Legal Information
Privacy Policy
This Privacy Policy explains how personal data collected through the website at https://hulaguhanlabs.com.tr, operated by Hülagühan Labs Yazılım Teknolojileri Ltd. Şti. ("Hülagühan Labs", "we"), and through the mobile applications we publish, is processed.
This English text is an informational translation. In the event of any discrepancy, the Turkish original prevails: read the Turkish version
1. Data Controller
The organisation acting as data controller under Turkish Personal Data Protection Law No. 6698 ("KVKK") is set out below:
- Legal name: Hülagühan Labs Yazılım Teknolojileri Ltd. Şti.
- Location: İstanbul / Türkiye
- Email: kvkk@hulaguhanlabs.com.tr
All applications and requests concerning the data controller are handled through the email address above.
The same organisation also acts as data controller for processing activities falling within the scope of the European Union General Data Protection Regulation ("GDPR").
2. Personal Data We Collect
We only collect data that is necessary for specific, explicit and legitimate purposes. The categories of data collected are as follows:
| Data category | Content | Collection method |
|---|---|---|
| Identity data | First name, last name | Contact form, email, job application |
| Contact data | Email address, company name | Contact form, email |
| Customer transaction data | Content of the enquiry, service of interest, budget range | Contact form |
| Transaction security data | IP address, browser and device information, access logs | Server logs (automatic) |
| Usage data | Pages visited, session duration, referring source | Cookies (only with your explicit consent) |
| Professional experience data | CV content, education and work experience details | Job applications (only when you send one) |
We do not request special categories of personal data. We do not collect data such as health, religion, political opinion or biometric data through our forms. Please do not send us such data on your own initiative.
3. Purposes and Legal Bases of Processing
| Purpose | Legal basis under KVKK Art. 5 | GDPR Art. 6 equivalent |
|---|---|---|
| Responding to enquiries and preparing proposals | Directly related to the establishment or performance of a contract | 6(1)(b) — performance of a contract / pre-contractual steps |
| Managing contractual processes and delivering services | Performance of a contract | 6(1)(b) |
| Ensuring site security and preventing abuse | Legitimate interest | 6(1)(f) — legitimate interest |
| Meeting statutory retention and disclosure obligations | Legal obligation | 6(1)(c) — legal obligation |
| Analytics measurement and site improvement | Explicit consent | 6(1)(a) — consent |
| Sending commercial electronic messages | Explicit consent | 6(1)(a) — consent |
| Evaluating job applications | Pre-contractual steps / explicit consent | 6(1)(b) and 6(1)(a) |
4. Retention Periods
We do not keep personal data for longer than the processing purpose requires. At the end of the period, data is deleted, destroyed or anonymised.
- Contact form records: 2 years from the last contact
- Contracts and commercial records: 10 years from the end of the relationship (as required by the Turkish Commercial Code and the Tax Procedure Law)
- Server access logs: 1 year (obligations under Law No. 5651 are reserved)
- Job applications: 1 year from the application date; 2 years with your consent
- Analytics cookie data: 14 months at most
5. Transfer of Personal Data
We do not sell your personal data and we do not transfer it to third parties for marketing purposes. Your data is transferred only in the following cases and only to the extent necessary:
- Hosting and infrastructure providers: in order to operate the site and the applications
- Email and communication service providers: in order to respond to your enquiry
- Accounting, legal and audit advisers: in order to meet legal obligations
- Competent public authorities: within the scope of requests for information and documents arising from legislation
Transfers abroad
Some of the infrastructure services we use may host their servers abroad. In that case the transfer is carried out under KVKK Art. 9 on the basis of an appropriate legal mechanism, such as transfer to a country with adequate protection, standard contractual clauses, or your explicit consent. For GDPR purposes, the Standard Contractual Clauses (SCCs) apply.
6. Your Rights
Under KVKK Art. 11 you have the following rights as a data subject:
- To learn whether your personal data is being processed
- To request information if it has been processed
- To learn the purpose of processing and whether the data is used in line with that purpose
- To know the third parties in Türkiye or abroad to whom the data has been transferred
- To request rectification if the data has been processed incompletely or inaccurately
- To request erasure or destruction under the conditions set out in KVKK Art. 7
- To request that rectification, erasure and destruction be notified to the third parties to whom the data was transferred
- To object to a result to your detriment arising from analysis carried out exclusively by automated systems
- To claim compensation if you suffer damage due to unlawful processing
If you fall within the scope of the GDPR you additionally have the rights to data portability, restriction of processing, objection to processing and withdrawal of the consent you have given. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.
7. How to Apply
You can send your requests by email to kvkk@hulaguhanlabs.com.tr. Depending on its nature, your application is concluded free of charge as soon as possible and in any case within thirty (30) days. If the process entails an additional cost, a fee may be charged in line with the tariff set by the Turkish Personal Data Protection Board.
If your application is rejected or you find the response inadequate, your right to lodge a complaint with the Turkish Personal Data Protection Board is reserved.
8. Data Security
We apply appropriate technical and administrative measures to prevent unlawful processing of and access to personal data:
- Encryption of all traffic with TLS (HTTPS)
- Access control based on authorisation and the principle of least privilege
- Keeping access logs and reviewing them regularly
- Applying dependency and infrastructure security updates regularly
- Confidentiality undertakings and awareness training for employees
- An incident response and notification procedure for data breaches
In the event of a data breach, the Turkish Personal Data Protection Board and the individuals concerned are notified without delay and within 72 hours at the latest from the moment we become aware of the breach.
9. Children's Privacy
Our services are not directed at people under the age of 18. We do not knowingly collect personal data from people under 18. If we notice, or are informed, that such data has reached us, the data is deleted without delay.
10. Mobile Applications
Applications we develop and publish on the App Store and Google Play are subject to this policy. The categories of data each application collects are additionally declared in the privacy labels (App Store Privacy Labels) and the data safety section (Google Play Data Safety) on the relevant store page.
- In-app permissions (location, notifications, camera and so on) are requested only so that the relevant feature can work, and the reason is explained on screen.
- In applications where an account is created, a request to delete the account and the associated data can be submitted from inside the app or via kvkk@hulaguhanlabs.com.tr.
- The advertising identifier (IDFA/AAID) is used only with your explicit permission.
11. Cookies
For detailed information about the cookies used on our site and how you can manage your preferences, see our Cookie Policy.
12. Changes to This Policy
We may revise this policy in line with changes in legislation or updates to our services. The current version is always published on this page and the "last updated" date at the top of the page is changed. Material changes are additionally communicated.
13. Contact
For questions about this policy you can reach us at kvkk@hulaguhanlabs.com.tr. We also recommend reading our Data Protection Notice and Terms of Use.