Privacy policy

This is a translation for convenience. The Turkish version of this page is the authoritative one. It is an information notice under Turkish data protection law no. 6698 (KVKK).

1. Data controller

Bünyamin Ilhan
Ergenekon Mh. Özkök Sk. No 9
45400 Turgutlu / Manisa, Türkiye
Phone: +90 536 561 99 19
Email: mail@ilhan-buenyamin.com

VERBİS registration: the controller is exempt from registration in the Data Controllers' Registry, having fewer than 50 employees and an annual balance sheet below 100 million Turkish lira, and not processing special categories of data as its main activity. Crossing either threshold creates the duty to register.

2. What we process

Personal data reaches us from two sources on this website, and only one of them is stored by us.

The email you send us. The project request form opens your own mail program with what you filled in; it does not send the form to us through this website. Whether and when to send it is your decision. The email that reaches us contains your name, your email address, the project type you chose, the timeline you indicated, the description you gave of your project and your message. That email is kept in our mailbox.

The technical data that arrives with your request. As with any web request, your IP address and what your browser sends reach the server so that the page can be delivered to you. This site keeps no access log: logging is not enabled in our web server configuration, so this data is never written to disk and never stored.

3. How the data is collected

Your personal data reaches us in two ways: directly from you, through the email you send with your own mail program after filling in the form on this site; and automatically, through the technical data that arrives with your request when you open the site. Nothing is recorded on that second path. No data is collected from any other source, from third parties or from public registers.

4. Who it may be passed to

Your data is not sold, not rented and not passed on for marketing. It is passed to two categories of recipient only, and only so that the service can be provided: to our hosting provider, so that the site and the mailbox work at all; and to the competent public authorities where a legal obligation arises. Because the hosting provider is outside Turkey, that is also a transfer abroad; the section below sets out the detail.

5. Purposes and legal grounds

The data in the email you send is processed to answer your enquiry, prepare a quote and get back to you. The legal ground is article 5/2 (c) KVKK: directly related to the conclusion or performance of a contract.

The technical data arriving with your request is used only to deliver the page and is not stored. The legal ground is article 5/2 (f) KVKK: legitimate interest.

No data is processed to analyse user behaviour, to profile, to advertise or to market.

6. No cookies, no tracking

This website sets no cookies at all, and uses no analytics, advertising or tracking service. It makes no connection to third-party providers; every resource including the fonts is served from our own server.

Your browser's local storage holds four preferences, each of them created by an action of yours:

• theme — the colour scheme you picked, written when you click the light/dark toggle. It stays until you clear it.
• lang — the language you picked, written when you switch language. It stays until you clear it.
• fab-x and fab-y — where you left the back-to-top button if you dragged it, written only if you actually moved it. They stay until you clear them.

These never leave your device, are never sent to us or to anyone else, and hold nothing that could identify you. Each is strictly necessary for a function you explicitly asked for, so under the Board's guide on cookie practices none of them requires consent, and this site therefore shows no cookie consent window. You can clear them at any time in your browser settings.

7. Hosting and transfer abroad

The site is hosted on a server rented from IONOS SE. That server is in the European Union, and so is the mailbox that holds the email you send us, which sits in the same group's mail infrastructure.

Because the server is outside Turkey, every time you open the site your request and with it your IP address leave the country, and the email you send us rests in a mailbox abroad. Both are transfers abroad within the meaning of article 9 of law no. 6698.

Since 1 June 2024 that article sets out a sequence: first an adequacy decision by the Board; failing that, appropriate safeguards (the standard contract published by the Board, a written undertaking, or binding corporate rules); and only failing those, the incidental cases the law lists exhaustively. The Board has issued no adequacy decision for any country to date, so this transfer cannot rest on one.

The incidental cases are, as the name says, for transfers that do not recur; a transfer that happens every time the site is opened is not one of them. The basis therefore has to be one of the appropriate safeguards.

We plan to base this transfer on the standard contract published by the Board as the appropriate safeguard. We will approach the hosting provider to sign it; once it is signed, it will be notified to the Authority within five working days of signature, as article 9 requires, and this notice will be updated.

Your data is not sold to third parties and is not passed on for marketing.

8. Retention

The email you send us is deleted once your enquiry is finally settled, subject to statutory retention obligations. Since no access log is kept on the server, there is no log file to delete either.

9. Your rights (article 11 KVKK)

You have the right to learn whether your personal data is processed, to request information about it if it is, to learn the purpose and whether the data is used accordingly, to know the third parties at home or abroad to whom it is transferred, to have it corrected if it is incomplete or wrong, to have it erased or destroyed, to require that these actions are notified to the third parties the data was transferred to, to object to a result reached against you by analysing the data exclusively through automated systems, and to claim compensation if you suffer damage because the data was processed unlawfully.

10. How to apply

Send your request in writing to the address above or by email to mail@ilhan-buenyamin.com, in line with the Turkish communiqué on the procedures for applying to a data controller. Your application is answered within thirty days at the latest. If it is refused, or if no answer arrives in time, you may complain to the Turkish Personal Data Protection Board.

11. Showing your IP address on the home page

The terminal on the home page can show you your own public IP address. This happens only when you start it by clicking. An endpoint on our own server is queried and you are given only the address your request arrived from. No external service is involved, no location is derived from the address, and the address is neither stored nor shared. The server log described above is not affected, because there is none.

Everything else the terminal shows about your visit, meaning device, time, time zone, connection type, load time, number of requests and colour scheme, is determined by your own browser alone. Those values never leave your device.

12. Contact via WhatsApp

Where a WhatsApp link is offered on this site, it is an external link to the WhatsApp service. Contact is only made if you click it and use WhatsApp, in which case WhatsApp's own privacy policy applies. No data is transferred to WhatsApp through this website.

13. Security

The site uses SSL/TLS encryption to protect data in transit.

14. For visitors from the European Union

If you visit this site from the European Union, you also have the rights the GDPR gives you: information, rectification, erasure, restriction of processing, data portability and objection. You can exercise those through the same contact details above.