1. Overview
At Demircode Yazılım ve Teknoloji ("Demircode", "we"), we place great importance on protecting your personal data. This Privacy Policy explains how your personal data is collected, processed, and protected when you visit our website (demircode.com) and use our services.
This policy has been prepared in accordance with the Turkish Personal Data Protection Law (KVKK No. 6698) and the European Union General Data Protection Regulation (GDPR).
Details on cookies can be found in our Cookie Policy, and the information required under KVKK in our Personal Data Protection Notice (KVKK).
2. Personal Data Collected
We may collect the following personal data to provide our services:
- Identity Information: Name, surname, title
- Contact Information: Email address, phone number, address, website address (optional)
- Company Information: Company name, tax ID, tax office
- Technical Data: IP address, browser information (user agent), operating system, pages visited, date and time of visit
- Form Submissions: Messages and information you submit through contact, quote or order forms, including the products and modules you select in a quote request
- Security Data: The spam risk score generated by Google reCAPTCHA v3 when a form is submitted
- Cookie Data: Only with your consent: data collected through analytics and advertising cookies and, if you arrive through an advertising campaign, the campaign information (utm_source, utm_medium, utm_campaign) and Google click ID (gclid) kept in the session storage of your browser during your visit. UTM campaign information is not saved in our database and is not sent with forms or by email (see our Cookie Policy)
- Advertising source and WhatsApp reference data: If you arrive from a Google ad, regardless of your cookie choices, the ad click ID (gclid, gbraid or wbraid), the time the click reached our website and the first page opened are saved with your request when you submit the quote form. When you click the WhatsApp button, the reference code added to your message, the page you clicked on and the time of the click are saved (together with the ad click ID if you came from an ad). To measure the effectiveness of our ads, only the click ID and the time of the request are reported to Google Ads (see our KVKK Privacy Notice)
3. Purposes of Data Processing
Your personal data is processed for the following purposes:
- Providing and improving our services
- Evaluating and responding to your quote, contact and order requests
- Preparing and sending offers and following up on the offer process (including reminder emails about your offer)
- Establishing and performing contracts
- Providing customer support
- Fulfilling our legal obligations
- Ensuring the security of our website and preventing spam and automated (bot) form submissions
- Measuring the effectiveness of our advertising spend: linking your quote request or WhatsApp message to the Google ad click you came from
- With your explicit consent, conducting statistical analyses and measuring the results of our advertising campaigns (Google Analytics data is pseudonymous, not anonymous)
Under Art. 5(2) KVKK, we process this data on the grounds that processing is necessary for the establishment or performance of a contract (c), for compliance with our legal obligations (ç), and for our legitimate interests, provided that your fundamental rights and freedoms are not harmed (f), such as website security, spam prevention, following up on your requests and measuring the effectiveness of our advertising. Analytics and advertising cookies are used only with your explicit consent (Art. 5(1) KVKK). Under the GDPR, the corresponding legal bases are Art. 6(1)(b), (c) and (f), and Art. 6(1)(a) for consent.
4. Data Sharing
Your personal data will not be shared with third parties except in the following cases:
- Legal obligations: Court orders or legal requests from competent public authorities
- Our hosting provider: Our website and database are hosted in a data centre in Germany (Contabo GmbH); the data you submit through our forms is stored on these servers
- Google (Google LLC / Google Ireland Limited): Our business email service (Google Workspace), through which form notification emails are delivered; spam protection on forms (reCAPTCHA v3); cookie-based analytics and advertising measurement only with your consent (Google Analytics 4, Google Ads); cookieless measurement signals of Google Consent Mode even without your consent (including the ad click ID if you came from an ad); for measuring advertising effectiveness, only the ad click ID and the time of the request (Google Ads); the map on our contact page (Google Maps); product videos only when you click play (YouTube)
- Explicit consent: Other cases in which you have given your explicit consent
Only the minimum data necessary for service delivery is shared with our service providers.
Transfers abroad: Because our website and database are hosted on servers in Germany (Contabo GmbH), personal data processed through our website, including the data you submit through our forms, is stored outside Türkiye. In addition, data processed through Google services (including form notification emails) may be processed on servers outside Türkiye. Both constitute transfers abroad within the meaning of Art. 9 KVKK. Such transfers are carried out on the basis of the appropriate safeguards provided for by law (e.g. standard contractual clauses) or, for cookie-based analytics and advertising services, on the basis of your explicit consent.
