Privacy Notice (KVKK)
Effective date: 23 October 2026
The Turkish version of this notice prevails; this English version is provided for information.
This notice explains how we process your personal data, as required by Article 10 of the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform.
1. Data controller
E MMANUEL İÇ VE DIŞ TİCARET LİMİTED ŞİRKETİ, Şirinevler Mh. Adnan Kahveci Bul. Karanfil İş Merkezi No:184/8, 34188 Bahçelievler / İstanbul. MERSİS No: 0323126405500001. E-mail: info@emmanuel.com.tr
2. What we collect and how
- Contact and project requirements form: name, company, role, e-mail, phone, site location, project details, your message and any personal data in files you upload. Collected electronically, as you enter it.
- E-mail and phone: your contact details and the content of our correspondence. Collected electronically or orally.
- AI assistant: the content of your messages, the selected language and a random chat number. Collected electronically and automatically. Chat transcripts do not record your IP address or browser information.
- Visiting the Site: IP address, browser and device information, the page visited and strictly necessary cookies. Processed automatically by our server and Cloudflare. Umami, which we use for visit statistics, sets no cookies and does not store your IP address.
- Trade fairs and meetings: business card details and meeting notes. Collected on paper or electronically.
3. Purposes and legal bases
- Answering your request, preparing a preliminary solution and quotation, concluding and performing a contract: KVKK Art. 5(2)(c) (directly related to concluding or performing a contract).
- Managing customer relations and request history: KVKK Art. 5(2)(f) (legitimate interest).
- Answering your questions through the AI assistant and reviewing chat transcripts to improve the answers: KVKK Art. 5(2)(c) and (f).
- Delivering and securing the Site, preventing misuse and keeping visit statistics: KVKK Art. 5(2)(f).
- Commercial books, invoices and other legal obligations: KVKK Art. 5(2)(ç) (legal obligation).
- Establishing, exercising or protecting a right: KVKK Art. 5(2)(e).
4. Who receives your data
Your personal data may be shared, only for the purposes above, with:
- Our service providers, who process data on our behalf: Cloudflare, Inc. (USA; delivering and protecting the Site), Apple Inc. (iCloud Mail; the info@emmanuel.com.tr mailbox), Anthropic PBC (USA; answers of the AI assistant).
- The Site and its contact database run on a server outside Türkiye, in Belgrade, Serbia, operated by us.
- Our team: team members who handle your request work in Türkiye, Serbia and China and can access your data as far as their work requires.
- Manufacturers: to prepare a quotation we may share the necessary technical information (such as layout, load and capacity data) with manufacturers in China under confidentiality obligations; we take care not to include your contact details in what we share.
- Competent public authorities, where required by law.
Transfers abroad
Some of the transfers above go outside Türkiye. The Turkish Personal Data Protection Board has not yet issued an adequacy decision for any country. Under Article 9 KVKK, the signing of the standard contracts published by the Board with our service providers and their notification to the Personal Data Protection Authority are in progress. This section will be updated once these steps are completed.
5. How long we keep it
- Requests that do not lead to a quotation or contract: up to 2 years after our last contact.
- If a contract follows: the statutory retention periods for commercial and tax records (for example Art. 82 of the Turkish Commercial Code No. 6102 and Art. 253 of the Tax Procedure Law No. 213).
- AI assistant chat transcripts: up to 12 months in our systems.
- When the period ends, the data is deleted, destroyed or anonymised.
6. Your rights under Article 11 KVKK
You have the right to:
- learn whether your personal data is processed,
- request information about the processing,
- learn the purpose of processing and whether the data is used accordingly,
- know the third parties in Türkiye or abroad to whom the data is transferred,
- request correction of incomplete or inaccurate data,
- request deletion or destruction of the data under the conditions of Article 7 KVKK,
- request that correction, deletion or destruction be notified to the third parties who received the data,
- object to a result against you arising exclusively from automated analysis,
- claim compensation for damage caused by unlawful processing.
7. How to apply
In line with the Communiqué on the Procedures and Principles of Application to the Data Controller, you can send your application in Turkish in writing to our address above, or with a secure electronic or mobile signature, or from an e-mail address you have previously given us and that is registered in our systems, to info@emmanuel.com.tr. Please state your name, contact details and request. Applications are answered free of charge within 30 days at the latest (Art. 13 KVKK). If your application is rejected, you find the answer insufficient or you receive no answer in time, you may complain to the Personal Data Protection Board (Art. 14 KVKK).
8. Cookies
See our Cookie Policy (/cerez-politikasi).