Privacy Policy

We appreciate your interest in our Privacy Policy. Qontrolo takes the protection of your data very seriously. In this Policy you can find out what data Qontrolo collects when you use the website and how it is used.

This Privacy Policy applies to www.qontrolo.com (our “website”) operated by Qontrolo of [Insert Address] (“Qontrolo”, “us” or “we”) acting as the data controller in accordance with Turkeys Law No. 6698 on Protection of Personal Data (“PDPL”). As well as the EUs General Data Protection Act (“GDPR”). If you have any questions, you can reach us using our Contact Form or write to the above address.

We would like to ask you to read this policy along with our Cookie Policy and if you are a user of our services, please also refer to our Data Processing Agreement.

General Information
What is Personal Data?
Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.

What is Special Category Data?
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to explicitly consent to the processing.

What is processing?
“Processing” means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

What are the legal bases of processing?
In accordance with the PDPL and GDPR, we have to have at least one of the following legal bases to process your Personal Data:

you have given your consent,
the data is necessary for the fulfillment of a contract / pre-contractual measures,
the data is necessary for the fulfillment of a legal obligation or
the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

Data we collect automatically
Log data
Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user’s device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

Content Delivery Network
We use a Content Delivery Network (CDN) to distribute our online content. Our CDN is a network of regionally distributed servers of our technical service providers connected via the Internet. When our website is visited, your device`s browser transmits information to these service providers, which is collected in corresponding server log files. Server log files are generally anonymized and then transmitted without any personal reference. Server log files include, in particular, i) details of the browser and operating system used, ii) the previously visited pages (so-called referral URL), iii) the IP address of the device used, iv) the name of the Internet provider, as well as v) the date, time of all page views including the amount of data transmitted. The legal basis for processing is our legitimate interest.

Hosting
To provide our website, we use the services of HostArmada INC, who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.

Cookies
We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. There are different types of cookies: i) Essential Cookies. Essential cookies are cookies to provide a correct and user-friendly website; and ii) Non-essential Cookies. Non-essential Cookies are any cookies that do not fall within the definition of essential cookies, such as cookies used to analyze your behavior on a website (“analytical” cookies) or cookies used to display advertisements to you (“advertising” cookies).

As set out in the PDPL and the GDPR, we need to obtain consent for the use of Non-essential Cookies. For further information on the Cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

When you watch our videos
On our website, we implement videos of the video portal “YouTube” of the company Google LLC.
Doing so, we use the “extended data protection mode” option provided by Google. When you call up a page that has an embedded video, a connection is established to Google’s servers and in the process the content is displayed on the website by notifying your browser. According to Google’s information, in “extended data protection mode” your data – in particular which of our Internet pages you have visited as well as device-specific information including the IP address – is only transmitted to the YouTube server in the USA when you watch the video. By clicking on the video, you consent to this transmission.

If you are logged in to Google at the same time, this information will be assigned to your YouTube member account. You can prevent this by logging out of your YouTube account before visiting our website.

Data we collect directly
General
We may ask you for Personal Data when you:
use our website,
request our demo, services, support, or information,
participate online or otherwise in marketing activities,
subscribe to Qontrolo`s marketing and promotional emails or other materials,
interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or
contact us.

Categories of Personal Data we collect may include your name, email address, and IP addresses. We may also collect demographic data such your interests, and preferences.

In order to provide you with a more consistent and personalized user experience in your interactions with Qontrolo, data collected through one source may also be linked to other data collected by Qontrolo through other sources. This may include data that helps us identify you when you access our website through several different devices.

Contacting us
In addition to your name, company name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and Contract.

We are present on social media on the basis of our legitimate interest (LinkedIn, Instagram, XING, and YouTube). If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any.

When using our services
We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, invoicing, fulfillment of our accounting and tax obligations. Your data will not be used by us for automated decision making or profiling, nor will it be shared with third parties. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations.

We ensure that access by our staff members to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our staff members and enforce privacy and protection safeguards strictly.

Administration, financial accounting, office organization, contact management
We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

Testimonials
Within your testimonial you may be able to display certain information, share certain details, knowledge, and insights. Content and data are publicly viewable. You have choices about the information on your testimonial. You don’t have to provide additional information and it is your choice whether to include sensitive information and to make it public. Please do not post or add personal data to your profile that you would not want to be available. The legal basis for the storage is our legitimate interest and your consent.

Principles of processing Personal Data
Storage and Retention
At the time of data collection, for example in the context of a contractual relationship we process and store Personal Data from you. We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

Security
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

Special Category Data
Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

Automated decision-making
Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

Do Not Sell
We do not sell your Personal Data.

Minors
We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

Sharing and Disclosure
We will not disclose or otherwise distribute your Personal Data to third parties unless this is i) necessary for the performance of our services, ii) you have consented to the disclosure, iii) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; or proceedings at home or abroad or to fulfill our legitimate interests.

International Transfer
We may transfer your Personal Data to other companies and/or staff members as necessary for the purposes described in this Privacy Policy. In doing so, your Personal Data may be transferred to so called third countries including India, Pakistan, Lebanon and Bangladesh. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

Third-party services and content
We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (“content”). This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any:

Analytics and Tracking: Google Analytics by Google LLC
Fonts: Font Awesome by Fonticons Inc,

Your Rights and Privileges
Privacy rights
Under the PDPL, you have the following rights:
Right to be informed
Right to access
Right to rectification
Right to erasure
Right to deletion
Right to object/opt-out

Under the GDPR, you can exercise the following rights:
Right to information
Right to rectification
Right to object to processing
Right to deletion
Right to data portability
Right of objection
Right to withdraw consent
Right to complain to a supervisory authority
Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

Updating your information
If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

Withdrawing your consent
You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

Access Request
In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The competent data protection authority in Turkey is: The Turkish Personal Data Protection Authority, Nasuh Akar Mahallesi Ziyabey Caddesi, 1407 Sokak No:4 06520, Çankaya, Ankara Turkey (www.kvkk.gov.tr)

Changes and Questions
We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise the Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Personal Data. If you would like to contact us regarding our privacy practices for any reason, please contact us.

Effective Date
Monday, April 3, 2023