Scope
This policy covers people who visit the Efe Software website or use its contact form.
The contact-form confirmation acknowledges receipt of the privacy notice; it is not an explicit-consent declaration.
Data controller
The data controller is Ertan Efe – Şahıs Şirketi. Official notification address: Güllük Mah. Sağlık Sok. Faika Mithat Sözer İş Merkezi B Blok No:5/3 Daire:101, Adapazarı/Sakarya.
The e-mail address for personal-data applications is [email protected]. No KEP address is available.
Data processed and purposes
- The name, e-mail address and message entered in the contact form are processed to receive and answer the request and manage the correspondence record.
- IP addresses, request headers and technical logs are processed to deliver and secure the site and prevent abuse.
- The cookie choice and policy version are stored to apply the visitor's decision and ask again when the policy changes.
- Analytics data is processed to measure site usage only after the visitor grants analytics consent.
Collection method and legal basis
Data is collected electronically by automatic or partly automatic means through contact-form submissions, HTTP requests to the site, the browser preference record and measurement after analytics consent.
- Contact-form data: Article 5(2)(c) of Law No. 6698 (directly related to the formation of a contract) and Article 5(2)(f) (legitimate interest).
- Security and technical records and the cookie choice: Article 5(2)(f) (legitimate interest).
- Analytics measurement: explicit consent given through the analytics permission in the cookie notice.
Service providers and transfers
Through the use of Amazon Web Services (AWS), AWS SES, Cloudflare and Google Analytics 4 (GA4), personal data is transferred abroad to the countries and for the purposes listed in this section.
- Amazon Web Services (AWS): Servers are in the AWS Istanbul Local Zone (Türkiye); part of the AWS infrastructure is in Frankfurt (Germany). Transfer purpose: Hosting and backups.
- AWS SES: Form notification e-mails pass through eu-central-1 (Frankfurt, Germany). Transfer purpose: Delivery of contact-form notification e-mails.
- Cloudflare: The proxy is enabled; traffic, IP addresses and request headers pass through its global network. Transfer purpose: Traffic delivery and security/bot protection.
- Google Analytics 4 (GA4): Measures site usage only after analytics consent; measurement data is processed by Google on servers outside Türkiye, including in the United States. Transfer purpose: Usage measurement.
Retention periods
- Contact-form submissions are kept for 12 months.
- Submissions marked as spam are kept for 30 days.
- User- and event-level data in GA4 is kept for 2 months.
Cookies
The Cookie Policy lists the cookies and browser records used on the site, together with their purposes and durations.
Your rights and applications
You may send requests concerning your rights under Article 11 of Law No. 6698 by e-mail to [email protected] or in writing to the notification address Güllük Mah. Sağlık Sok. Faika Mithat Sözer İş Merkezi B Blok No:5/3 Daire:101, Adapazarı/Sakarya; requests are answered free of charge within 30 days at the latest.
Governing language
This English text is a translation. The Turkish version prevails in the event of any inconsistency.