This policy explains how Uluten Group and its group companies (“Uluten Group”, “we”, “us”) collect, use, disclose and protect personal data, and the rights available to you under applicable law — including the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and, where relevant, the EU General Data Protection Regulation (“GDPR”).
1. Who we are
Uluten Group is a technology group headquartered in Ankara, Türkiye, operating companies across finance, cybersecurity, agriculture, insurance and real estate. For personal data processed through this website, Uluten Group is the data controller. Where a group company processes personal data on behalf of a client, that client is the controller and the group company acts as a processor under a separate written agreement.
2. Data we collect
- Information you provide — your name, organization, email address and the contents of any message you send us.
- Technical data — IP address, browser and device type, and approximate location, collected to operate and secure the site.
- Correspondence — records of communications between you and us.
3. How we use data
- To respond to your enquiries and manage our relationship with you.
- To operate, secure, maintain and improve this website.
- To comply with our legal, regulatory and contractual obligations.
- To protect our users, systems and rights against fraud, abuse and security threats.
4. Legal bases
We process personal data on the bases of your consent, the performance of a contract, our legitimate interests in running a secure and effective organization, and compliance with legal obligations — as applicable under the KVKK, the GDPR and other applicable laws.
5. Sharing and disclosure
We do not sell personal data. We share it only with service providers acting on our instructions under confidentiality obligations, with group companies where necessary for the purposes above, and with authorities where required by law or to protect our rights. Every recipient is held to a standard of protection no lower than our own.
6. International transfers
Where personal data is transferred outside your country, we rely on adequacy decisions, standard contractual clauses, your explicit consent, or the other safeguards required under the KVKK and GDPR. For sovereign and isolated deployments, client data can remain entirely within the client’s own environment and jurisdiction.
7. Retention
We keep personal data only as long as necessary for the purpose it was collected, to meet legal and regulatory requirements, and to establish or defend legal claims. When it is no longer needed, it is securely deleted or anonymized.
8. Security
We apply technical and organizational measures appropriate to the risk — including access control, encryption, audit logging and the zero-trust principles described in our Security statement — to protect personal data against loss, misuse, alteration and unauthorized access.
9. Your rights
Subject to applicable law, you have the right to access your personal data, to have it corrected or deleted, to restrict or object to its processing, to data portability, to withdraw consent, and to lodge a complaint with a supervisory authority. Under Article 11 of the KVKK, you may exercise the rights set out there. To exercise any right, contact us using the details below.
11. Children
This site and our services are not directed at children, and we do not knowingly collect personal data relating to them.
12. Changes
We may update this policy from time to time. Material changes will be reflected in the “last updated” date above and, where required by law, notified to you directly.
Privacy requests and questions: privacy@ulutengroup.com