As CYCLE Marketing Digital Strategy Consultancy Inc. (“CYCLE”), we present the following information in compliance with our obligation to inform and in accordance with Law No. 6698 on the Protection of Personal Data (“KVKK”) and other relevant regulations, acknowledging that the protection of the Personal Data we process as the Data Controller is a fundamental right. This information notice has been drafted to inform you about the processing of your personal data (detailed below) submitted via the contact form on CYCLE’s Website (https://cycle-marketing.com/) and the purposes of processing this data. Cookies are used on the Website and Mobile Application. You can access CYCLE’s Cookie Policy at “…………………”. DEFINITIONS In this Information Notice:
- Explicit Consent: Refers to the consent based on being informed about a specific subject and expressed freely.
- Data Subject: Refers to the natural person whose Personal Data is processed.
- Personal Data: Refers to any information relating to an identified or identifiable natural person.
- Processing of Personal Data: Refers to any operation performed on data, such as collecting, recording, storing, retaining, changing, re-organizing, disclosing, transferring, taking over, making available, classifying, or preventing its use, either wholly or partially, through automated or non-automated means, provided that it is part of a data recording system.
- KVKK: Refers to Law No. 6698 on the Protection of Personal Data.
- Board: Refers to the Personal Data Protection Board.
- Authority: Refers to the Personal Data Protection Authority.
- Special Categories of Personal Data: Refers to data related to an individual’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance, association, foundation or trade union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data.
- Data Controller: Refers to the natural or legal person who determines the purposes and means of processing Personal Data and is responsible for establishing and managing the data recording system.
- Data Processor: Refers to the natural or legal person who processes Personal Data on behalf of the Data Controller based on the authority given.
- Website: Refers to CYCLE’s website (https://cycle-marketing.com/).
PROCESSED PERSONAL DATA CYCLE processes the following personal data shared/provided by you and/or obtained by CYCLE for the customers to whom we offer our products and services:
- Identity Information (name-surname),
- Contact Information (mobile phone number, email address),
- Customer Transaction Information (responses, behaviors, preferences, search activities related to notifications/surveys/offers/campaigns within the Website, IP address, cookie and ad identifier, and traffic information on the site and application).
- Information of the Represented/Worked Company.
PURPOSES OF PROCESSING PERSONAL DATA Following your completion of the Contact Form in the “Contact” section, your personal data will be collected, recorded, processed, stored, and classified as the Data Controller to respond to your question or request, evaluate your feedback, and communicate with you in this context based on the legal reason of necessity for the protection of our legitimate interests as per Article 5/2(f) of the Law. In addition, your personal data may be disclosed to official authorities without your explicit consent if required by the relevant legislation and in cases where disclosure is mandated by imperative legal provisions. Your personal data may also be used and shared with courts and other competent institutions and organizations as necessary concerning any legal dispute affecting CYCLE or potential disputes. In this context, your personal data may be processed without your explicit consent under Article 5/2(c) of the Law to fulfill CYCLE’s legal obligations and under Article 5/2(e) to establish or protect CYCLE’s rights. METHOD OF COLLECTING PERSONAL DATA Your Personal Data is collected by CYCLE to enhance the quality of the services provided; directly from you, during your visit to the Website and our office, through contact forms on the Website, live support plugins on the Website, forms generated through ads, phone calls, online messaging portals, WhatsApp, online support, and social media channels, video, photo, and email communications, or shared directly by you or through persons or institutions you designate. STORAGE AND DISPOSAL OF PERSONAL DATA We store your Personal Data mentioned above in both digital and physical environments owned by CYCLE. Your Personal Data is processed in connection with and limited to the purpose requiring its processing and retained in the most accurate and up-to-date form as reported by you or the supplier company to which you are affiliated as an Employee/Authorized/Contact Person. When the reasons for processing no longer exist, your Personal Data will be deleted, destroyed, anonymized, or used for statistical purposes following KVKK and relevant legislation and in line with CYCLE’s storage and disposal policies. LEGAL REASONS FOR PROCESSING YOUR PERSONAL DATA Your Personal Data is collected verbally, in writing, or electronically through various communication channels (Website, contracts, electronic mail, communication and application forms, etc.) established during and throughout your legal relationship with CYCLE. The collected Personal Data will be processed based on the compliance reasons specified in Articles 5, 6, and 8 of KVKK. Your Personal Data, which will be processed under the personal data processing conditions, principles, and purposes stated in Articles 5 and 6 of KVKK, is processed based on:
- Your explicit consent for commercial communication activities and for contacting you for commercial purposes,
- Your explicit consent for the overseas transfer of your Personal Data until June 1, 2024, and after that date if the Board does not grant approval or adequate guarantees are not provided,
- The legal reason for processing Personal Data “being necessary for the protection of the legitimate interests of the Data Controller provided that it does not damage the fundamental rights and freedoms of the Data Subject” concerning our customer relations processes,
- Legal obligations arising from legislation; for carrying out work and operations within the scope of compliance with Occupational Health and Safety Legislation and for any work and operations within the legal framework of our field of activity,
- The legal reason for processing Personal Data “being necessary for the establishment, exercise, or defense of a legal claim” concerning legal disputes, investigations, and other judicial/official processes.
