This policy explains which personal data ee İstanbul (www.ee-istanbul.com), operated by ee İstanbul Proje Tasarım Yönetim ve Danışmanlık Ltd. Şti. ("we"), processes, why, for how long, and what rights you have. It describes what the site actually does today. If that changes, we update this policy before the change takes effect.

This policy is based on the Turkish Personal Data Protection Law no. 6698 (KVKK) and, for visitors in the European Union, refers to the General Data Protection Regulation (GDPR). The information required by KVKK Art. 10 is also given in the separate "KVKK Information Notice" page.

1. Who is responsible

The controller for this site is ee İstanbul Proje Tasarım Yönetim ve Danışmanlık Ltd. Şti..

Address: İçerenköy Mahallesi Çayır Caddesi Ayplaza No:2 Kat:3, Ataşehir / İstanbul
Email: info@ee-istanbul.com
Phone: +90 216 573 08 08

For any privacy question or request, write to the email address or the postal address above.

2. What this site is

ee İstanbul is the presentation and contact site of ee İstanbul Proje Tasarım Yönetim ve Danışmanlık Ltd. Şti.. The site offers no membership or account area for visitors, and nothing is sold or paid for through it. You can read every page without giving us any personal data.

3. What we process, why, and on which legal basis

For each processing we state the legal ground under KVKK and (for EU visitors) under the GDPR.

3.1 Delivering the pages

To deliver a page, our hosting and network providers necessarily process your IP address and technical request data (requested address, time, browser type). We use this only to deliver the site and to protect it against attacks and abuse, not to identify you or build a profile. Hosting request logs are kept for about 30 days.

Legal basis: our legitimate interest in operating a secure website (KVKK Art. 5/2(f); GDPR Art. 6(1)(f)).

3.2 Visit statistics

The site counts page views with the hosting platform's own first-party measurement. No third-party analytics service is used.

• Without your consent, a page view is recorded without any identifier: the page address and title, the referring page, the page language, and the screen and window size.
• Only if you allow analytics in the cookie banner, a random visitor ID is also stored in your browser (localStorage) and a random session ID for the current visit (sessionStorage), so that returning visits can be counted. Events with these IDs are kept for 400 days; statistics aggregated from them for up to 1,100 days.

Your IP address and browser user-agent are not stored with these events.

Legal basis: counting without identifiers, our legitimate interest in knowing which pages are read (KVKK Art. 5/2(f); GDPR Art. 6(1)(f)); the IDs, your consent (KVKK Art. 5/1; GDPR Art. 6(1)(a)), which you can withdraw at any time.

3.3 Your cookie choice

When you answer the cookie banner, your choice is saved in a cookie on your device and we keep a proof record of it: a random consent ID, the categories you allowed, the policy version, the time, your browser user-agent and a salted one-way hash of your IP address (never the IP address itself). The record is kept for 365 days plus 3 years, so that we can show which consent was given.

Legal basis: our legal obligation to be able to demonstrate consent (KVKK Art. 5/2(ç); GDPR Art. 6(1)(c) together with Art. 7(1)).

3.4 Contact and request forms, email

If you fill in a contact or request form on the site, we receive the details the form asks for (your first name, surname, phone number, email address and message) and use them only to answer and assess your request. Submitted forms are stored on the hosting platform and are viewed only by authorised persons who handle the request. Your request is kept for as long as needed to answer it and for any follow-up correspondence, and is deleted when you ask us to delete it.

Legal basis: our legitimate interest in answering requests (KVKK Art. 5/2(f); GDPR Art. 6(1)(f)), or steps you ask us to take (KVKK Art. 5/2(c); GDPR Art. 6(1)(b)).

3.5 Job applications

If you apply through the careers form, we receive the details the form asks for (your name, phone number, email address) and the CV you upload. We use them only to assess your application and to contact you.

Legal basis: assessing your application, that is, steps you ask us to take (KVKK Art. 5/2(c); GDPR Art. 6(1)(b)), and our legitimate interest in contacting you when a suitable position opens (KVKK Art. 5/2(f); GDPR Art. 6(1)(f)). You can ask us at any time to delete your CV.

3.6 Email newsletter

If you enter your email address in the sign-up form on the site, we store your email address and the place and time of the sign-up, and use the address only to send the updates the form announces. You can stop every message with the link in it or by writing to us; if you unsubscribe, we keep a minimal record so that we do not email you again.

Legal basis: your consent (KVKK Art. 5/1; GDPR Art. 6(1)(a)), which you can withdraw at any time.

3.7 Embedded third-party content

Some pages may embed third-party content such as Google Maps. When you view such content, the provider receives your IP address and browser details itself and processes them under its own privacy policy. We do not send data to these providers.

Legal basis: our legitimate interest in displaying the content of the site (KVKK Art. 5/2(f); GDPR Art. 6(1)(f)).

3.8 What we do not do

We do not offer visitor accounts, send anything beyond the newsletter you opt in to, sell anything through this site, show third-party advertising, sell personal data, or make decisions about you by automated means.
We do not use third-party analytics or advertising tags.

4. Who receives data

• Hosting and site software: the site runs on the CIQRA platform, operated by CIQRA OÜ (Estonia), on Microsoft Azure data centres in Germany (Frankfurt, with a backup region in Germany). CIQRA OÜ processes this data only on our behalf and on our instructions (as processor) and does not use it for its own purposes.
• Network and security: Cloudflare, Inc. delivers the pages and protects the site against attacks, and in doing so processes your IP address and request data.
• Email: if we answer you by email, the reply is sent through our email service provider.
• Authorities: only where the law requires it.

No one else receives your data, and we do not sell it.

5. Transfers abroad

The site's data is stored in the EU (Germany); the service provider is established in Estonia and Cloudflare, Inc. is based in the United States. Your data is therefore transferred abroad. The transfer is limited to what is needed to run the site and is assessed under KVKK Art. 9. For details, write to info@ee-istanbul.com.

6. How long we keep data

• Hosting request logs: about 30 days.
• Page views without identifiers: kept as aggregate statistics.
• Analytics events with visitor/session IDs (only with consent): 400 days; aggregated statistics up to 1,100 days.
• Cookie consent proof: 365 days plus 3 years.
• Contact and requests: as described in 3.4.
• Job applications: during the assessment; you can ask for deletion at any time.
• Newsletter sign-up: until you unsubscribe, then a minimal suppression record.
• Backups of the platform: up to 35 days, then overwritten.

7. Your rights

Under KVKK Art. 11 you have the right to learn whether your personal data is processed, to request information about it, to learn the purpose of processing and whether it is used accordingly, to know the third parties to whom it is transferred in Turkey or abroad, to ask for correction if incomplete or inaccurate, to ask for deletion or destruction under KVKK Art. 7, to ask that these actions be notified to the third parties to whom the data was transferred, to object to a result against you arising from automated analysis, and to claim compensation if you suffer damage from unlawful processing. Where processing is based on consent, you can withdraw it at any time without affecting earlier processing; for analytics, use the cookie settings button that remains on every page after you have made a choice.

Write to info@ee-istanbul.com. We answer within 30 days at the latest, free of charge depending on the nature of the request. You also have the right to complain to the Turkish Personal Data Protection Board (www.kvkk.gov.tr) and, if you live in the EU, to the data protection authority where you live or work.

8. Children

This site is not directed at children, and we do not knowingly collect personal data from children.

9. Security

Pages are served only over encrypted connections (HTTPS). The platform separates each site's data at database level and limits access to authorised staff.

10. Changes

We update this policy when the site changes.