy
Updated:
This notice explains how personal data of visitors to omerneziroglu.com (the “Site”) and of email newsletter subscribers is processed under Turkish Personal Data Protection Law No. 6698 (“KVKK”) and, where applicable, the EU General Data Protection Regulation (“GDPR”). The Turkish version prevails in case of any discrepancy.
1. Data controller
The data controller is ÖLN Yönetim Danışmanlığı Yazılım Limited Şirketi (the “Company”). The Company’s address, registration (MERSİS) number and contact details are at the end of this page.
2. How data is collected
Personal data is collected electronically: automatically when you visit the Site, and partly automatically when you fill in the newsletter form.
3. Visiting the Site
The Site is read-only. There are no accounts or comments.
- Server logs: the Site is hosted on Cloudflare. For security and availability, Cloudflare briefly processes technical data such as IP address, browser information and request time.
- Visit statistics: Cloudflare Web Analytics, which uses neither cookies nor local storage, records aggregated, anonymous statistics (page views, country, device type, referring site). These are not used to identify anyone or to track you across sites.
Legal basis: legitimate interest in operating the Site securely and improving its content (KVKK Art. 5/2-f; GDPR Art. 6(1)(f)).
4. Email newsletter
You can subscribe to the newsletter with the form on the Site. The newsletter is a notification email that is sent only when a new article is published on the Site. It contains no advertising or promotion.
Data we process
| Data | Purpose |
|---|---|
| Email address | Sending notification emails |
| Language preference (Turkish / English) | Sending the article in the right language |
| Time of the request and of the confirmation, version of the consent text, page the form was submitted on | Demonstrating that consent was given |
| Which article notification was sent and when | Preventing the same email from being sent twice |
| An irreversible, salted hash of the IP address | Preventing abuse (spam) of the form |
Your IP address itself is not stored. You need to provide your email address to subscribe; without it the newsletter cannot be sent. Nothing else is required. No automated decision-making or profiling takes place.
Double opt-in
When you submit the form, we send you a confirmation email. Your subscription only starts when you open the link in that email and press “Confirm subscription”. Requests not confirmed within 7 days are deleted automatically.
Legal basis
Processing your email address for the newsletter is based on your explicit consent (KVKK Art. 5/1; GDPR Art. 6(1)(a)). Records proving consent are kept to comply with legal obligations and to establish, exercise or defend legal claims (KVKK Art. 5/2-ç and 5/2-e; GDPR Art. 6(1)(c) and (f)).
Withdrawing consent
You can withdraw your consent at any time:
- with the “Unsubscribe” link at the bottom of every newsletter email;
- with the unsubscribe button offered by your email program; or
- by writing to the contact address below.
Withdrawal does not affect the lawfulness of processing carried out before it.
No tracking
Newsletter emails contain no tracking pixels, remotely loaded images or tracked links. We do not measure whether emails are opened or which links are clicked.
5. Recipients
Data is not sold and is not shared with third parties for marketing. The following providers may access data as processors, and only to provide their service:
- Cloudflare, Inc.: hosting of the Site, visit statistics and the subscriber database (Cloudflare D1). The database is located in the European region.
- Microsoft (Microsoft 365 / Exchange Online): sending confirmation and notification emails. Copies of sent emails are kept in the sending mailbox for the period in section 6.
These providers may operate servers outside Türkiye. Transfers abroad are made in accordance with the conditions and procedures of KVKK Art. 9 and the related regulation. Data may be disclosed to competent public authorities only where legally required.
6. Retention
| Data | Period |
|---|---|
| Unconfirmed subscription requests | 7 days |
| Active subscription data | Until you unsubscribe |
| Consent records of people who unsubscribed (email address, language preference, consent text version, signup page, dates of subscription and withdrawal) | 3 years from withdrawal. No newsletter is sent to the address during this period, and the record is deleted at the end of it. |
| Delivery records | 30 days after a mailing is completed |
| Copies of sent emails in the sending mailbox | 30 days |
| IP address hashes | At most 24 hours |
Expired data is deleted automatically.
7. Your rights
Under KVKK Art. 11 you have the right to:
- learn whether your personal data is processed,
- request information about it if it is,
- learn the purpose of the processing and whether the data is used for that purpose,
- know the third parties in Türkiye or abroad to whom it is transferred,
- have it rectified if it is incomplete or inaccurate,
- have it erased or destroyed under KVKK Art. 7,
- have rectification, erasure or destruction notified to the third parties it was transferred to,
- object to a result against you arising exclusively from automated analysis,
- claim compensation if you suffer damage from unlawful processing.
Where GDPR applies, you also have the rights to restriction of processing, to data portability and to object (GDPR Arts. 15–21).
How to apply: send your request in writing to the postal address below, by registered electronic mail (KEP), with a secure electronic or mobile signature, or by email to the address below from the email address you subscribed with. Requests are answered free of charge within 30 days at the latest. You may also lodge a complaint with the Turkish Personal Data Protection Board or, where GDPR applies, with your local supervisory authority.
8. Changes
When this notice is updated, the date at the top of the page changes. Significant changes that directly affect newsletter subscribers will be announced by email.
Data controller and contact
ÖLN YÖNETİM DANIŞMANLIĞI YAZILIM LİMİTED ŞİRKETİ
Address: Şirinevler Mah. Kocasinan Cad. Fatih Apt. Blok No: 44/2, Bahçelievler / İstanbul
MERSİS: 0654-0941-2560-0001
Email: on@omerneziroglu.com