Under the GDPR, hosting in Germany, an EU member state, does not involve a transfer to a third country; transfers to third countries within the meaning of the GDPR may only arise in connection with Google services.
5. Data Security
We implement industry-standard security measures to protect your personal data:
- Secure data transmission with SSL/TLS encryption
- Firewalls and access controls
- Regular security updates and audits
- Database encryption
6. Your Rights
Under Art. 11 KVKK, you have the right to:
- Learn whether your personal data is being processed
- Request information about the processing if your personal data has been processed
- Learn the purpose of the processing and whether your data is used in line with that purpose
- Know the third parties in Türkiye or abroad to whom your personal data has been transferred
- Request the rectification of your personal data if it is incomplete or inaccurate
- Request the erasure or destruction of your personal data under the conditions set out in Art. 7 KVKK
- Request that any rectification, erasure or destruction be notified to the third parties to whom your personal data has been transferred
- Object to a result to your detriment arising from the analysis of your data exclusively by automated systems
- Claim compensation for damage suffered as a result of the unlawful processing of your personal data
If you are located in the European Union or the European Economic Area, you also have the rights of access, rectification, erasure, restriction of processing, data portability and objection under the GDPR, as well as the right to withdraw your consent at any time and to lodge a complaint with a data protection supervisory authority.
To exercise these rights, you can send a written application to our address or email us at info@demircode.com; the application procedure is described in our Personal Data Protection Notice (KVKK). Your application will be concluded free of charge within 30 days at the latest; if the process involves an additional cost, a fee may be charged according to the tariff set by the Turkish Personal Data Protection Board.
7. Third-Party Services
The following third-party services are used on our website:
- Google Tag Manager: For tag management; runs analytics and advertising tags according to your cookie choices
- Google Analytics 4: To analyze website traffic — only with your consent; the data is pseudonymous, not anonymous
- Google Ads: To measure conversions from our advertising campaigns — only with your consent; in addition, only the ad click ID and the time of the request, to measure requests that come from our ads
- Google reCAPTCHA v3: To protect forms against spam and bot submissions — on pages with forms
- Google Workspace: Our business email service, used for form notifications and our correspondence
- Google Maps: To show our location on the contact page; Google may process your IP address in order to display the map
- YouTube: For product videos — loaded only when you click play, via the privacy-enhanced mode (youtube-nocookie.com)
Analytics and advertising cookies are not set unless you give your consent. Under Google Consent Mode (v2), which we use on our website, Google tags may send cookieless signals (e.g. that a page was viewed) even before consent; if you came from a Google ad, these signals also contain the ad click ID, which allows Google Ads to match a conversion to the ad click. Google also uses these signals for aggregated modelling. Details can be found in our Cookie Policy.
These services have their own privacy policies and are subject to their own cookie policies.
8. Data Retention Period
Your personal data is retained for as long as necessary for the purpose of collection or as required by our legal obligations:
- Contact and quote form data: Up to 2 years after our last interaction, unless a contract follows
- Contract, invoice and accounting records: For the statutory retention periods (10 years under the Turkish Commercial Code)
- Cookie consent records: 2 years
- Advertising source information: If saved with a quote request, for as long as that request is kept; WhatsApp reference records for 1 year
- Server security logs: For the short period required for security purposes
When the retention period expires, the data is erased, destroyed or anonymised.
9. Privacy of Children
Our services are not intended for individuals under the age of 18. We do not knowingly collect personal data from individuals under 18.
10. Policy Updates
This privacy policy may be updated from time to time. Changes will be published on this page and you will be notified of significant changes.
Last updated: October 19, 2026
11. Contact
For questions about our privacy policy, you can contact us:
- Data Controller: Demircode Yazılım ve Teknoloji
- Email: info@demircode.com
- Phone: +90 543 326 47 77
- Address: Fatih Sultan Mehmet Mah. Balkan Cad. No: 62 A, 34771 Ümraniye/İstanbul, Türkiye