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Version: EN-1.0 · Effective date: [PUBLICATION DATE]

StructFlow Early-Access List: Privacy Notice

This notice explains how we process the personal data you give us through the early-access form on the StructFlow website at structflow.com.tr. It is written to meet Article 10 of Türkiye's Personal Data Protection Law No. 6698 ("KVKK") and, where it applies to you, Article 13 of the EU General Data Protection Regulation ("GDPR"). This notice is not a consent form. We ask for your consent to receive emails separately, through the checkbox in the form.

1. Who we are (data controller)

[COMPANY NAME] ("StructFlow", "we") · Trade registry (MERSİS) no.: [MERSİS NO] · Address: [ADDRESS], Türkiye · Email: [CONTACT EMAIL] · EU representative (Art. 27 GDPR): [NAME AND CONTACT, if appointed]

2. What we collect

  • Identity and contact details: your full name and email address and, if you choose to give them, your office or company name and your role.
  • Consent records: when you submitted the form and when you confirmed your email; the version of the consent text and of this notice you were shown; your language; the page the form was on; whether your consent has been registered with Türkiye's Commercial Message Management System (İYS); and, if you withdraw, when and how.
  • Security data: the time of your submission and a keyed, one-way hash (HMAC) of your IP address used to prevent abuse. We do not store your raw IP address or your browser or device details.

We do not ask for special-category data. Please don't enter any in the office name field.

3. Why we use your data and on what legal basis

a) To send you early-access invitations, beta updates and StructFlow product announcements by email, and to plan invitations. Legal basis: your consent (KVKK Art. 5(1) and consent to commercial electronic messages under Turkish Law No. 6563, Art. 6; GDPR Art. 6(1)(a)).

b) To send you a confirmation link that proves the address is yours, and the confirmation of consent Turkish law requires within 24 hours. Legal basis: legal obligation (KVKK Art. 5(2)(ç); Turkish Regulation on Commercial Communication and Commercial Electronic Messages, Art. 7(3)) and our legitimate interest in stopping people from signing up others (KVKK Art. 5(2)(f); GDPR Art. 6(1)(f)).

c) To keep records of consent and withdrawal, register them with İYS, and prove consent if needed. Legal basis: legal obligation under Turkish law (KVKK Art. 5(2)(ç)), establishing and defending legal claims (KVKK Art. 5(2)(e)) and, under GDPR, our legitimate interest in demonstrating consent and complying with Turkish law (Art. 6(1)(f); see also Art. 7(1)).

d) To prevent abuse of the form (spam, bots, mass sign-ups of other people's addresses) and keep the site secure. Legal basis: legitimate interests (KVKK Art. 5(2)(f); GDPR Art. 6(1)(f)).

e) To answer requests you send us about your data. Legal basis: legal obligation (KVKK Art. 5(2)(ç); GDPR Art. 6(1)(c)).

We do not profile you, make automated decisions about you, sell your data, or share it with others for their marketing. If we ever want to use your data for a new purpose, we will tell you first and ask for fresh consent where required. Giving us your name and email is voluntary; without them we cannot add you to the list.

4. How we collect it

Directly from you, electronically and partly by automated means: through the web form, the confirmation link and the unsubscribe link.

5. Who receives your data

  • Our service providers (processors), which act only on our instructions: website hosting [HOSTING PROVIDER; COUNTRY]; database [DATABASE PROVIDER; REGION]; email delivery [EMAIL PROVIDER; COUNTRY].
  • İleti Yönetim Sistemi A.Ş. (İYS), Türkiye, where Turkish law requires consents and withdrawals to be registered.
  • Competent authorities (e.g. the Turkish Ministry of Trade, the Turkish Data Protection Authority, courts), only when legally required.

International transfers: we are based in Türkiye, so if you are in the EU/EEA or UK, your data comes directly to us in Türkiye. Some of our processors, or their servers, are located in [COUNTRIES]. For transfers out of Türkiye we use the standard contracts published by the Turkish Data Protection Board (KVKK Art. 9). For data covered by GDPR we rely on the European Commission's Standard Contractual Clauses and, where the provider is certified, the EU-U.S. Data Privacy Framework. You can ask us for a copy of the relevant safeguards.

6. How long we keep it

  • Unconfirmed sign-ups: deleted completely if you don't click the confirmation link within 7 days.
  • Active subscribers: kept while your consent is valid. If we stop using the list, we delete it within [12] months.
  • After you withdraw: we stop emailing you immediately, and in any case within 3 business days, and we delete your office name and role. We keep a minimal consent record (name, email, timestamps, text version, source) for [3 (three)] years from the end of your consent, as Turkish commercial-messaging law requires, and then delete or anonymise it.
  • Security data: IP hashes and abuse counters are kept for up to 30 days. Our hosting provider's technical access logs are kept for its standard period ([PERIOD]).

7. Your rights

Depending on the law that applies to you, you can: access your data and get a copy; have inaccurate data corrected; have your data erased; restrict processing; receive your data in a portable format; object to processing based on legitimate interests; withdraw your consent at any time without affecting earlier processing; learn who we have shared your data with, including recipients abroad (KVKK Art. 11); object to decisions based solely on automated processing; and claim compensation for unlawful processing.

8. How to use your rights or unsubscribe

  • To stop receiving emails, click "Unsubscribe" in any of our emails or reply with "unsubscribe". If you have a Turkish phone or e-Devlet account, you can also use İYS (iys.org.tr). Unsubscribing is free.
  • For any other request, write to [CONTACT EMAIL] from the address you signed up with, or by post to [ADDRESS]. We reply within 30 days, free of charge, and may ask you to prove your identity.
  • You can complain to the Turkish Data Protection Board (Kişisel Verileri Koruma Kurulu, www.kvkk.gov.tr). If you are in the EU/EEA, you can complain to your local data protection authority; in the UK, that is the ICO.

9. Cookies and tracking

We use no cookies and store nothing persistent in your browser. There are no advertising, analytics or profiling trackers. Fonts are served from our own domain, so opening the page sends no request to Google or other third parties. Our emails contain no open or click tracking pixels.

10. Changes

When we update this notice, we publish the new version here with a new version number and effective date. If a change materially affects how we use your data, we will also tell you by email. Previous versions: [VERSION HISTORY LINK]

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