The Turkish version of this text is the legally binding version.
1. Data controller
Bella Binary Yazılım (MERSİS: 0163111961900001, Tax ID: 1631119619) — İvedikosb Mah. 2224 Cad. No: 1 İç Kapı No: 116, Yenimahalle / Ankara (Teknopark Ankara). Email: info@bellabinary.com · Phone: +90 541 871 53 11.
2. Which personal data we process
- Contact form: name, email address and your message (required); company, phone, topic and preferred meeting time (optional).
- Added automatically when the form is sent: IP address, browser information, time of submission, page language and the page the form was sent from; the campaign data (UTM) of your first visit and the referring site; the first 20 pages you visited in the same session and the total page count.
- Visit statistics: on each page view, the page address, page language, browser language and referring address. The IP address is not stored; to count unique visitors, a one-way digest is produced from the IP and browser data with a key that changes every day, and it cannot be traced back to a person.
- Server access logs: the IP address, requested address, browser information and time kept by the web server.
- Information you send when you write to us directly by email, phone or WhatsApp.
- ChatGPT ad measurement (only if you arrive from our ChatGPT ad and choose "Accept" in the consent box): the identifier that OpenAI's measurement code creates in your browser, the address of the page you visit, the ad click reference (oppref), timestamps, and a "lead created" signal when you send the contact form. OpenAI's automatic matching feature may add contact details you type into the form, such as your e-mail address and phone number, to this signal after irreversibly hashing them in your browser. The content of your message is not sent to OpenAI.
The site has no membership, orders, newsletter or payments. The site sets no cookies of its own; OpenAI's measurement code runs only under the condition above (see the Cookie Policy).
3. Purposes and legal bases
- Answering your request, arranging a meeting and running the proposal process — KVKK Art. 5/2-c (directly related to entering into a contract) and Art. 5/2-f (legitimate interest).
- Understanding which channel the request came from and which topics interest you (UTM, referring site, pages visited); following up the sales process — Art. 5/2-f (legitimate interest).
- Keeping site visit statistics — as an anonymous digest; Art. 5/2-f (legitimate interest).
- Ensuring information security and preventing abuse and form floods (IP address, server logs, request limits) — Art. 5/2-f (legitimate interest).
- Keeping records needed to establish, exercise or protect a right — Art. 5/2-e.
- Meeting legal obligations and requests from competent authorities — Art. 5/2-ç (legal obligation).
- Measuring whether our ChatGPT ad brings in requests — solely on the basis of the explicit consent you give in the consent box (Art. 5/1). If you do not consent, this measurement does not take place; the rest of the site is unaffected.
Apart from the ChatGPT ad measurement, we do not rely on your explicit consent. The checkbox on the contact form is for confirming that you have read this notice; it is not a declaration of consent. Consent is not required for us to answer your request.
4. How data is collected
Data is collected electronically by automated means through the contact form, the site's visit counter, the web server and, only if you consent, OpenAI's measurement code; and by partly automated means when you write to us directly by e-mail, phone or WhatsApp.
5. To whom and why we transfer data
- Hosting — GoDaddy: data from the website, contact form and our customer relationship system is kept on GoDaddy servers outside Türkiye. This is a transfer abroad under Article 9 of the KVKK and is made on the basis of the standard contract announced by the Personal Data Protection Board.
- Corporate email — Google Workspace (Google): emails you send to info@bellabinary.com and the form's email fallback are processed on Google servers outside Türkiye; this transfer is likewise based on the standard contract under Article 9.
- WhatsApp (Meta): only if you choose to write to us on WhatsApp; the platform's own terms also apply in that case.
- Competent public authorities: only where there is a legal obligation or a request from a competent authority.
- Ad measurement — OpenAI: if you arrive from the ChatGPT ad and consent, the measurement data listed in section 2 is sent to OpenAI's servers abroad and processed by OpenAI under its own privacy policy. This is a transfer abroad under Art. 9 KVKK and is based on the explicit consent you give in the consent box; without your consent, no transfer takes place.
Your personal data is not sold. The only advertising-related sharing is the consent-based ChatGPT ad measurement described above.
6. Retention periods
- Requests that do not become a customer relationship: 2 years from the last activity; after that, identity, contact and message details are deleted and the record is anonymized. Requests marked as spam: 90 days.
- Requests that become a customer relationship: for the duration of the contract and the retention periods set by law (10 years under the Turkish Commercial Code and Tax Procedure Law).
- IP address and browser information attached to a request: 6 months.
- Application logs: 12 months; change records (audit log): 2 years.
- Server access logs: at most 12 months.
- Campaign and browsing data in the browser's session storage: deleted from your browser when the tab is closed.
- ChatGPT ad measurement: the ad arrival entry in your browser is kept for 30 days and your consent decision until you clear your browser data; measurement data sent to OpenAI is subject to OpenAI's retention policy.
When a period ends, the data is deleted or anonymized automatically by a scheduled job.
7. Your rights under Article 11 of the KVKK
- To learn whether your personal data is processed,
- To request information if it has been processed,
- To learn the purpose of processing and whether it is used in line with that purpose,
- To know the third parties in Türkiye or abroad to whom it is transferred,
- To request correction if it is incomplete or inaccurate,
- To request its deletion or destruction under the conditions of Article 7 of the KVKK,
- To request that correction, deletion or destruction be notified to third parties to whom the data was transferred,
- To object to a result against you arising from analysis of the data exclusively by automated systems,
- To claim compensation if you suffer damage due to unlawful processing.
- to withdraw your explicit consent at any time (for the ChatGPT ad measurement, by clearing this site's data in your browser and choosing "Decline" in the box, or by writing to info@bellabinary.com).
8. How to apply
In line with the Communiqué on the Procedures and Principles of Application to the Data Controller, you may send your request as a signed written petition to our address above, with a secure electronic signature, mobile signature or registered electronic mail (KEP), or from an email address you have previously given us and that is registered in our systems, to info@bellabinary.com. Your request is resolved free of charge within 30 days at the latest; if the process involves an additional cost, the Board's tariff may apply. If you find our answer insufficient, you may lodge a complaint with the Personal Data Protection Board.
9. Changes
This notice is updated when our processing activities change; the current version is published on this page with the date at the top.
