Privacy Policy and KVKK Transparency/Disclosure (KVKK Compliant)

Effective Date: 01.01.2025

1. Data Controller

This Privacy Policy applies to the collection and processing of personal data by:
Vira Services Bilgi Teknolojileri Danışmanlık ve Eğitim Ltd. Şti.
Head Office: Marmara Mah. Nil Cad. No:3/10 İstanbul
Email: info@viraservices.com
Website: https://viraservices.com

Pursuant to Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”), Vira Services acts as the data controller, meaning we determine the purposes and means of processing your personal data.

2. Legal Grounds for Processing Personal Data

We process your personal data in accordance with Article 5 and Article 6 of KVKK based on the following legal conditions and grounds:

  • Explicit Consent: Your explicit consent, where mandated by law or necessary for processing.
  • Legal Compliance: Being clearly provided for by law (e.g., fulfilling obligations under tax laws).
  • Performance of Contract: Being necessary for the establishment or performance of a contract (e.g., providing the consulting service you purchased).
  • Legal Obligation: Being mandatory for the data controller to fulfill its legal obligation (e.g., responding to judicial requests).
  • Legitimate Interest: Being mandatory for the legitimate interests of the data controller, provided that it does not violate the fundamental rights and freedoms of the data subject.
  • Exercise or Defense of Rights: Being mandatory for the establishment, exercise, or defense of a right (e.g., processing data for a legal dispute).

3. Categories of Personal Data Processed

We may collect and process the following categories of data:

Data Category Description
Identity Data Full name, ID number (if required), title
Contact Data Email, phone number, address
Transaction Data Training or consulting session records, user interactions
Website Usage Data IP address, browser type, session logs, cookies
Media Uploads Images, documents uploaded by users
Communication Data Emails, comments, contact form messages
Technical Data Cookies, user agent string, device type

4. Purposes of Data Processing

We collect your personal data for the following purposes:

  • Providing IT consulting and training services and managing customer relations.
  • Registering and managing user accounts and fulfilling contractual obligations.
  • Delivering newsletters or educational content (based on consent or legitimate interest).
  • Improving website functionality and user experience through analysis.
  • Ensuring information and transaction security (e.g., combating fraud).
  • Performing statistical and analytical operations for business development.
  • Complying with legal obligations, including regulatory and financial reporting requirements.

5. Transfer of Personal Data

Your personal data may be shared with the following entities where legally necessary or for service provision:

  • Third-Party IT Service Providers (e.g., hosting, cloud services, analytics providers).

  • Legal or Regulatory Authorities upon lawful request (e.g., courts, public institutions).

  • Business Partners or Subcontractors engaged in service delivery (e.g., specific consulting experts).

  • Auditors, Consultants, and Legal Advisors for professional service and legal defense purposes.

Cross-Border Transfer of Data

We do not transfer your data abroad without fulfilling the requirements of KVKK Article 9.

If cross-border transfer is required for service provision, it will only be done under the following conditions:

  1. We obtain your explicit consent for the transfer; OR
  2. The transfer is to a country deemed to have Adequate Protection by the Personal Data Protection Board (KVK Kurulu); OR
  3. We ensure Adequate Protection through a commitment letter approved by the KVK Board, in cases where the country does not offer Adequate Protection.

6. Data Retention Period

Your personal data will be stored for only as long as necessary for the purposes stated in this policy or as required by applicable law. Retention durations include:

Data Type Retention Period
Contact Forms 3 years
Training/Consulting Records 10 years (as per Tax & Commercial Law)
Cookies Up to 1 year
User Comments Indefinite (unless deletion is requested)
Legal Claims or Disputes Until resolution or expiry of statutory periods

7. Your Rights Under KVKK

According to Article 11 of the KVKK, you have the right to request from the data controller:

  • To learn whether your personal data is being processed;
  • To request information regarding such processing;
  • To learn the purpose of processing and whether data is used in line with that purpose;
  • To know the third parties to whom your personal data has been transferred domestically or abroad;
  • To request the correction of incomplete or inaccurate data;
  • To request the deletion or destruction of your personal data (where applicable);
  • To request the notification of correction/deletion to third parties to whom the data has been transferred;
  • To object to the emergence of a result against you due to the analysis of processed data exclusively through automated systems;
  • To request compensation for damages suffered due to unlawful processing.

You may submit your request by sending an email to info@viraservices.com with a subject line like “KVKK Personal Data Request”.

8. Data Security Measures

We implement appropriate technical and organizational measures to ensure the security of your personal data, including:

  • Data encryption (in transit and/or at rest).

  • Firewalls and secure servers to restrict unauthorized access.

  • Role-based access controls (Least Privilege Principle).

  • Periodic security audits and employee training on KVKK compliance.

9. Cookie Policy

Our website uses cookies for functional, analytical, and user experience purposes. You can manage cookie preferences via your browser settings.

For more details, refer to our Cookie Policy [Link to be updated soon].

10. Updates to This Policy

We may update this policy from time to time in line with regulatory changes or operational needs. The most recent version will always be available on our website.