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Privacy Policy

KVKK, GDPR & CCPA Privacy Notice

Last Updated:

1. Introduction

This Privacy Policy explains how Muhittin Camdali (“we”, “us”) processes personal data when you visit and use muhittincamdali.com (the “Site”). It is prepared under the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and, for visitors in the European Union, refers to the corresponding provisions of the General Data Protection Regulation (“GDPR”). Information for California residents is in Section 11. A Turkish-language KVKK information notice is available at /aydinlatma-metni/.

This policy describes how the Site actually works today. In short:

  • Visitor measurement runs on our own server; no third-party analytics, advertising or session-recording script is embedded in the pages.
  • If you do not consent to analytics, no persistent visitor identifier is created; only identifier-free, aggregate measurement takes place.
  • Messages you type into the chatbot are sent to Google Gemini (USA) to generate replies; do not enter personal data in the chat.
  • Maps and web fonts are loaded from Google only when you press the button.

2. Data Controller

Name:
Muhittin Camdali
Location:
Istanbul, Türkiye
Email:
info@muhittincamdali.com
Website:
muhittincamdali.com

3. Personal Data We Process

The sections below describe which data is processed in which situation. Legal bases are in Section 5 and retention periods in Section 9.

a) Contact form

  • Your name, email address, subject and message
  • The time you confirmed on the form that you have read the Privacy Policy (on the Turkish-language form, also the KVKK Notice)

Your full message is forwarded to us in a notification email, and you receive an automatic acknowledgement email. If your request is not answered within 24 hours, your name and the subject are sent to the administrator’s Slack notification channel as a reminder. Your IP address is not added to the form record.

b) Project quote form

  • Name and email address; optionally phone number and company name
  • Project type, name and description, target platform, budget range, timeline, priority and requested features
  • How you heard about us and the time you confirmed that you have read these notices

A summary of the request (name, email, project name and type, budget, timeline) is forwarded to us in a notification email, and you receive an acknowledgement email. If the request is not answered within 24 hours, your name and the project name are sent to the administrator’s Slack notification channel as a reminder. Your IP address is not added to the form record.

c) KVKK request form

  • Name and email address; optionally phone number and identity verification details
  • Request type and your description
  • The IP address from which the request was sent (for the security of the request)

Your request is forwarded to us in a notification email, and you receive an acknowledgement email containing your request number.

d) Newsletter subscription

  • Your email address, the form you subscribed through, your language and status
  • The time you confirmed your subscription (as proof of consent)
  • Newsletter statistics (from the newsletters sent to you only, for your confirmed subscription): number of opens and clicks, time of last engagement

Subscription uses double opt-in. After you submit the form, you receive a confirmation email. Its link opens a page, and your subscription starts only when you press the “Confirm my subscription” button on that page. The link is valid for 7 days. Records that were never confirmed (awaiting confirmation, unsubscribed before confirming or undeliverable) are deleted after 14 days. Your IP address is not stored in the subscriber record.

Every newsletter contains a one-click unsubscribe link, and your email client’s “unsubscribe” option (List-Unsubscribe) also works. Reporting a newsletter as spam also unsubscribes you. When you unsubscribe, your record is marked “unsubscribed” and your name (if any), newsletter statistics and tags are deleted. Your email address is kept only to prevent further newsletters from being sent to you; the time of your confirmation remains in the record as proof of the consent you gave. Event records of the emails already sent to you (section e) are kept separately for 13 months.

If the newsletter permanently cannot be delivered to your address (for example, the mailbox no longer exists), sending stops and the record is marked “undeliverable”; temporary delivery failures do not change the record. A confirmed record stays in this state until you unsubscribe or ask for it to be deleted. If the address becomes reachable again, sending may resume on the basis of the consent you gave earlier; this is not done if you have unsubscribed. If the form is submitted again with this address after you unsubscribed or after a delivery failure, the record awaits confirmation again: your name, tags and newsletter statistics are deleted, and nothing is sent until you confirm again. Because anyone who knows the address can submit the form, the earlier confirmation and unsubscribe times stay as proof until you confirm again; a record that was never confirmed is deleted entirely if it is not confirmed within 14 days.

e) Emails we send

Emails sent on behalf of the Site (form and request acknowledgements, confirmation emails and newsletters) are delivered through Resend. For each email we record the recipient address, subject, template and events such as sent, delivered, opened and clicked; for clicks only the link address is kept, without query parameters. Opens and clicks are measured with Resend’s tracking pixel and link redirect (links.muhittincamdali.com). Resend sees your IP address and browser details when this happens; we do not store them.

f) Chatbot

Messages you type into the chat window are sent to Google LLC’s Gemini service (USA) to generate a reply. Only the message texts (the last 10 messages as context) are sent to Gemini; your IP address, identifiers and browser details are not.

