Last updated: [DD.MM.YYYY]. This document is a general template and does not constitute legal advice. Replace bracketed fields with your company details and have it reviewed by legal counsel before publication.
1. Introduction
This Privacy Policy explains how [COMPANY NAME] ("we", "us", "our") collects, uses, stores, shares and protects your personal data when you use the [BRAND] platform, websites and related services (the "Service"). We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and, where applicable, the Turkish Personal Data Protection Law No. 6698 (KVKK).
2. Data Controller
The controller responsible for your personal data is:
- Company: [COMPANY LEGAL NAME]
- Address: [registered address]
- Email: [privacy@example.com]
- Data Protection Officer / contact (if any): [DPO name / email]
3. Personal Data We Collect
- Identity & account data: first/last name, email address, phone number, password (stored hashed), account type and role.
- Subscription & billing data: plan selection, subscription status, licenses, billing details and transaction records.
- Usage & technical data: IP address, browser and device information, log records, pages viewed and timestamps.
- Cookies & similar technologies: as described in our Cookie Policy.
- Communications: messages you send us through support, email or forms.
4. How We Collect Data
- Directly from you — when you register, subscribe, activate a license, or contact us.
- Automatically — through cookies, server logs and analytics tools as you use the Service.
- From third parties — e.g. payment or marketplace providers where applicable.
5. Purposes and Legal Bases (GDPR Art. 6)
- To provide the Service (account creation, license activation, subscriptions) — performance of a contract.
- To process payments and manage billing — performance of a contract / legal obligation.
- To communicate service notices, security alerts and support responses — legitimate interest / contract.
- To improve and secure the Service, prevent fraud and abuse — legitimate interest.
- To comply with legal obligations (accounting, tax, lawful requests) — legal obligation.
- Analytics and marketing cookies — your consent (which you can withdraw at any time).
6. Cookies and Tracking
We use essential cookies necessary for the Service to function, and — only with your consent — functional, analytics and marketing technologies. You can manage your choices at any time via the cookie banner or your browser. See our Cookie Policy for details.
7. Sharing and Processors
We do not sell your personal data. We may share it with:
- Service providers acting as data processors (hosting, email delivery, payment, analytics) under appropriate data-processing agreements.
- Authorities or third parties where required by law or to protect our rights.
8. International Transfers
Where personal data is transferred outside your country or the EEA, we rely on appropriate safeguards such as adequacy decisions or Standard Contractual Clauses.
9. Data Retention
We retain personal data only as long as necessary for the purposes described above or as required by law (e.g. accounting records). When no longer needed, data is deleted or anonymized.
10. Security
We apply technical and organizational measures — including encryption in transit, hashed passwords, access controls and logging — to protect personal data against unauthorized access, loss or alteration.
11. Your Rights (GDPR Art. 15–22)
- Access your personal data and obtain a copy.
- Rectify inaccurate or incomplete data.
- Erase your data ("right to be forgotten") where applicable.
- Restrict or object to certain processing.
- Data portability.
- Withdraw consent at any time, without affecting prior lawful processing.
- Lodge a complaint with your supervisory authority.
To exercise these rights, contact us via our contact page or at [privacy@example.com].
12. Children's Privacy
The Service is not directed to children under the age required by applicable law, and we do not knowingly collect their personal data.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be announced through the Service. The "Last updated" date reflects the latest revision.
14. Contact
For any privacy-related questions, please reach out via our contact page or email [privacy@example.com].