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Personal Data Protection

 

Policies, privacy notices and rules regarding the processing of personal data by CLYMFLEX DANIŞMANLIK LİMİTED ŞİRKETİ under the Turkish Personal Data Protection Law No. 6698 (“KVKK”).

Contents

  1. Website Privacy and Cookie Notice
  2. Data Subject Rights and Application Form
  3. Privacy Notice for Clients and Prospective Clients
  4. Privacy Notice for Job and Internship Applicants
  5. Privacy Notice for Newsletter Subscribers
  6. Privacy Notice for Suppliers and Prospective Suppliers
  7. Privacy Notice for Communication via E-mail and Contact Channels

 

Data Controller

Title: CLYMFLEX DANIŞMANLIK LİMİTED ŞİRKETİ (“Clymflex”, “we”, “us”)
Address: BİRLİK MAH. 457 SK. CAN APT. NO: 3 İÇ KAPI NO: 5 ÇANKAYA / ANKARA
MERSIS No: 0211153315600001
E-mail: msg@clymflex.com
Registered E-mail (KEP): msg@clymflex.com
Website: www.clymflex.com

 

1. Website Privacy and Cookie Notice

 

1.1 Purpose and Scope

As data controller, Clymflex attaches great importance to the protection of the personal data of visitors to www.clymflex.com (the “Website”). This notice is provided under Article 10 of KVKK and the Communiqué on Procedures and Principles to be Followed in Fulfilment of the Obligation to Inform, and explains which personal data we process when you use the Website, including through cookies and similar technologies, for which purposes and on which legal grounds, to whom the data may be transferred, and your rights.

 

1.2 What Are Cookies?

Cookies are small text files placed on your device by the websites you visit. They allow a website to function, to remember your preferences and to understand how it is used. Cookies may be session cookies (deleted when you close your browser) or persistent cookies (kept for a defined period), and may be first-party (set by the Website) or third-party (set by service providers).

 

1.3 Cookies Used on the Website

Strictly necessary cookies. These are required for the Website to operate securely and cannot be switched off. They are processed under Article 5(2)(c) KVKK (necessary for the establishment or performance of a contract) and Article 5(2)(f) (legitimate interest of the data controller).

  • XSRF-TOKEN — Purpose: Security; prevents cross-site request forgery; Type: First-party (Wix); Retention: Session
  • hs — Purpose: Security; Type: First-party (Wix); Retention: Session
  • svSession — Purpose: Identifies unique visitors and tracks a visitor’s session; Type: First-party (Wix); Retention: Up to 2 years
  • bSession — Purpose: System effectiveness measurement; Type: First-party (Wix); Retention: 30 minutes
  • ssr-caching — Purpose: Indicates how the site was rendered; Type: First-party (Wix); Retention: Up to 1 minute
  • TS* — Purpose: Security and anti-fraud; Type: First-party (Wix); Retention: Session
  • server-session-bind / client-session-bind — Purpose: Security; Type: First-party (Wix); Retention: Session

Performance and analytics cookies. These help us understand how visitors use the Website (pages visited, time spent, errors) so that we can improve it. They are used only with your explicit consent under Article 5(1) KVKK. [Please list here any analytics tools in use, e.g. Google Analytics: _ga, _gid — up to 2 years / 24 hours.]

Functionality and marketing cookies. These remember your choices or are used to show you relevant content. They are used only with your explicit consent. [Please list any such cookies if used; otherwise delete this paragraph.]

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1.4 Personal Data Processed and Method of Collection

Through the Website we may process: transaction security data (IP address, browser and device information, log records, cookie identifiers); identity and contact data you submit through contact forms or by e-mail (name, surname, company, title, e-mail address, phone number); and request/complaint data (the content of your message). This data is collected by automated means through cookies and server logs, and partly automated means through forms you complete.

 

1.5 Purposes of Processing

Ensuring the operation and information security of the Website; responding to your enquiries and requests; carrying out communication activities; improving our services and the user experience; fulfilling legal obligations and responding to requests from authorised public institutions.

 

1.6 Transfer of Personal Data

Your personal data may be transferred to our website infrastructure and hosting provider (Wix.com Ltd. and its affiliates), cloud, e-mail and IT service providers, our business partners where necessary for the purposes above, and to authorised public institutions and organisations where required by law. As some of these service providers have servers located outside Türkiye, cross-border transfers are made in accordance with Article 9 KVKK, on the basis of the appropriate safeguards provided for in that article (such as standard contracts notified to the Personal Data Protection Authority) or, where these are not available, your explicit consent.

 

1.7 Managing Cookies

You can accept or refuse non-essential cookies through the cookie banner on the Website and change your preferences at any time. You can also delete or block cookies through your browser settings (e.g. Google Chrome, Mozilla Firefox, Safari, Microsoft Edge, Opera). Please note that blocking strictly necessary cookies may prevent parts of the Website from working properly.

 

1.8 Your Rights

You may exercise your rights under Article 11 KVKK as described in Section 2 below.