You may withdraw your consent at any time regarding the processing of Personal Data based on your explicit consent. LEGAL GROUNDS FOR PROCESSING SPECIAL CATEGORIES OF PERSONAL DATA With the amendment to the Law effective as of June 1, 2024, the processing of special categories of personal data is permissible under the following circumstances:
- If the Data Subject has given explicit consent,
- If processing is explicitly stipulated by law,
- If processing is necessary to protect the life or physical integrity of the Data Subject or another person who is incapable of giving consent due to actual impossibility or whose consent is not legally valid,
- If processing relates to personal data that has been publicly disclosed by the Data Subject and is consistent with their disclosure purpose,
- If processing is necessary for the establishment, exercise, or defense of a legal claim,
- If processing is necessary for protecting public health, preventive medicine, medical diagnosis, treatment, and the management and financing of healthcare services by persons or authorized institutions bound by confidentiality,
- If processing is necessary to fulfill legal obligations in employment, occupational health and safety, social security, social services, and social assistance areas.
TRANSFER OF YOUR PERSONAL DATA Your Personal Data obtained directly from you and legally obtained by CYCLE from various channels may be transferred for the purposes stated in this Information Notice and limited to these purposes. Transfers are carried out in accordance with the security and confidentiality principles set by the legislation and with sufficient and effective measures taken to:
- Public authorities or organizations legally authorized to request these data due to legal requirements,
- Institutions we have contractual relationships with domestically and internationally, our lawyers and consultants, agents, business partners, suppliers benefiting from our services, solution partners, service provider companies, and intermediary companies,
- All CYCLE Affiliates and any other commercial entities/persons/companies established by Gamze Tüysüz and/or their authorized persons/employees.
INTERNATIONAL TRANSFER Due to our cooperation with international partners and the use of servers located abroad for communication methods such as WhatsApp, Gmail, and the necessity of receiving support in information technologies, marketing/analysis/segmentation/advertising activities, consultancy services, social media request/complaint management, software development and support services, advertising, digital marketing and analysis services, and location data collection services, hosting, maintenance and development services, and online survey services, your data (including identity, contact, customer transaction, finance, marketing, transaction security, legal transaction data, and visual and audio records shared with us) may be transferred abroad. This transfer will be carried out based on the processing purposes specified in this information notice, the proportionality principle, and other legal limitations stated in the Law. STORAGE OF YOUR PERSONAL DATA Your Personal Data will be processed and stored based on your explicit consent under Articles 5 and 6 of KVKK. All actions taken concerning the deletion, destruction, and anonymization of your Personal Data are recorded by CYCLE. When the purpose requiring the processing of your Personal Data is no longer applicable, or when the mandatory storage periods required by KVKK expire, your data will be deleted, destroyed, or anonymized. YOUR RIGHTS REGARDING THE PROTECTION OF YOUR PERSONAL DATA Under Article 11 of KVKK, you can make the following requests regarding your Personal Data:
- To learn whether your personal data is being processed,
- To request information if your personal data has been processed,
- To learn the purpose of processing your personal data and whether it is used in accordance with its purpose,
- To know the third parties to whom your
