Prepared under Article 10 of the Law. It explains which of your data we collect, for which purpose and on which legal ground we process it, how long we retain it and what your rights are.
1. Purpose
As TTEN Teknoloji A.Ş. (“tten”), in our capacity as data controller, we process your personal data in accordance with the Personal Data Protection Law No. 6698 (KVKK) (the “Law”).
This Privacy Notice has been prepared under Article 10 of the Law and explains the following: which of your data we collect, for which purpose and on which legal ground we process it, with whom we share it, how long we retain it and how you may exercise your rights.
Its relationship with our other documents:
General framework regarding the protection of your data: Privacy Policy
Cookies, measurement tools and cookie preferences: Cookie Policy
Processing activities based on your explicit consent and withdrawal of consent: Explicit Consent Text
The form of the application you will make to exercise your rights: KVKK Application Form
Rules for the use of our websites and services: Terms of Use
In the event of any conflict between this text and our other documents, this Privacy Notice shall prevail with respect to the processing of personal data.
2. Scope
This text applies to personal data processed within the scope of the domain names tten.net, store.tten.net and core.tten.net operated by tten and the services offered through them. Our customers, prospective customers, website visitors, employees of suppliers and business partners, and everyone who contacts us fall within the scope of this text.
Where our customers process data belonging to their own users on tten's infrastructure, tten acts as data processor. That relationship is outside the scope of this text and is governed by a separate Data Processing Agreement.
3. Data controller
Trade name: TTEN Teknoloji A.Ş.
Tax office / number: Ziyapaşa / 8591442515
Trade registry number: 94489 (Adana)
MERSİS number: 859144251500001
Address: Cemalpaşa Mah. Gazipaşa Blv. No: 20/11 Seyhan / Adana
General e-mail: [email protected]
KVKK application e-mail: [email protected]
Telephone: 0850 307 31 31
VERBİS registration information: tten is not registered with the Data Controllers Registry because it falls below the VERBİS registration obligation threshold
4. Categories of personal data processed
The categories below vary according to the type of relationship you have with us. The data of a person who merely visits our website is not the same as the data of a customer who purchases a service.
Identity information: First name, surname and, within the scope of the invoicing obligation, Turkish ID number
Contact information: Telephone number, e-mail address, address
Financial information: Invoice information, payment information, bank or card information
Transaction security data: IP address, log records, username, website activity
Customer transaction information: Purchase history, service usage information, support requests
Marketing information: Cookie records, survey and campaign responses, campaign interactions
We do not collect date of birth, gender, marital status, education status or photograph information. In accordance with the data minimisation principle of the Law, we do not collect any category that the service does not require.
During payment, your card information is processed through the payment infrastructures of PayTR Ödeme ve Elektronik Para Kuruluşu A.Ş. and iyzi Ödeme ve Elektronik Para Hizmetleri A.Ş. Your card information is not stored in tten's systems.
We do not process special categories of personal data (health, biometric data, religion, membership of associations/foundations/trade unions and the like).
5. Methods of data collection
We collect your personal data by wholly or partly automated means and by non-automated means provided that they form part of a data recording system:
Through our websites: contact and request forms, purchase and membership steps, cookies and measurement tools
Through Core Panel and Public API: account and service management operations, transaction records
Through e-mail and support channels: the messages and support requests you send us
Through live chat: what you write and the contact details you leave when you start the chat
Through telephone calls: the information you convey to us verbally during sales calls
Through physical and digital forms: contracts, applications and documents completed in legal processes
6. Processing purposes and legal grounds
Provision of the service, supply of server and infrastructure resources, management of your account: Being directly related to the establishment or performance of a contract
Carrying out purchase, invoicing and collection processes: Performance of a contract and fulfilment of a legal obligation
Handling support requests, managing customer relations, evaluating complaints and feedback: Performance of a contract and legitimate interest
Ensuring information security, preventing unauthorised access and misuse, keeping transaction records: Fulfilment of a legal obligation and legitimate interest
Fulfilment of retention and notification obligations arising from financial, commercial and communications legislation, responding to requests of competent authorities: Being expressly provided for by law and fulfilment of a legal obligation
Establishment, exercise and protection of rights in legal disputes: Being mandatory for the establishment, exercise or protection of a right
Development of services, usage measurement and business development activities: Your explicit consent (for cookie-based measurement) and legitimate interest
Sending promotional messages, campaigns and commercial electronic messages, targeted advertising activities: Your explicit consent
The details of processing based on explicit consent and the way to withdraw your consent are explained in the Explicit Consent Text.
7. Sharing of data
We do not sell your personal data. Sharing takes place only with the parties below and only to the extent required by the purpose that necessitates the sharing:
Public institutions and organisations authorised by law: Responding to a request or obligation arising from legislation
Suppliers and service providers (payment, invoicing, e-mail delivery, measurement, infrastructure): Provision and continuation of the service
Business partners: Carrying out jointly provided services
Lawyers, financial advisors and independent auditors: Following up legal disputes, fulfilment of legal and financial obligations
When working with our suppliers, we contractually guarantee that your data is processed only for the purpose we determine and that appropriate security measures are taken.
8. Transfer abroad
We distinguish between two sets of data:
Data on your servers: tten's infrastructure is hosted in Türkiye. The data you keep on your servers remains at service points in Türkiye and is not transferred abroad by tten.
