As Sirkhet Dijital Pazarlama ve Danışmanlık Limited Şirketi, we attach importance to the privacy and security of your personal data. This Privacy Policy explains for what purposes, on what legal grounds and how your personal data is processed when you visit our website, contact us, request a digital analysis/audit or use our services.
We do not sell your data. We process personal data to ensure the secure operation of our website, respond to your requests, provide our services, measure our performance and use analytics and marketing technologies only where we have your necessary consent.
1. Data controller
The data controller for personal data processed through this website is:
Sirkhet Dijital Pazarlama ve Danışmanlık Limited Şirketi
Address: İzmir - Konak, Akdeniz Mahallesi, Şehit Fethibey Caddesi, Heris Tower, No:55, İç Kapı No:091
E-mail: hello@sirkhet.com
KEP (registered electronic mail): sirkhetdijitalpazarlamavedanismanlik@hs01.kep.tr
This Policy applies to personal data processing activities involving Sirkhet's website, e-mail communications, digital analysis/audit requests sent by e-mail, and cookies and similar technologies used on the website.
Access to Google Search Console, Google Ads, Google Analytics, social media advertising accounts, CRM or similar systems and project data provided to us for client projects are managed under separately signed service agreements, confidentiality agreements and, where necessary, data processing agreements.
2. What personal data do we process?
Depending on how you use our website and services, we may process the following categories of personal data:
2.1. Contact data
Your first name, surname, e-mail address, telephone number, company name, website address and the content of messages you send us by e-mail to hello@sirkhet.com.
2.2. Request and audit application data
The website address, company information, marketing objectives, information about your existing digital assets and other information voluntarily provided by you in connection with your digital analysis or audit request.
2.3. Technical and security data
IP address, device type, browser type and version, operating system, HTTP request information, access time, error records, security logs and technical information necessary for the secure operation of our website.
2.4. Usage and analytics data
Pages visited, session duration, referral source, approximate location information, scrolling and clicking behaviour, device and browser information, campaign interactions and similar usage data.
These data are processed through analytics cookies and similar technologies only if you have given the necessary consent.
2.5. Cookie and similar technology data
Cookie identifiers, pixel tags, local storage identifiers, advertising/analytics identifiers and records of your cookie preferences.
For detailed information, you can review our Cookie Policy.
2.6. Client project data
Account access, campaign performance data, search console data, advertising account data, reporting data and project communications provided to us under an active service relationship.
Such data are separately governed by the relevant client agreement and, where necessary, a data processing agreement.
2.7. Special categories of personal data
We do not request special categories of personal data through our website. Please do not share health information, political opinions, religious beliefs, biometric data or similar special categories of personal data with us by e-mail.
3. How do we collect personal data?
Your personal data may be collected in the following ways:
| Collection method | Description |
|---|---|
| Directly from you | Information you provide to us through contact and audit requests sent by e-mail, meetings or client communications |
| Automatically | Through server logs, security records, cookies, pixels and similar technologies when you visit the website |
| Through third-party tools | Through analytics, advertising, tag management, hosting, security and reporting services |
| Within the client relationship | Through service agreements, project management, advertising/analytics account access and reporting processes |
4. For what purposes and on what legal grounds do we process your personal data?
We process your personal data for the following purposes and on the following legal grounds:
| Processing purpose | Categories of data processed | Legal ground under the Turkish Personal Data Protection Law No. 6698 (KVKK) | GDPR legal basis |
|---|---|---|---|
| Responding to your contact requests | Contact data, message content | Necessary for the conclusion or performance of a contract; legitimate interest | Article 6(1)(b), Article 6(1)(f) |
| Evaluating your audit or proposal requests | Contact data, company information, website address, request content | Pre-contractual processes; legitimate interest | Article 6(1)(b), Article 6(1)(f) |
| Providing services and managing the client relationship | Client project data, contact data, account access information | Conclusion or performance of a contract | Article 6(1)(b) |
| Ensuring the secure and proper operation of the website | Technical data, security logs, necessary cookies | Legitimate interest; legal obligation | Article 6(1)(f), Article 6(1)(c) |
| Measuring and improving website performance | Usage data, analytics cookie data | Explicit consent | Article 6(1)(a) |
| Marketing, advertising measurement and retargeting | Cookie/pixel data, campaign interactions, device identifiers | Explicit consent | Article 6(1)(a) |
| Sending commercial electronic messages | Contact data, contact preferences | Explicit consent or circumstances permitted by applicable legislation | Article 6(1)(a) or Article 6(1)(f) |
| Fulfilling accounting, tax, contractual and regulatory obligations | Invoice, contract, contact and transaction records | Legal obligation | Article 6(1)(c) |
| Managing rights requests and complaints | Identity verification information, request content, contact data | Legal obligation; legitimate interest | Article 6(1)(c), Article 6(1)(f) |
| Preventing or managing legal disputes | Contract, contact, transaction and log records | Legitimate interest; establishment, exercise or protection of a right | Article 6(1)(f) |
For processing activities based on explicit consent, you may withdraw your consent at any time. Withdrawal of your consent does not affect the lawfulness of processing carried out on the basis of consent before the date of withdrawal.