 

2. Data Subject Rights and Application Form

 

2.1 Your Rights under Article 11 KVKK

As a data subject, you have the right to:

  • learn whether your personal data is processed;
  • request information if your personal data has been processed;
  • learn the purpose of processing and whether the data is used in line with that purpose;
  • know the third parties, in Türkiye or abroad, to whom your personal data is transferred;
  • request rectification of incomplete or inaccurate data and notification of this to third parties to whom the data was transferred;
  • request erasure or destruction of your personal data where the reasons for processing no longer exist, and notification of this to third parties to whom the data was transferred;
  • object to a result against you arising from the analysis of your data exclusively through automated systems;
  • claim compensation for damages arising from unlawful processing of your personal data.

 

2.2 How to Apply

In accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, you may submit your request in Turkish, in writing, using the form below or a petition containing the same information, by one of the following methods:

  • by hand delivery or registered mail with return receipt to: BİRLİK MAH. 457 SK. CAN APT. NO: 3 İÇ KAPI NO: 5 ÇANKAYA / ANKARA (marked “Personal Data Protection Law Information Request” on the envelope);
  • through a notary public;
  • by e-mail to msg@clymflex.com from the e-mail address you have previously provided to us and that is registered in our systems, with the subject line “Personal Data Protection Law Information Request”.

Your request must include your name and surname, signature (for written applications), Turkish ID number (or nationality and passport/ID number for non-Turkish citizens), residential or business address for notification, e-mail address, telephone number, and the subject of your request. Requests will be concluded free of charge as soon as possible and within thirty (30) days at the latest, depending on the nature of the request. If the process requires an additional cost, the fee set out in the tariff determined by the Personal Data Protection Board may be charged.

 

2.3 Data Subject Application Form

A. Applicant Information

  • Name and surname: ____________________
  • Turkish ID No. / Passport No. and nationality: ____________________
  • Address for notification: ____________________
  • Telephone: ____________________
  • E-mail: ____________________

B. Your Relationship with Clymflex (Client / Prospective client / Job applicant / Supplier / Business partner / Website visitor / Other: ________) — Department or contact person you dealt with, if any: ________

C. Your Request (please tick)

  1. ☐ I would like to learn whether my personal data is processed.
  2. ☐ I request information about the processing of my personal data.
  3. ☐ I would like to learn the purpose of processing and whether it is used in line with that purpose.
  4. ☐ I would like to know the third parties, in Türkiye or abroad, to whom my personal data is transferred.
  5. ☐ I request rectification of my incomplete or inaccurate personal data.
  6. ☐ I request erasure or destruction of my personal data.
  7. ☐ I request that third parties to whom my data was transferred be notified of the rectification, erasure or destruction.
  8. ☐ I object to a result against me arising from analysis exclusively through automated systems.
  9. ☐ I request compensation for damage arising from unlawful processing of my personal data.

Details of your request: ______________________________________

D. Method of Response ☐ To my address ☐ To my e-mail address ☐ I will collect it by hand

E. Declaration I declare that the information above is accurate and complete and that I am submitting this application under Article 11 KVKK. I acknowledge that Clymflex may request additional information to verify my identity and that providing inaccurate information may lead to my request being rejected.

Name and surname: ____________ Date: ____________ Signature: ____________

 

3. Privacy Notice for Clients and Prospective Clients

This notice concerns our clients and prospective clients and, where the client is a legal entity, its shareholders, officers, signatories, employees and contact persons.

  • Identity — Data: Name, surname, title, signature; ID details where required for contracts and invoicing; Purposes: Preparing proposals; executing and performing contracts; invoicing; managing client relations; Legal basis (Art. 5 KVKK): Art. 5(2)(c) contract; 5(2)(ç) legal obligation
  • Contact — Data: E-mail, phone, business address; Purposes: Communication; organising meetings and project delivery; Legal basis (Art. 5 KVKK): Art. 5(2)(c) contract; 5(2)(f) legitimate interest
  • Professional experience — Data: Company, department, position; Purposes: Project management; identifying contact persons; Legal basis (Art. 5 KVKK): Art. 5(2)(c); 5(2)(f)
  • Customer transaction — Data: Proposals, contracts, project records, correspondence, invoice information; Purposes: Delivering consulting, training and advisory services; finance and accounting; Legal basis (Art. 5 KVKK): Art. 5(2)(c); 5(2)(ç)
  • Finance — Data: Bank account and tax details; Purposes: Payment collection; accounting and tax obligations; Legal basis (Art. 5 KVKK): Art. 5(2)(c); 5(2)(ç)
  • Visual records — Data: Photographs/recordings at trainings, events or online meetings; Purposes: Event documentation; promotional activities; Legal basis (Art. 5 KVKK): Explicit consent, Art. 5(1)
  • Marketing — Data: Communication preferences; Purposes: Sending commercial electronic messages and invitations; Legal basis (Art. 5 KVKK): Explicit consent, Art. 5(1), and Law No. 6563

Method of collection: Directly from you or your company, verbally, in writing or electronically, through meetings, e-mail, contracts, the Website and events.

Transfer: To our business partners and subcontractors involved in delivering the service, financial advisors, auditors, legal counsel, banks, cloud and IT service providers, and authorised public institutions where legally required. Cross-border transfers (e.g. for international projects in Qatar, Sweden or other countries, or through service providers with servers abroad) are made in accordance with Article 9 KVKK.

