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METU Technopolis · Ankara

Protection of Personal Data

Privacy Notice

Effective date 1 July 2026 Last updated 3 July 2026

Placeholder content. The text below is a sample draft showing the structure of the final privacy notice to be prepared under Turkish Law No. 6698 on the Protection of Personal Data ("KVKK"). Before publication, the company details and VERBİS registration must be verified and legal counsel approval obtained.

Contents

  1. Identity of the Data Controller
  2. Personal Data Processed
  3. Purposes of Processing and Legal Basis
  4. Transfer of Personal Data
  5. Retention Period
  6. Rights of the Data Subject (KVKK Article 11)

01Identity of the Data Controller

Under Turkish Law No. 6698, the data controller is the company operating the EarFit brand (hereinafter “EarFit” or the “Company”).

  • Trading name: [company trading name to be entered here]
  • Address: METU Technopolis, Ankara
  • Email: [email protected]
  • MERSİS / VERBİS No: [to be completed before publication]

02Personal Data Processed

EarFit may process personal data in the following categories in its product sales, custom production and customer relations processes:

  • Identity: first name, surname
  • Contact: email, telephone, delivery/billing address
  • Customer transactions: order history, cart contents, product configuration preferences
  • Financial: the outcome of the payment transaction (card details are not stored by EarFit; they are processed by the payment provider)
  • Auditory / biometric measurements: ear impression and acoustic measurement data taken for custom production (where applicable)

03Purposes of Processing and Legal Basis

Your personal data is processed for the following purposes, on the legal bases set out in Articles 5 and 6 of the KVKK:

  • Creating, producing and delivering the order — conclusion/performance of a contract
  • Issuing invoices and meeting legal obligations — legal obligation
  • Responding to customer support and contact requests — legitimate interest
  • Sending commercial electronic messages where you have consented — explicit consent

This section contains placeholder text; the final legal text will be entered here once approved by a lawyer or legal adviser.

04Transfer of Personal Data

Your personal data may be transferred to the following parties, only to the extent required by the purposes above and in accordance with the KVKK: courier/logistics companies, payment and banking institutions, accounting/legal advisers, cloud infrastructure providers and legally authorised public authorities.

Where a transfer abroad is involved, the conditions set out in Article 9 of the KVKK are met. This section contains placeholder text; the final legal text will be entered here once approved by a lawyer or legal adviser.

05Retention Period

Your personal data is retained for the periods prescribed by the relevant legislation (for example, 10 years for commercial and tax records) and for as long as the purpose of processing requires; at the end of that period it is deleted, destroyed or anonymised.

06Rights of the Data Subject (KVKK Article 11)

Under Article 11 of the KVKK, you have the following rights:

  • To learn whether your personal data is being processed and to request information about it
  • To learn the purpose of processing and whether the data is used in line with that purpose
  • To request the correction of incomplete or inaccurately processed data
  • To request the erasure or destruction of the data
  • To object to a result arising from analysis carried out exclusively by automated systems
  • To claim compensation for damage arising from unlawful processing

You can send your requests to [email protected]. Requests are concluded within 30 days at the latest.

Do you have a request about your data?

You can contact us to exercise your rights under the KVKK (Turkish Personal Data Protection Law) or to submit a request.

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