5. Cookies and similar technologies
Cookies, pixel tags, tag management tools and similar technologies may be used on our website.
Necessary cookies are required for the secure and proper operation of our website. These cookies are used for the basic functions of the website and cannot be disabled through the cookie preference panel.
Analytics and marketing cookies are placed only if your explicit consent is obtained. You do not have to accept these cookies. You can set your preferences using the “Reject all”, “Settings” or “Accept all” options.
You can change your cookie preferences or withdraw your consent at any time using the “Cookie settings” link at the bottom of our website.
Your choice is stored in your browser's localStorage under the key sirkhet_consent_v1, not in a cookie. The categories are Necessary / Analytics / Marketing. You can change your choice at any time using the “Cookie settings” link at the bottom of the page. Google Tag Manager (GTM-KNDM8L2) loads without consent; Google Analytics 4 loads through it only with analytics consent; Cloudflare Web Analytics also loads only with analytics consent. Google Search Console does not use cookies.
We do not currently use marketing cookies. If they are added in the future, they will be placed only with your consent.
For detailed information about cookies, you can review our Cookie Policy.
6. Third-party services we use
We may use third-party service providers for the operation and security of our website, performance measurement and marketing activities.
These providers may act as data processors, independent data controllers or joint controllers, depending on the product and configuration used. Each provider's role may vary according to the relevant terms of service, data processing terms and privacy policies.
The categories and examples of service providers we may use are as follows:
| Service provider / tool | Purpose of use | Types of data that may be processed |
|---|---|---|
| Netcup GmbH, Germany | Static website hosting on our own server using nginx | IP address, log records, device and browser information |
| Cloudflare, Inc. | DNS and network security | IP addresses may be processed |
| Google Analytics 4 | Website usage analysis and performance measurement with analytics consent | Cookie identifiers, device information, usage data, approximate location |
| Cloudflare Web Analytics | Cookieless page performance and visit measurement with analytics consent | Page address, referring page, browser and device type, performance timings; no cookies or cross-site tracking |
| Google Tag Manager | Management of tags and measurement tools | May not place cookies on its own, but may trigger other tags |
| Google Search Console | Monitoring organic search performance; does not use cookies | General and aggregated search performance data |
| E-mail and communications infrastructure providers | E-mail communication and request management | E-mail address, message content, technical delivery records |
| Legal, accounting and consultancy services | Regulatory obligations, contract management and dispute processes | Contract, invoice, contact and transaction records |
| Authorised public bodies | Fulfilment of legal obligations | Data required by legislation |
We do not sell your personal data to third parties directly in exchange for money. However, if you have given consent, pseudonymous identifiers and campaign interaction data may be shared with advertising and measurement providers in connection with analytics and marketing technologies.
7. Transfer of personal data abroad
Some service providers we use may be located outside Türkiye or process data on servers outside Türkiye. Your personal data may therefore be transferred abroad for hosting, security, analytics, advertising measurement, tag management, communication and reporting purposes.
Where personal data is transferred abroad, transfer mechanisms compliant with applicable legislation are used. These mechanisms may include adequacy decisions, appropriate safeguards, standard contracts, binding corporate rules or other transfer methods permitted by applicable legislation. Where explicit consent is required, the transfer is carried out only after the necessary information has been provided and your explicit consent has been obtained.
Where data is transferred abroad in connection with non-essential cookies, analytics tools, advertising pixels and retargeting technologies, these technologies are operated only after the necessary consent and preference management processes have been completed.
8. How long do we retain data?
We retain your personal data for as long as necessary for the purpose of processing and for the limitation periods and retention and evidential obligations prescribed by applicable legislation.