We use Gemini’s free tier. Under the Gemini API terms, content submitted on this tier and the generated replies may be used to improve Google’s products and services and may be read by human reviewers. Please do not enter personal data such as your name, email address or phone number, or any confidential information, in the chat.

If you have given analytics consent, the conversation is stored for 90 days: the messages, visitor and session identifiers, a coarse device family (e.g. “Chrome/Windows”), a keyed hash of your IP address, the page where you started the chat and the language. Without consent, the conversation is not stored. The chat history is also kept only in the open browser tab and is deleted when you close it.

g) Analytics (only with your consent)

If you allow analytics in the cookie preferences, our own measurement tool creates a visitor identifier (mc_visitor_id) and a session identifier (mc_session_id) in your browser. Together with these identifiers, the following data is sent to muhittincamdali.com/api/analytics, i.e. the same server that hosts the Site (Hetzner, Germany); it is not sent to a third-party analytics company:

  • Pages you visit, time spent on them and scroll depth
  • Referring address and campaign (UTM) parameters
  • Device type, operating system, browser family, screen size, browser language and colour scheme
  • Links and buttons you click (element type and description, first 100 characters of its text, link address, click position)
  • Names of the form fields you reach (not the values you enter), the subject type you choose on the contact form, searches on the blog and code copying
  • Browser error messages and page performance metrics
  • The country derived by Cloudflare from your IP address and a keyed hash of your IP address (the IP address itself is not stored)

When you decline or withdraw consent, both identifiers are deleted from your browser immediately and measurement stops.

h) Identifier-free measurement (no consent required)

Even without analytics consent, an identifier-free, aggregate measurement runs to check that the Site works properly. It records: page path, scroll depth (25%, 50%, 75%, 100%), repeated or ineffective clicks and their position, an in-page description of the clicked element, slow interactions, whether the page is visible or in the background, clicks on consulting links, browser error messages, browser window size, device and connection type, language and the country code derived by Cloudflare from your IP address.

These records contain no visitor or session identifier, and your IP address is not stored. If you have consented, your visitor and session identifiers are added to the same events. Without consent, no persistent visitor identifier is created for measurement; the only exception is the cookie set when you like a post so that the like is counted once (see j).

i) Achievement notifications

When you unlock an achievement anywhere on the Site, the name of the achievement and the page language are reported to the server; achievements unlocked earlier in your browser but not yet reported are reported at the same time. If you have given analytics consent, your visitor identifier is added; otherwise a new random identifier is used for every notification, so notifications cannot be linked to you. Your IP address is not recorded. Achievements already reported are marked in your browser (mc_achievements_reported) so they are not sent again; this marker is not an identifier and is not sent to the server.

j) Blog engagement

When you like a post, a mc_visitor_id cookie containing a random identifier is set in your browser (1 year; readable only by the server) so that the like is counted once, and the post, this identifier and the action type are recorded. If you have given analytics consent, post views are counted uniquely the same way. Bookmarks are kept only in your browser.

k) Error reports

When an error occurs on the Site or the server, error details are sent to Sentry (Functional Software, Inc., USA); event data is stored in Sentry’s EU (Germany) region. Sent data: error message and stack trace, page address and referrer (without query parameters), browser, operating system and language, and the navigation and click steps before the error. In addition, a session summary showing whether the visit ended without errors is sent on each visit; no persistent identifier is created in your browser for this. IP addresses and cookies are not stored; only the country is derived from the IP address. Session replay is not used.

l) Security logs

Our server logs every request with the IP address, date and time, requested address, response code, referrer and browser details (access log). To prevent abuse, rate-limit records (IP address) and application error logs (which may contain an IP address) are kept. The chat service records abuse events, such as exceeding the rate limit, with a keyed hash of the IP address and a coarse device family.

m) Admin login

Admin panel login attempts are stored with the IP address and browser details to prevent unauthorised access.

n) Data that stays on your device

Your theme, language and sound preferences, game high scores, achievement progress, like and bookmark markers and your Google Fonts choice are kept only in your browser and are not sent to the server (except the achievement notification above). The full list is in our Cookie Policy.