Retention: For the term of the contract and for the statutory limitation and retention periods thereafter (e.g. 10 years under the Turkish Commercial Code and Tax Procedure Law); proposals not converted into contracts for [2] years.

 

4. Privacy Notice for Job and Internship Applicants

  • Identity — Data: Name, surname, date of birth, nationality; Purposes: Evaluating applications; conducting recruitment processes; Legal basis (Art. 5 KVKK): Art. 5(2)(c) – steps prior to entering into a contract; 5(2)(f)
  • Contact — Data: E-mail, phone, address; Purposes: Communicating with the applicant; scheduling interviews; Legal basis (Art. 5 KVKK): Art. 5(2)(c); 5(2)(f)
  • Professional experience — Data: CV, education, certificates, work history, references, language skills; Purposes: Assessing suitability for the position; Legal basis (Art. 5 KVKK): Art. 5(2)(c); 5(2)(f)
  • Interview records — Data: Interview notes and assessment results; Purposes: Selection and decision-making; Legal basis (Art. 5 KVKK): Art. 5(2)(f)

Please do not include special categories of personal data (such as health, religion, ethnicity or biometric data) in your CV unless specifically requested. If such data is shared, it will be processed only under the conditions in Article 6 KVKK.

Method of collection: Through the Website (Careers), e-mail, recruitment platforms, references and interviews.

Transfer: To IT and cloud service providers and, where required, to authorised public institutions. Applications are not shared with third parties for any other purpose.

Retention: Applications are kept for [2] years after the end of the recruitment process to evaluate the applicant for future openings, unless the applicant requests earlier deletion.

 

5. Privacy Notice for Newsletter Subscribers

  • Identity — Data: Name, surname; Purposes: Managing subscriptions; Legal basis: Explicit consent, Art. 5(1) KVKK
  • Contact — Data: E-mail address; Purposes: Sending newsletters, insights, event and training announcements (incl. Clymflex Akademi); Legal basis: Explicit consent, Art. 5(1) KVKK; Law No. 6563 on Electronic Commerce
  • Professional experience — Data: Company, position (if provided); Purposes: Tailoring content; Legal basis: Explicit consent
  • Transaction security — Data: Opening/click data, IP address, subscription and consent logs; Purposes: Proving consent; measuring engagement; Legal basis: Art. 5(2)(ç) legal obligation; 5(2)(f)

You can unsubscribe at any time free of charge via the link in every e-mail or by writing to msg@clymflex.com. Your data is transferred only to e-mail delivery and IT service providers (which may be located abroad, in accordance with Article 9 KVKK) and is retained until you withdraw your consent, and consent records for the period required by law.

 

6. Privacy Notice for Suppliers and Prospective Suppliers

This notice concerns our suppliers, prospective suppliers, independent consultants and trainers, and the officers, employees and contact persons of supplier companies.

  • Identity — Data: Name, surname, title, signature; ID details where required; Purposes: Supplier selection; contract execution; Legal basis (Art. 5 KVKK): Art. 5(2)(c); 5(2)(ç)
  • Contact — Data: E-mail, phone, address; Purposes: Communication and coordination; Legal basis (Art. 5 KVKK): Art. 5(2)(c); 5(2)(f)
  • Professional experience — Data: CV, expertise, references, certificates; Purposes: Assessing qualifications of consultants and trainers; Legal basis (Art. 5 KVKK): Art. 5(2)(c); 5(2)(f)
  • Finance — Data: Bank account, tax number, invoice details; Purposes: Payments; accounting and tax obligations; Legal basis (Art. 5 KVKK): Art. 5(2)(c); 5(2)(ç)
  • Legal transaction — Data: Contracts, correspondence, NDAs; Purposes: Managing legal relationships and disputes; Legal basis (Art. 5 KVKK): Art. 5(2)(c); 5(2)(e) establishment, exercise or protection of a right

Method of collection: From you or your company through proposals, contracts, e-mail, meetings and documents submitted. Transfer: To financial advisors, auditors, legal counsel, banks, IT service providers, clients (where the supplier is part of the project team) and authorised public institutions. Retention: For the contract term and statutory retention periods thereafter.

 

7. Privacy Notice for Communication via E-mail and Contact Channels

When you contact us via msg@clymflex.com, the Website contact form, telephone or social media, we process your identity data (name, surname), contact data (e-mail, phone), professional data (company, title) and the content of your message, in order to respond to your enquiry, direct it to the relevant team, manage our communication activities and keep records of correspondence. This processing is based on Article 5(2)(c) (where your enquiry relates to a contract), Article 5(2)(f) (our legitimate interest in responding to communications) and Article 5(2)(e) KVKK. Your data may be transferred to our e-mail, cloud and IT service providers (including providers located abroad, in accordance with Article 9 KVKK) and to authorised public institutions where legally required, and is retained for [2] years from the last communication unless a longer period is required by law or a business relationship begins.

 

Updates

Clymflex may update this page to reflect changes in legislation or in its processing activities. The current version is always published on this page.

Last updated: 25.10.2026

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