Our general retention periods are as follows:
| Data category | Retention period |
|---|---|
| E-mail requests and correspondence | 3 years from the last interaction, then deleted |
| Audit or proposal applications | 3 years from the application or last interaction |
| Client project data | For the duration of the service relationship and 5 years after it ends; longer if required by legislation |
| Accounting, invoice and contract records | For the period prescribed by applicable legislation |
| Google Analytics data | 14 months under the configured retention period |
| Server and security logs | Generally 90 days |
| Cookie consent records | Generally 1 year |
| Legal dispute and rights request records | For the duration of the dispute or request process and the applicable limitation period |
Data whose retention period has expired is deleted, destroyed or anonymised.
9. Data security
We apply appropriate technical and administrative measures to protect your personal data against unauthorised access, loss, alteration, disclosure or unlawful processing.
In this context, we may use the following measures according to our needs:
Secure connection via HTTPS,
Access authorisation and restrictions,
Access limited to authorised personnel and service providers,
Security logs and technical monitoring,
Regular system and security checks,
Necessary contractual data protection provisions with service providers,
Data processing agreements and confidentiality obligations where necessary.
We cannot guarantee that data transmission over the internet is entirely risk-free. However, we take reasonable and appropriate security measures to protect your personal data.
10. Automated decision-making and profiling
We do not carry out fully automated decision-making through our website that produces legal effects concerning you or similarly significantly affects you.
Analytics and marketing technologies may lead to limited profiling or segmentation for advertising measurement, audience creation and remarketing purposes, only if you have given explicit consent. You can reject such cookies and pixels or withdraw your consent through the cookie preference panel.
11. Commercial electronic messages
Providing us with your e-mail address or contact details does not automatically mean that you agree to receive marketing messages.
Where we need to send commercial electronic messages, we obtain your consent in accordance with applicable legislation or rely on exceptional circumstances permitted by legislation. You can opt out of marketing messages at any time.
Necessary information and operational messages sent in connection with a service, contract, request or existing client relationship are not considered marketing messages.
12. Your rights
You have various rights concerning your personal data under Article 11 of the KVKK and, to the extent applicable, the GDPR.
In this context, you may exercise the following rights:
To learn whether your personal data is being 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 for that purpose,
To know the third parties to whom your personal data is transferred within the country or abroad,
To request correction if your personal data is incomplete or inaccurately processed,
To request deletion or destruction of your personal data where the relevant conditions are met,
To request that third parties to whom your personal data has been transferred be notified of correction, deletion or destruction,
To object to a result against you arising from analysis by automated systems,
To request compensation if you suffer damage due to unlawful processing of your personal data,
To withdraw your consent for processing activities based on explicit consent,
To exercise your rights of access, correction, deletion, restriction of processing, data portability and objection, to the extent applicable,
To lodge a complaint with the relevant supervisory authority.
The scope of KVKK rights is also explained by the Personal Data Protection Authority.
13. How can you exercise your rights?
You can send us your rights requests through the following channels:
E-mail: hello@sirkhet.com
KEP: sirkhetdijitalpazarlamavedanismanlik@hs01.kep.tr
Address: İzmir - Konak, Akdeniz Mahallesi, Şehit Fethibey Caddesi, Heris Tower, No:55, İç Kapı No:091
Your application must include your first name, surname, contact details, the subject of your request and information that will help us verify your identity. We respond to your application as soon as possible and within 30 days at the latest, depending on the nature of the request. Applicable time limits for applications under the GDPR are also taken into account.
We may request additional information to verify your identity so that your request can be concluded securely.
14. Third-party links
Our website may contain links to third-party websites, social media platforms or service providers. We are not responsible for the privacy practices of these third parties. When you visit third-party sites, we recommend that you review their privacy policies.
15. Children's privacy
Our website is not intended for children. We do not knowingly collect personal data belonging to children. If you believe that a child's personal data has been sent to us, please contact us. We will make the necessary assessment and take reasonable steps to delete the relevant data.
16. Policy changes
We may update this Privacy Policy from time to time to reflect changes in our processing activities, the technologies we use or our legal obligations.
We publish significant changes on this page and, where necessary, inform you separately or obtain your consent again.
Continued use of the website does not mean that you consent to new processing activities requiring explicit consent. Where explicit consent is required, your consent is requested separately.
17. Contact
You can contact us with questions about this Privacy Policy or the processing of your personal data:
Sirkhet Dijital Pazarlama ve Danışmanlık Limited Şirketi
E-mail: hello@sirkhet.com
KEP: sirkhetdijitalpazarlamavedanismanlik@hs01.kep.tr
Address: İzmir - Konak, Akdeniz Mahallesi, Şehit Fethibey Caddesi, Heris Tower, No:55, İç Kapı No:091