Personal Data Protection Notice

ThinkVoice AI | ThinkVoice Bilişim Anonim Şirketi

This Personal Data Protection Notice ("Notice") has been prepared by ThinkVoice Bilişim Anonim Şirketi ("ThinkVoice AI", "ThinkVoice", "Company", "we", "us" or "our") in its capacity as data controller, in accordance with Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK" or "Law") and the Communiqué on the Principles and Procedures to Be Followed in Fulfillment of the Obligation to Inform.

This Notice explains how we collect, process, store, and transfer personal data when you visit our website, interact with our digital services, or contact us regarding our artificial intelligence-powered products and solutions.

Article 1. Identity of the Data Controller

The data controller responsible for processing your personal data is:

Article 2. Categories of Personal Data Processed

Depending on how you interact with our website and services, we may process the following categories of personal data:

2.1. Identity and Contact Information

Your first and last name, business email address, telephone number, company name, and professional title or position.

This information is collected when you voluntarily submit a contact form, request a product demonstration, or inquire about our products and services.

2.2. Communication and Inquiry Information

Information contained in messages, inquiries, correspondence, and other communications submitted through our website forms or via email.

2.3. Information Security and Technical Data

Your IP address, browser type, device information, access timestamps, server logs, and other technical information necessary to operate, maintain, and protect our website and digital infrastructure.

2.4. Cookies and Website Usage Data

Information relating to website visits, pages viewed, navigation patterns, user interactions, preferences, and website performance.

Such information may be collected through cookies and similar technologies, including analytics solutions such as PostHog, subject to the applicable legal requirements and your consent where necessary.

Special Categories of Personal Data

Our website does not request or intentionally collect special categories of personal data, as defined under Article 6 of the KVKK.

We kindly ask that you refrain from submitting sensitive personal information through our contact forms or general communication channels.

Article 3. Purposes and Legal Grounds for Processing Personal Data

We process personal data only for specified, explicit, and legitimate purposes, in accordance with the principles of lawfulness, fairness, data minimization, and proportionality.

The purposes of processing and their corresponding legal grounds are outlined below.

Where processing activities are based on our legitimate interests, we take into account the necessity and proportionality of the processing and the potential impact on your fundamental rights and freedoms.

Where explicit consent is required, it is obtained separately from this Notice. You may withdraw your consent in accordance with applicable law.

Article 4. Methods of Personal Data Collection

4.1. We collect personal data through automated, partially automated, and, where applicable, non-automated methods, including:

• Website interactions: Through cookies, similar tracking technologies, website analytics tools, server access records, and technical security logs.

• Direct communications: Through information that you voluntarily provide when completing contact or demonstration request forms, sending emails, or otherwise communicating with ThinkVoice AI.

4.2. Personal data is collected and processed in accordance with the legal grounds described in Article 3 of this Notice and the relevant provisions of the KVKK.

Article 5. Transfer and Disclosure of Personal Data

5.1. We may disclose or transfer your personal data to authorized third parties, to the extent necessary for the purposes described in this Notice and in compliance with Articles 8 and 9 of the KVKK.

Depending on the relevant processing activity, recipients may include:

• Hosting, security, and infrastructure providers: Service providers supporting the hosting, security, availability, and content delivery of our website.

• Website analytics providers: PostHog, where used to evaluate website performance, visitor interactions, and user experience.

• Tag management providers: Google, as the provider of Google Tag Manager (GTM), where relevant personal data is processed or transferred in connection with the operation of this service.

• Professional advisers: Authorized legal advisers, auditors, and other professional service providers, where necessary.

• Public authorities: Competent regulatory bodies, judicial authorities, and other public institutions where disclosure is required or permitted by applicable law.

5.2. Any such transfer shall be limited to personal data necessary for the relevant purpose and shall be subject to applicable confidentiality, security, and data protection requirements.

5.3. ThinkVoice AI does not sell personal data to third parties or transfer personal data for the independent commercial exploitation of such data.

Article 6. International Transfers of Personal Data

6.1. Our website may use third-party infrastructure and content delivery network (CDN) services to support website performance, availability, and security. In this context, certain technical information, such as IP addresses and connection logs, may be processed by the relevant service providers.