4. Purposes of Processing

  • Receiving and answering your contact messages, quote requests and KVKK requests
  • Sending the newsletter, proving subscription consent and monitoring newsletter statistics
  • Checking whether our emails reach you
  • Generating replies to your questions in the chatbot
  • If you have consented, measuring how the Site is used and improving it
  • Monitoring the Site’s operation, performance and errors without identifiers
  • Keeping the Site and the admin panel secure and preventing abuse
  • Keeping like and view counters accurate
  • Complying with legal obligations

Your personal data is not sold and is not used or shared for advertising.

6. Cookies and Browser Storage

There are two categories in the cookie preferences:

Required (always on)

Session / persistent

Your cookie choice, theme and language, form and chat limits, like and bookmark markers, your Google Fonts choice, game scores and achievement progress. No consent is needed; they are kept only to run the Site and the feature you use.

Analytics (optional)

While consented

Visitor identifier (mc_visitor_id) and session identifier (mc_session_id). Created only with your consent and deleted immediately when you decline or withdraw consent.

There are no third-party cookies by default; Google Maps cookies may be set only when you load the map on the Contact page. No advertising or third-party analytics cookies are used.

Analytics consent is valid for 12 months; when it expires, measurement stops and you are asked again. Even without consent, the identifier-free measurement, error reports and security logs described in Section 3 continue; they do not store identifiers in your browser. You can change your preferences at any time via the “Cookie Preferences” link at the bottom of the page. For the full list, please see our Cookie Policy.

7. Service Providers (Recipients)

The following service providers are used to run the Site. Each processes only the data needed for the task described. Visitor measurement uses our own tool; no third-party analytics script is embedded in the pages.

Hetzner Online GmbH — Germany

Server hosting: the Site, database, measurement tool, server logs and 30-day local backups are on a server in Nuremberg. All data collected on the Site is processed there.

Privacy Policy — Hetzner Online GmbH — Germany →

Cloudflare, Inc. — USA

Content delivery and security: every request passes through Cloudflare with its IP address, browser details and requested address. Also DNS, forwarding of emails sent to the Site’s addresses (info@, teklif@, kvkk@) to the administrator’s mailbox, and R2 storage where database backups are kept for 90 days. Cloudflare also provides the site administrator with aggregate traffic statistics derived from these requests.

Privacy Policy — Cloudflare, Inc. — USA →

Resend — USA (sending via Amazon SES, Ireland region)

Email delivery: form and request notifications and acknowledgements (name, email, message or request content), confirmation emails and newsletters; delivery, open and click tracking of the emails sent.

Privacy Policy — Resend — USA (sending via Amazon SES, Ireland region) →

Google LLC — USA

Gemini: generating replies to messages you type into the chatbot. Google Maps and Google Fonts: loaded only when you press “Load Map” on the Contact page or the load-fonts button in the Toolkit font tool; your IP address and browser details are then sent to Google.

Privacy Policy — Google LLC — USA →

Slack — USA

Administrator notifications: for contact and quote requests unanswered for 24 hours, the requester’s name and the subject or project name; other notifications contain only counts and system status.

Privacy Policy — Slack — USA →

Functional Software, Inc. (Sentry) — USA; data stored in the EU (Germany) region

Error monitoring: error details, page address, browser and operating system, and a session summary. IP addresses and cookies are not stored; only the country is derived from the IP address.

Privacy Policy — Functional Software, Inc. (Sentry) — USA; data stored in the EU (Germany) region →

8. International Transfers

Within Türkiye, your personal data is not transferred to third parties; it may be disclosed to authorised public authorities only upon a lawful request and to the extent required by law.

The Site’s server is in Germany and some of the providers in Section 7 are in the United States, so your personal data is transferred abroad. The basis for these transfers is as follows:

  • Infrastructure used continuously: hosting and database (Hetzner), content delivery, DNS, email forwarding and backup storage (Cloudflare), email delivery (Resend), error monitoring (Sentry) and administrator notifications (Slack). Data you send through the forms is also delivered through this infrastructure. These transfers are not based on your consent; they take place under contractual safeguards such as the providers’ data processing agreements and the EU Standard Contractual Clauses.
  • Optional features: sending a message to the chatbot, and loading the map on the Contact page or the fonts in the Toolkit. You are informed on the relevant screen and in this policy before the action; the transfer is based on the consent you give by taking the action. You can keep using the Site without these features.

Possible risks: these transfers do not rely on an adequacy decision of the Turkish Personal Data Protection Board. Data held abroad may not enjoy protection equivalent to that in Türkiye and may be accessible to authorities under the law of the country where it is held.

