Privacy notice
This English version is a translation provided for information only, and in the event of any inconsistency the Turkish version prevails.
This notice explains, under Article 10 of the Turkish Personal Data Protection Law No. 6698 (the "Law"), how the personal data of visitors to opussmart.com, and of anyone who contacts us by email or telephone, is processed.
Data controller
Opus Smart Solutions Teknoloji ve Danışmanlık Tic. Ltd. Şti.
Vişnezade Mah. Süleyman Seba Cad. No:79/1, 34357 Beşiktaş, Istanbul, Türkiye
Email: info [at] OpusSmart.com
Phone: +90 (212) 951 01 41
Data we process
When you visit the site: So that your browser can connect to our server, your full IP address is processed momentarily in the server's memory for the duration of the connection. Our server keeps a shortened access log entry for each page request. The entry contains only:
- a shortened form of your IP address (for IPv4 addresses the last part is set to zero; for IPv6 addresses only the first 48 bits are kept),
- the date and time of the request,
- the path of the page requested (without query parameters),
- the server's response code (HTTP status code) and the size of the response,
- the device class (desktop, mobile or automated client; for known bots, the bot's name),
- only the domain name of the site you came from (for example, www.linkedin.com).
Your full IP address and browser details are not written to the access log. Server error logs are kept only for critical errors; in exceptional cases these logs may contain a full IP address.
The site has no forms, accounts, cookies, analytics or advertising tools, and pages do not load resources from third parties.
When you contact us: We process the identity and contact details you share by email or telephone (such as your name, surname, organisation, email address and telephone number) and the content of the correspondence. Telephone calls are not recorded. Please do not share special categories of personal data (such as health data) that your request does not require.
Purposes
We process your full IP address only to establish the connection and to fix critical errors. We process access and error logs to keep the site secure, to detect attacks and attempts at misuse, to find and fix technical faults and to see, at a general level, where visits to the site come from.
We process contact data to answer your question or request, to handle discussions and proposals relating to a service you have asked about and, if the correspondence leads to a business relationship, to meet our record-keeping and retention obligations under the law.
Legal grounds
We rely on the following grounds in Article 5(2) of the Law:
- Full IP address, access and error logs: sub-paragraph (f): processing is necessary for our legitimate interest in keeping the site secure and working, provided that your fundamental rights and freedoms are not harmed. In the event of an attack or unlawful use, also sub-paragraph (e): processing is necessary to establish, exercise or protect a right.
- Contact data: for correspondence about a service or proposal, sub-paragraph (c): processing is directly related to entering into or performing a contract. For general enquiries, sub-paragraph (f): legitimate interest. For retention obligations under the law, sub-paragraph (ç): processing is necessary for us to comply with a legal obligation.
We do not rely on your explicit consent for this processing.
How we collect data
Your full IP address and the data in the access and error logs are collected automatically by the server software when you visit the site. Contact data is collected from you electronically through the emails you send us, and verbally during telephone calls.
Transfers
Your personal data is transferred only to the following groups of recipients, for the purposes stated:
- Our hosting provider: The site, your full IP address and the access and error logs are processed on this provider's servers in the United Kingdom (London).
- Our email service provider: Emails you send us are kept on this provider's servers in the European Union.
- Authorised public bodies and judicial authorities: only where there is a legal obligation or a duly made request, under sub-paragraph (ç) of Article 5(2) of the Law.
Our hosting and email service providers process the data only on our behalf and on our instructions.
Transfers abroad: Because the hosting and email servers are outside Türkiye, processing the data on these servers is a transfer abroad within the meaning of Article 9 of the Law. These transfers are made only for the purposes stated above.
Retention
- Full IP address: not stored, except in critical error logs.
- Access and error logs: kept for no more than 14 days, then deleted automatically.
- Contact data: kept for 2 years. If the correspondence leads to a business relationship, it is kept for the period required by the applicable legislation.
When the retention period ends, the data is deleted, destroyed or anonymised.
Cookies
Our site does not use cookies or any analytics or advertising tracking tools, so no cookie consent is requested. If this changes, we will update this notice in advance.
Your rights
Under Article 11 of the Law, you have the right to apply to us to:
- find out whether your personal data is processed,
- request information about it if it has been processed,
- find out the purpose of the processing and whether the data is used for that purpose,
- know the third parties in Türkiye or abroad to whom it has been transferred,
- ask for it to be corrected if it is incomplete or inaccurate,
- ask for it to be erased or destroyed under the conditions in Article 7 of the Law,
- ask for any correction, erasure or destruction to be notified to the third parties to whom the data has been transferred,
- object to an outcome against you that results only from analysis of the data by automated systems,
- claim compensation if you suffer damage because of unlawful processing.
How to apply
Under the Communiqué on the Procedures and Principles for Applications to the Data Controller, you may send your application in Turkish by any of the following means:
- a signed letter delivered by hand or by post to our address above,
- an email signed with a secure electronic signature or mobile signature, sent to info [at] OpusSmart.com,
- an email sent to info [at] OpusSmart.com from an address you have previously given us and that is recorded in our systems.
Your application must include your name and surname and, for written applications, your signature; for Turkish citizens, your Turkish identity number, and for foreign nationals, your nationality and passport number or identity number if any; your residential or business address for service; your email address, telephone and fax number for notifications, if any; and the subject of your request.
We will conclude your application as quickly as its nature allows, and within 30 days at the latest, free of charge. If the reply exceeds 10 pages, a fee of TRY 1 may be charged for each additional page, and if the reply is provided on a recording medium such as a CD or memory stick, a fee equal to the cost of that medium may be charged.
If your application is refused, if you find the reply insufficient or if no reply is given in time, you may complain to the Personal Data Protection Board within 30 days of learning of the reply, and in any case within 60 days of the application date.
