Cookie & Privacy Notice

1. Data Controller

The data controller responsible for the processing of personal data through analyticaestates.com (the “Website”) is:

Analytica Danışmanlık Hizmetleri Limited Şirketi

E-mail: info@analyticaestates.com

For questions regarding this Privacy and Cookie Notice or to exercise your data protection rights, you may contact us using the details above.

2. Scope of This Notice

This Notice explains how we use cookies and similar technologies on the Website and how we process personal data collected through those technologies.

The Website uses strictly necessary cookies to ensure that the Website functions properly and to remember your cookie preferences.

We may also use Google Analytics 4 (“GA4”) for website analytics. GA4 analytics cookies are activated only after you provide your explicit consent through our cookie consent mechanism.

3. Categories of Data We Process

Depending on your cookie preferences and your use of the Website, we may process the following categories of data:

• Cookie identifiers and similar technical identifiers;
• Cookie consent and preference information;
• Information about pages viewed and interactions with the Website;
• Referring website or source;
• Device and browser information;
• Date and time of visits;
• Approximate geographical location, such as country or city, where provided or derived by the analytics service;
• Technical information required for the secure and proper operation of the Website.

We do not intentionally use GA4 to collect directly identifying information such as your name, postal address, telephone number, or e-mail address. You should not provide such information to Google Analytics through URLs, page titles, events, or other analytics parameters.

4. Strictly Necessary Cookies

Strictly necessary cookies are used where they are required for the secure and proper operation of the Website or for storing your cookie preferences.

These cookies may be used without consent where permitted by applicable law, including on the basis of the legitimate interests of the data controller under Article 5/2(f) of the Turkish Personal Data Protection Law No. 6698 (“KVKK”), where applicable. These cookies do not require consent where they are strictly necessary for the service or functionality requested by the user.

5. Analytics Cookies – Google Analytics 4

We use Google Analytics 4 (“GA4”) to understand how visitors use the Website and to improve its performance, functionality, content, and user experience.

GA4 may process information such as pages visited, interactions with the Website, referring sources, device and browser information, approximate geographical information, and technical identifiers associated with analytics cookies.

Analytics cookies are not activated before you provide explicit consent. The legal basis for processing analytics data based on consent is, where applicable:

• KVKK Article 5/1, based on your explicit consent; and
• GDPR Article 6(1)(a), where the GDPR applies.

You can refuse analytics cookies without affecting your ability to use the Website. We do not use GA4 data for advertising profiling through this Website, and we do not sell personal data collected through our analytics activities.

6. Cookie Consent and Preference Management

When you first visit the Website, you will be presented with a cookie consent mechanism. You may:

• Accept analytics cookies;
• Reject analytics cookies; or
• Manage your cookie preferences through the “Cookie Settings” option.

Analytics cookies will not be activated unless you provide the relevant consent. You may withdraw or change your consent at any time by selecting “Cookie Settings” through the link available in the Website footer, or by using the reset button below to clear your choice:

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

7. Purposes of Processing

Personal data collected through cookies and similar technologies may be processed for the following purposes:

• Ensuring the secure and proper operation of the Website;
• Remembering and managing cookie preferences;
• Measuring Website traffic and usage;
• Understanding how visitors interact with the Website;
• Identifying technical or performance issues;
• Improving Website content, functionality, and user experience; and
• Generating aggregated statistical insights.

We do not use analytics information collected through this Website for advertising profiling unless this Notice and our consent mechanism are separately updated to reflect such processing.

8. Legal Bases

Depending on the category of cookie and applicable law, we rely on the following legal bases:

• Strictly necessary cookies: Legitimate interest under KVKK Article 5/2(f), where applicable, or another applicable legal basis where required.
• Analytics cookies: Your explicit consent under KVKK Article 5/1 and, where applicable, consent under GDPR Article 6(1)(a).

Where consent is the applicable legal basis, you may withdraw it at any time.

9. Third-Party Service Providers

We use Google Analytics 4, a service provided by Google, for website analytics. Analytics information may therefore be processed by Google in accordance with Google's applicable terms and privacy documentation.

We configure GA4 to limit the collection and use of personal data and do not intentionally send directly identifying information such as names or e-mail addresses to Google Analytics.

10. International Transfers

Certain personal data processed through third-party analytics services may be transferred to and processed in countries outside Türkiye and/or the European Economic Area (“EEA”).

Where such transfers constitute an international transfer of personal data under applicable law, we will rely on an appropriate legal mechanism permitted by the applicable data protection legislation.

For transfers subject to the KVKK, we will comply with the applicable requirements for international transfers of personal data, including the requirements applicable to transfers based on the data subject's explicit consent, where relied upon.

Where the GDPR applies, we will use an appropriate transfer mechanism under Chapter V of the GDPR, such as an adequacy decision or Standard Contractual Clauses (“SCCs”), where applicable.

You may contact us using the information in Section 1 if you would like further information regarding the applicable transfer mechanism.

11. Data Retention

Analytics data and cookies are retained according to the relevant GA4 configuration and cookie settings.

The current retention period configured for GA4 analytics data is 2 months for event-level data and 14 months for user-level data, unless a different retention period is required by applicable law or configured for a particular analytics feature.

When the applicable retention period expires, the relevant data is deleted or otherwise handled in accordance with applicable law and the relevant service configuration.

12. Data Security

We take reasonable technical and organizational measures designed to protect personal data against unauthorized access, accidental loss, destruction, alteration, disclosure, or other unlawful processing.

Access to personal data is limited to persons and service providers who require such access for legitimate business or technical purposes.

13. Your Rights under the KVKK

Subject to the conditions and limitations provided by applicable law, under Article 11 of the KVKK, you may have the right to:

• Learn whether your personal data is being processed;
• Request information about the processing;
• Learn the purpose of processing and whether the data is used in accordance with that purpose;
• Know the third parties to whom your personal data is transferred domestically or abroad;
• Request correction of incomplete or inaccurate personal data;
• Request deletion or destruction of personal data where the legal conditions are met;
• Request notification of correction, deletion, or destruction to relevant third parties where applicable;
• Object to a result arising against you through analysis of your processed data exclusively by automated systems, where applicable; and
• Claim compensation for damages arising from unlawful processing of your personal data, where the applicable legal conditions are met.

14. Your Rights under the GDPR

Where the GDPR applies, you may, subject to the conditions and limitations of the GDPR, have the right to:

• Access your personal data;
• Request rectification of inaccurate personal data;
• Request erasure of personal data;
• Request restriction of processing;
• Object to certain processing activities;
• Request data portability where applicable;
• Withdraw consent at any time where processing is based on consent; and
• Lodge a complaint with a competent data protection supervisory authority.

The withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

15. Exercising Your Rights

To exercise your rights or request information about the processing of your personal data, please contact us at:

E-mail: info@analyticaestates.com

We may need to take reasonable steps to verify your identity before responding to a request, where permitted or required by applicable law. We will respond to requests within the period required by the applicable legislation. For requests under the KVKK, the applicable application procedure and requirements will be followed.

16. Changes to This Notice

We may update this Cookie & Privacy Notice from time to time to reflect changes in our Website, technologies, services, legal requirements, or data processing practices.

The “Last Updated” date at the top of this Notice indicates when the Notice was most recently revised. Where required by applicable law, we will obtain new consent before introducing new categories of non-essential cookies or processing activities that require consent.

17. Contact

If you have questions about this Notice, our use of cookies, or the processing of your personal data, please contact:

Analytica Danışmanlık Hizmetleri Limited Şirketi

E-mail: info@analyticaestates.com