This privacy notice has been prepared pursuant to Article 10 of Law No. 6698 on the Protection of Personal Data ("KVKK") and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform, in order to inform visitors of adsaturn.com (the "Site"), persons who request a proposal or analysis, and persons who contact us about the processing of their personal data.
1. Data Controller
- Data controller: Adsaturn Digital Marketing ("Adsaturn")
- Trade name and registration details: [Trade name and MERSIS/tax no.: to be confirmed by Hasan]
- Address: Emniyet Evleri Mah. Eski Büyükdere Cad. Sapphire No:1/1 İç Kapı 1 B 04, Kağıthane / İstanbul
- Email: info@adsaturn.com
- Phone / WhatsApp: +90 545 312 80 30
2. Personal Data Processed
Through the Site, we process only the data you provide to us and the limited technical data required for the Site to operate and be measured:
- Identity and contact data: full name, company name, phone number and/or email address.
- Request data: your website address, the services you are interested in, and anything you write in the notes field.
- Direct communication records: information you share and the content of correspondence when you contact us by email, phone, or WhatsApp.
- Transaction security data: standard access logs (IP address, date and time, requested page, browser information) that the server hosting the Site may keep for security and debugging purposes.
- Marketing and measurement data (only with your consent): cookie identifiers, pages visited, interactions, device and browser information, ad click and conversion data.
The Site does not request special categories of personal data (such as health, religious belief, or biometric data). Please do not share such information in the notes field.
3. Purposes of Processing
- To receive and evaluate your free analysis and proposal requests and to respond to you;
- To hold preliminary discussions, prepare proposals, and carry out the contracting process for the services you request (Google Ads, Meta Ads, TikTok Ads, ChatGPT Ads, SEO, GEO, map listings, social media management, web design, e-commerce migration, measurement);
- To respond to communication requests received by email, phone, and WhatsApp;
- To ensure the security of the Site, prevent misuse, and resolve technical issues;
- Subject to your consent, to measure Site traffic, analyze the performance of our advertising campaigns, and improve our ads;
- To fulfill our legal obligations and respond to requests and inspections by competent authorities;
- To establish, exercise, and protect rights in the event of a dispute.
4. Collection Method and Legal Grounds
Your personal data is collected directly from you through the proposal/analysis form on the Site and through email, phone, and WhatsApp correspondence, and by automated means through cookies and similar technologies. This data is processed pursuant to Article 5 of the KVKK on the following legal grounds:
- Processing is directly related to the establishment or performance of a contract (Art. 5(2)(c)): evaluating proposal and analysis requests, preparing proposals, and holding preliminary discussions.
- Compliance with a legal obligation (Art. 5(2)(ç)): record-keeping obligations and obligations to provide information to competent authorities arising under the legislation.
- Establishment, exercise, or protection of a right (Art. 5(2)(e)): retaining records that may serve as evidence in the event of a dispute.
- Legitimate interest (Art. 5(2)(f)): ensuring the security of the Site, storing strictly necessary preference records, and responding to messages you send us directly.
- Explicit consent (Art. 5(1)): analytics and advertising cookies and related transfers abroad. For details, see the Explicit Consent Statement and the Cookie Policy.
5. Transfer of Personal Data
Your personal data is not sold, rented, or shared with third parties for marketing purposes. Limited to the purposes above and in accordance with Articles 8 and 9 of the KVKK, data may be transferred only to the following groups of recipients:
- Service providers that provide the Site's hosting and email infrastructure, to the extent technically necessary;
- Google and Meta, as analytics and advertising service providers, subject to your consent;
- Providers of software and AI tools that we use in delivering our services and that are bound by confidentiality obligations, only to the extent required by the service;
- Legally authorized public institutions and organizations and judicial authorities, upon request.
When you use the WhatsApp link, your correspondence takes place through the WhatsApp service provided by Meta Platforms, and that service's own privacy terms apply.
6. Transfer Abroad
The servers of the Google (Google Analytics 4, Google Tag Manager, Google Ads) and Meta (Meta Pixel) services used for analytics and ad measurement are located abroad, primarily in the United States of America. These services are activated only with your cookie consent. Transfers abroad are carried out in accordance with the current version of Article 9 of the KVKK: on the basis of an adequacy decision, where one has been announced by the Personal Data Protection Board; where there is none, on the basis of appropriate safeguards such as standard contracts notified to the Board or contractual safeguards offered by the relevant service providers; and, in incidental cases where these cannot be applied, on the basis of your explicit consent.
The same safeguards apply where the servers of our hosting and email service providers are located abroad.
7. Retention Periods
- Proposal and analysis requests: retained for 2 years from the date of the request, after which they are deleted or anonymized. If a request results in a service contract, the data is retained for the duration of the contractual relationship and the applicable statutory retention periods.
- Email and WhatsApp correspondence: deleted within 2 years at the latest after the purpose of the communication no longer applies.
- Server access logs: deleted at the end of the periods prescribed by the relevant legislation.
- Cookie and local storage records: retained for the periods specified in the Cookie Policy.
8. Your Rights Under KVKK Art. 11
Under Article 11 of the KVKK, by applying to the data controller, you have the right to:
- Learn whether your personal data is being processed;
- Request information about the processing if your personal data has been processed;
- Learn the purpose of processing your personal data and whether it is used in line with that purpose;
- Know the third parties in Turkey or abroad to whom your personal data has been transferred;
- Request the rectification of your personal data if it has been processed incompletely or inaccurately;
- Request the erasure or destruction of your personal data under Article 7 of the KVKK where the reasons requiring its processing no longer exist;
- Request that the rectification, erasure, or destruction be notified to third parties to whom your personal data has been transferred;
- Object to any outcome to your detriment arising from the analysis of your processed data exclusively through automated systems;
- Claim compensation for damages if you suffer loss due to the unlawful processing of your personal data.
9. How to Apply
Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller, you may submit requests regarding your rights in Turkish, together with information sufficient to verify your identity (full name, Turkish ID number or, for foreign nationals, nationality and passport/ID number, address for notifications, email and phone if any, and the subject of the request), through one of the following channels:
- In writing, by a petition bearing a wet signature, delivered in person or through a notary public, to: Emniyet Evleri Mah. Eski Büyükdere Cad. Sapphire No:1/1 İç Kapı 1 B 04, Kağıthane / İstanbul
- By email to info@adsaturn.com from the email address you previously provided to Adsaturn and that is registered in our system;
- From your registered electronic mail (KEP) address, using a secure electronic signature or mobile signature.
Your application will be concluded free of charge as soon as possible according to its nature and within 30 days at the latest. If the process requires an additional cost, a fee may be charged according to the tariff set by the Personal Data Protection Board. If your application is rejected, you find the response insufficient, or no response is given in time, you may file a complaint with the Personal Data Protection Board under Article 14 of the KVKK within 30 days from the date you learn of the response and, in any event, within 60 days from the date of your application.