Privacy and Personal Data Protection Policy

Last updated: 2 November 2026

This Privacy and Personal Data Protection Policy (“Privacy Policy”) has been prepared to explain the purposes for which personal data obtained through the website www.fixer.com.tr (“Website”) operated by FIXER Yazılım ve Danışmanlık Sanayi Ticaret Limited Şirketi (“FIXER”) are processed, how they are protected, and the rights of data subjects.

This text provides general information. Details on the contact form and commercial electronic communications are set out in the Contact Form Information Notice and the Commercial Electronic Communication Information Notice, and details on cookies are set out in the Cookie Policy.

1. Data Controller

Pursuant to the Turkish Personal Data Protection Law No. 6698 (“KVKK”), the data controller is:

FIXER Yazılım ve Danışmanlık Sanayi Ticaret Limited Şirketi
Zümrütevler Mah. Mevlana Halid Cad.
Nish Adalar Sitesi 12. Block D:15
34852 Maltepe / Istanbul / Türkiye
Email: info@fixer.com.tr

2. Personal Data Processed

Depending on the service you use, the following personal data may be processed through the Website:

  • Contact form: Name and surname, email address, company name, message content, commercial communication preference, language, IP address and submission date

  • Pre-analysis form: Name and surname, email address, company name, website address, current Umbraco version, any note you add, language, IP address and submission date

  • Newsletter subscription: Name and surname, email address, commercial communication preference, language, IP address and registration date

  • Direct communication: Your contact details and the content of the call or correspondence if you reach us by email or phone

  • Security verification and server records: IP address, browser and device information, and log records

  • Cookies: Your cookie choice, consent records and, if you give explicit consent, analytics data on your use of the Website

3. Method of Collection, Purposes and Legal Grounds

Your personal data are collected through forms on the Website, email and phone communications, server records, and cookies and similar technologies, by wholly or partly automated means, and are processed for the following purposes:

  • Receiving and responding to contact requests, managing quotation and business development processes: For the contact form, we rely on your explicit consent under Article 5/1 of the KVKK and on processing being necessary to establish, exercise or protect a right under Article 5/2-e.

  • Evaluating pre-analysis requests and conducting pre-contractual discussions: We rely on processing being directly related to the establishment of a contract under Article 5/2-c of the KVKK and being necessary for our legitimate interests under Article 5/2-f.

  • Sending the newsletter and commercial electronic communications: We rely on your explicit consent under Article 5/1 of the KVKK and Law No. 6563 on the Regulation of Electronic Commerce.

  • Ensuring information security, preventing abuse and operating the Website: We rely on processing being necessary for our legitimate interests under Article 5/2-f of the KVKK.

  • Fulfilling legal obligations: We rely on Article 5/2-ç of the KVKK.

  • Analyzing use of the Website: This takes place only if you give your explicit consent under Article 5/1 of the KVKK.

You may withdraw your consent at any time for processing based on explicit consent. Withdrawal does not affect the lawfulness of processing carried out before it.

4. Cookies and Analytics Tools

The Website uses strictly necessary cookies and, subject to your explicit consent, Google Analytics 4 analytics cookies. The Website does not use advertising or marketing cookies. The cookie list, retention periods and how to manage your preferences are set out in the Cookie Policy.

5. Transfer of Personal Data

Your personal data may be transferred to the following groups of recipients, limited to the purposes above and within the scope of Articles 8 and 9 of the KVKK:

  • Infrastructure and technical service providers: Google Workspace for email and business applications, Cloudflare for security and content delivery, and Hetzner for hosting

  • Analytics service provider: Google under Google Analytics 4, if you give your explicit consent

  • Authorized public institutions and judicial authorities: To the extent legally required

As these providers’ servers may be located abroad, your personal data may be transferred outside Türkiye. Article 9 of the KVKK applies to transfers abroad.

6. Retention Period of Personal Data

Personal data are retained for the periods stipulated in the relevant legislation and only as long as required by the purpose of processing. In determining this period, we take into account the conclusion of your request, the continuation of any business relationship, withdrawal of explicit consent and limitation periods for potential disputes. Upon expiry, personal data are deleted, destroyed or anonymized in accordance with the legislation. Retention periods for cookie choices and consent records are set out in the Cookie Policy.

7. Protection of Personal Data

FIXER implements administrative and technical measures to ensure the security of personal data and to prevent unauthorized access, loss or unlawful processing.

8. Rights of the Data Subject

Pursuant to Article 11 of the KVKK, data subjects have the right to:

  • Learn whether their personal data are processed

  • Request information if personal data have been processed

  • Learn the purpose of processing and whether data are used in accordance with that purpose

  • Know the third parties to whom personal data are transferred in Türkiye or abroad

  • Request correction of incomplete or inaccurate personal data

  • Request deletion or destruction of personal data under the conditions set out in the KVKK

  • Request that correction, deletion or destruction be notified to the third parties to whom the data were transferred

  • Object to a result against them arising from analysis of the data exclusively through automated systems

  • Claim compensation for damage suffered due to unlawful processing

9. Application Method

You may submit your requests under the KVKK in writing to our address above or by email to info@fixer.com.tr, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. Requests are concluded as soon as possible depending on their nature and within thirty days at the latest. You may also withdraw your permission for commercial electronic communications at any time by sending a request to the same email address.

10. Policy Updates

FIXER may update this Privacy Policy in line with changes in legislation and business processes. Updates take effect on the date they are published on the Website.