Your personal data within the scope of this text (account, contact, invoice and site usage data): as a rule it is processed in Türkiye. Transfer abroad occurs in three cases, and these three rest on different grounds:
(a) Measurement and advertising tools: based on your explicit consent. The providers of the measurement, advertising and session recording tools we use on our websites (the list in section 9 and in the Cookie Policy: Google, LinkedIn, X, Mouseflow) may transfer the data collected through these tools to their servers abroad. For example, Mouseflow session recordings are kept in Europe (Amsterdam) and retained for 30 days. These transfers are based on the consent to transfer abroad which is separately submitted for your approval in the Explicit Consent Text. If you do not give your approval, these tools are not run.
(b) Live chat: only when you start the chat. The live chat window on our site runs on the infrastructure of Tidio LLC. The company is registered in the United States of America; the data is kept in Europe. The tool is not loaded when the page opens: it is activated only when you start the chat, and from that moment on what you write and the contact details you leave are transferred to the provider's infrastructure. If you do not start the chat, this transfer does not take place. The transfer is made upon your own request for the purpose of carrying out the chat.
(c) Transactional e-mail delivery: based on performance of the contract. We send notifications relating to your account (proforma, payment reminder, suspension warning, account transactions) through the infrastructure of MailerSend, Inc. The company is registered in the United States of America. This delivery is mandatory for carrying out the service: without receiving the notifications it is not possible to follow the service. For this reason this transfer is not dependent on your explicit consent, and your not giving consent to transfer abroad does not stop these notifications from being sent. The data transferred is limited to your first name and surname, your e-mail address and the content of the notification. We do not send your password or similar authentication information in clear form by e-mail, so such information does not reach the delivery infrastructure.
9. Cookies and measurement
We use cookies and similar technologies on our websites. The full list of the tools used, their types and the steps for managing your preferences are set out in the Cookie Policy.
Cookies other than strictly necessary cookies only run if you give your consent. Consent is obtained on a type basis: you can turn functional, analytics and advertising cookies on and off separately. Until you make a selection, none of these tools are loaded.
There is a live chat tool (Tidio) on our sites. This tool is not loaded when the page opens: it runs only when you start the chat and processes your chat content from that moment on. The details are in section 8.
A session recording and heat map tool (Mouseflow) runs on our sites. This tool records your mouse movement, clicks and page navigation behaviour. What you type into form fields is masked and is not included in the recording. Session recordings are kept in Europe (Amsterdam) and retained for 30 days.
10. Processing based on explicit consent
Processing for promotional and advertising purposes and cookie-based measurement are additionally based on the explicit consent you give. Processing necessary for the provision of the service does not require explicit consent. Such processing is based on performance of the contract and other legal grounds.
You are not obliged to give your consent, and not giving consent does not prevent you from benefiting from the service. You may withdraw your consent at any time. For details, please see the Explicit Consent Text.
11. Retention periods
We retain your personal data for the period necessary for the purpose for which it is processed and for the retention periods stipulated by legislation. When the period expires, the data is erased, destroyed or anonymised.
Identity, contact, invoice and payment information · Retention period: For the duration of the service relationship and 10 years from its termination · Basis: Retention of commercial books and records, and the statute of limitations for receivables arising from the contract
Customer transaction information (purchase history, service usage) · Retention period: Same · Basis: Same
Support requests and correspondence · Retention period: For the duration of the service relationship and 10 years from its termination · Basis: Evidence and statute of limitations
Core Panel and Public API transaction records · Retention period: For as long as the service relationship continues · Basis: Provision of the service and transaction security
Explicit consent records · Retention period: For as long as your consent is valid and 3 years after your withdrawal · Basis: Proof of consent
Cookie records · Retention period: For the lifetime of each cookie, at most 12 months. Individual periods are in the table in section 6 of the Cookie Policy · Basis: Cookie setting
Visitor measurement data · Retention period: At most 14 months in measurement tools, 30 days for session recordings (Mouseflow) · Basis: Tool configuration
Records relating to your KVKK application · Retention period: 3 years from the conclusion of the application · Basis: Conclusion of the application and audit
Where legislation stipulates a longer period, that period applies. When the retention period expires, your data is erased, destroyed or anonymised in the first periodic destruction cycle.
12. Your rights under Article 11 of the Law
As a data subject whose personal data is processed, you have the following rights:
To learn whether your personal data is 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 that purpose
To know the third parties to whom your personal data is transferred in Türkiye or abroad
To request the rectification of your personal data if it has been processed incompletely or inaccurately
To request the erasure or destruction of your personal data within the framework of Article 7 of the Law
To request that the rectification, erasure or destruction operations be notified to the third parties to whom your data has been transferred
To object to a result arising against you through the analysis of the processed data exclusively by automated systems
To claim compensation for the damage if you suffer damage due to the unlawful processing of your personal data
13. Exercising your rights
You may submit your requests by completing the KVKK Application Form. The form contains the information required by the Communiqué on the Procedures and Principles of Application to the Data Controller and sets out one by one the accepted application channels (written application, registered electronic mail, secure electronic signature, mobile signature, the e-mail address registered in our system).
Your application is concluded as soon as possible and in any case within thirty days, depending on the nature of your request. We cannot conclude applications where we are unable to verify your identity, in order not to disclose another person's data to a third party.
If your application is rejected, if you find our response insufficient or if no response is given within the period, you may lodge a complaint with the Personal Data Protection Board (Article 14 of the Law).
14. Changes to this text
We may update this text due to changes in legislation, updates to our services and changes in our processing activities. The current version is always published on this page and the date of last update appears at the beginning of the document.
15. Contact
You may send your questions regarding your personal data to [email protected]. For general matters you may use the address [email protected] and the number 0850 307 31 31.