9. Data Retention

Data retention periods by category
Data CategoryRetention Period
Contact form messages2 years
Project quote requests3 years
KVKK (data subject) requests3 years
Administrator notifications (form summary)90 days
Newsletter subscriptionWhile subscribed
Newsletter records that were never confirmed14 days
Unsubscribed subscriber's email address and confirmation/unsubscribe times (to prevent further sending)Until you ask for deletion
Confirmed newsletter record with a permanent delivery failureUntil you unsubscribe or ask for deletion
Email event records (sent, delivered, opened, clicked)13 months
Consented analytics: visitor and session records13 months
Consented analytics: raw events (page views, clicks, etc.)90 days
Identifier-free measurement events365 days
Achievement notifications13 months
Blog engagement (like and view records)13 months
Chat logs (consented visitors only)90 days
Chat security events (IP hash and device family)90 days
Blog search queries (consented visitors only)90 days
Error reports (Sentry)30 days
Application error log30 days
Rate-limit records7 days
Admin login attempts90 days
Server access logs (nginx)14 days
Database backups30 days on the server, 90 days in Cloudflare R2

When you unsubscribe from the newsletter, your email address is kept only to prevent further sending. Data is deleted when its period ends; deleted data may remain in backups for up to 90 more days and is then removed from backups as well. Retention periods for information kept in your browser are listed in our Cookie Policy.

10. Your Rights (KVKK & GDPR)

Under KVKK Article 11 and, if you are in the European Economic Area, the GDPR, you have the right to:

  1. Access: learn whether your personal data is processed, request information and a copy, and learn the purpose of processing (GDPR Art. 15).
  2. Recipients: know the third parties in Türkiye or abroad to whom your data is transferred.
  3. Rectification (Art. 16): request correction of inaccurate or incomplete data.
  4. Erasure (Art. 17): request deletion of your data, and request that corrections or deletions be notified to the recipients (Art. 19).
  5. Restriction (Art. 18) and portability (Art. 20): request restriction of processing and receive your data in a machine-readable format (GDPR).
  6. Objection (Art. 21, 22): object to processing based on legitimate interests and to a result to your detriment arising solely from automated processing.
  7. Withdrawal of consent (Art. 7(3)): withdraw consent at any time via “Cookie Preferences” or the unsubscribe link in our emails.
  8. Compensation: claim compensation for damage caused by unlawful processing.
  9. Complaint: lodge a complaint with the Turkish Personal Data Protection Board or your local EU supervisory authority.

11. Your Rights (CCPA — California Residents)

If you are a California resident, you have the following rights under the CCPA:

  • Right to know: request disclosure of the categories and specific pieces of personal information we have collected about you.
  • Right to delete: request deletion of your personal information, subject to certain exceptions.
  • Right to opt out of sale or sharing: we do not sell personal information or share it for cross-context behavioural advertising.
  • Right to non-discrimination: we will not discriminate against you for exercising any of your CCPA rights.

12. How to Exercise Your Rights

To exercise your rights, email us at info@muhittincamdali.com or use our KVKK request form (in Turkish).

Email:
info@muhittincamdali.com
Response Time:
Within 30 days, free of charge

Please include information that allows us to verify your identity, the right you wish to exercise and a description of your request. If the request involves an additional cost, the fee set by the Turkish Personal Data Protection Board may be charged. If your request is rejected, you find the answer insufficient or we do not reply in time, you may complain to the Turkish Personal Data Protection Board under KVKK Article 14.

13. Data Security

We take the following technical and organisational measures to protect your data:

  • TLS encryption on all connections
  • The database is reachable only from within the server and is closed to the network
  • Two-factor authentication, account lockout and rate limiting for the admin panel
  • Role-based access control
  • Data minimisation: a hash instead of the IP address, a coarse device family instead of the raw browser string, no identifiers in measurement without consent
  • Cookies and request headers are stripped before error reports are sent

No method of transmission or storage is completely secure; we take reasonable measures to reduce the risks.

14. Children’s Privacy

The Site is not directed at children under the age of 16, and we do not knowingly collect personal data from children. If you believe a child has sent us personal data, please email info@muhittincamdali.com and we will delete it.

15. Policy Changes

We may update this Privacy Policy in response to legal changes or changes to our services. Updates are published on this page and the “Last Updated” date is revised. For material changes we may provide additional notice.

16. Contact

If you have any questions about this Privacy Policy or how your personal data is processed, please contact us:

Email:
info@muhittincamdali.com
Website:
muhittincamdali.com