6.2. Depending on the technical configuration and geographic location of the service providers, personal data processed through PostHog, Google Tag Manager, and CDN services may be transferred to servers, systems, or service providers located outside Türkiye.

6.3. Any international transfer of personal data shall be carried out in accordance with Article 9 of the KVKK and other applicable data protection legislation, based on a legally valid international transfer mechanism.

Such mechanisms may include:

• An applicable adequacy decision issued by the Turkish Personal Data Protection Board;

• Appropriate safeguards recognized under the KVKK, including standard contracts approved or published by the relevant authority, where applicable;

• Other legally permitted transfer mechanisms or statutory derogations, provided that their respective conditions are satisfied.

6.4. Where explicit consent is relied upon for an occasional international transfer in circumstances permitted by law, the relevant individual shall be informed of the potential risks before such consent is obtained.

6.5. We apply appropriate technical and organizational safeguards to protect personal data transferred internationally, in accordance with applicable legal requirements.

Article 7. Retention of Personal Data

7.1. We retain personal data only for as long as necessary to fulfill the purposes for which it was collected and processed, or for the periods required by applicable laws and regulations.

7.2. Retention periods may vary depending on the nature of the personal data, the relevant processing purpose, statutory requirements, and the retention settings applicable to cookies and similar technologies.

7.3. Once the applicable retention period expires or the processing purpose ceases to exist, personal data shall be deleted, destroyed, or anonymized in accordance with the KVKK and our Personal Data Retention and Destruction Policy, unless further retention is legally required or permitted.

Additional information concerning retention periods may be provided in our Privacy Policy and Cookie Policy.

Article 8. Commercial Electronic Communications

8.1. ThinkVoice AI may send commercial electronic communications relating to its AI-powered products, services, promotional activities, announcements, and marketing campaigns in accordance with Turkish Law No. 6563 on the Regulation of Electronic Commerce and other applicable legislation.

8.2. Where prior approval is legally required, we obtain your approval before sending commercial electronic communications through channels such as email, SMS, or telephone.

8.3. Consent, approval, and opt-out procedures are managed in accordance with the applicable requirements of the Commercial Electronic Message Management System (İleti Yönetim Sistemi – İYS).

8.4. You may exercise your right to opt out of commercial electronic communications at any time, in accordance with applicable legislation.

8.5. Where explicit consent is required for the processing of personal data, such consent is requested separately from this Notice and independently of any other legally required commercial communication approval.

Article 9. Your Rights as a Data Subject

Under Article 11 of the KVKK, you have the right to apply to the data controller and exercise the following rights concerning your personal data:

1. Confirmation of processing: To learn whether your personal data is being processed.

2. Access to information: To request information concerning the processing of your personal data, if such processing has occurred.

3. Purpose of processing: To learn the purpose of the processing and whether your personal data is being used in accordance with that purpose.

4. Disclosure of recipients: To know the third parties to whom your personal data has been transferred, whether within Türkiye or abroad.

5. Rectification: To request the correction of incomplete or inaccurate personal data.

6. Erasure or destruction: To request the deletion or destruction of your personal data under the conditions set out in Article 7 of the KVKK.

7. Notification to third parties: To request that any correction, deletion, or destruction carried out in accordance with the KVKK be communicated to third parties to whom your personal data has been transferred.

8. Objection to automated processing: To object to any result that is detrimental to you and arises exclusively from the analysis of your personal data through automated systems.

9. Compensation: To request compensation for damages suffered as a result of the unlawful processing of your personal data.

These rights may be exercised subject to the conditions and limitations set out in applicable legislation.

Article 10. Exercising Your Rights and Contact Information

10.1. You may submit requests concerning your personal data in accordance with the Communiqué on the Principles and Procedures for Applications to the Data Controller.

Requests may be submitted through the following channels:

10.2. Your request will be evaluated and finalized as soon as possible and, in any event, within thirty (30) days of receipt, in accordance with applicable legislation.

10.3. Depending on the nature of your request, additional information may be required to verify your identity and ensure that personal data is not disclosed to unauthorized parties.

ThinkVoice AI

Intelligent Voice Technologies & AI-Powered Customer Experience Solutions

ThinkVoice Bilişim Anonim Şirketi

Website: https://thinkvoice.ai

Email: [email protected]