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Personal Data and General Confidentiality Agreement

PRIVACY & DATA PROTECTION POLICY

 

(KVKK – GDPR – US Privacy Compliant)

 

1. INTRODUCTION

 

This Privacy & Data Protection Policy (“Policy”) explains how personal data is collected, processed, stored, and protected by NUAGE TECHNOLOGY LLC (“Company”, “we”, “us”, “our”) in compliance with:

  • Turkish Law No. 6698 on the Protection of Personal Data (KVKK), where applicable

  • EU General Data Protection Regulation (GDPR), where applicable

  • Applicable United States federal and state privacy laws

 

This Policy applies to all visitors, users, customers, and members of www.nuagedc.com.


2. DATA CONTROLLER

 

Data Controller:

NUAGE TECHNOLOGY LLC

Website: www.nuagedc.com

Contact: Via the contact details published on the website

 

For users located in Türkiye or the European Union, the Company acts as Data Controller within the meaning of KVKK and GDPR.


3. PERSONAL DATA COLLECTED

 

The Company may collect and process the following categories of personal data:

  • Identity data (name, surname, company name)

  • Contact data (address, phone number, e-mail address)

  • Account data (username, encrypted password)

  • Billing and transaction data

  • IP address, access logs, device and browser information

  • Usage, traffic, and statistical data

 

Personal data is collected lawfully, fairly, and only to the extent necessary.


4. PURPOSES OF DATA PROCESSING

 

Personal data may be processed for the following purposes:

  • Provision of products and services

  • Account and membership management

  • Billing, invoicing, and payment processing

  • Customer support and communications

  • Website security, monitoring, and system administration

  • Compliance with legal obligations

  • Improvement of services and user experience

  • Prevention of fraud, abuse, and unauthorized access


5. LEGAL BASIS FOR PROCESSING

 

Personal data is processed based on one or more of the following legal grounds:

  • Explicit consent of the data subject

  • Necessity for the performance of a contract

  • Compliance with legal obligations

  • Legitimate interests of the Company, provided such interests do not override fundamental rights and freedoms


6. DATA SHARING AND INTERNATIONAL TRANSFERS

 

Personal data shall not be sold or shared with third parties except:

  • Where explicitly consented to by the data subject

  • Where required by applicable law, court order, or regulatory authority

  • With payment service providers (e.g., Paypal) solely for payment processing

  • With infrastructure or service providers strictly limited to service delivery

 

Personal data may be transferred and processed in the United States, European Union, or other jurisdictions where the Company or its service providers operate, in compliance with KVKK and GDPR safeguards (including contractual and technical measures).


7. DATA RETENTION

 

Personal data is retained only for as long as necessary to fulfill the purposes stated herein or as required by applicable law. Upon expiration of the retention period, data is securely deleted, destroyed, or anonymized.


8. DATA SECURITY

 

The Company implements reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure, including:

  • Firewall systems

  • Secure infrastructure

  • Access control mechanisms

  • Logging and monitoring

 

However, no system can be guaranteed to be 100% secure. Users are responsible for protecting their own devices, credentials, and access information.


9. COOKIES, LOGS, AND TRACKING

 

Cookies and similar technologies may be used to enhance functionality and user experience.

IP addresses and access logs may be recorded for security, operational, and statistical purposes.

 

Users may manage cookie preferences through their browser settings.


10. DATA SUBJECT RIGHTS

 

Depending on the applicable law (KVKK, GDPR, US Privacy), users may have the right to:

  • Access their personal data

  • Request correction or update

  • Request deletion or anonymization

  • Object to certain processing activities

  • Restrict processing

  • Request data portability (GDPR)

  • Withdraw consent at any time

 

Requests may be submitted through the contact channels available on the website.


11. ELECTRONIC COMMUNICATION DISCLAIMER

 

Electronic communications (e-mails) that are not encrypted cannot be guaranteed to be secure. The Company shall not be responsible for unauthorized access to such communications initiated by users.


12. THIRD-PARTY WEBSITES

 

Our website may contain links to third-party websites. The Company is not responsible for the privacy practices, security measures, or content of such websites.


13. MINORS

 

The Company’s services are not intended for individuals under the age of 18. The Company does not knowingly collect personal data from minors.


14. CHANGES TO THIS POLICY

 

The Company reserves the right to amend this Policy at any time. Updates shall become effective upon publication on www.nuagedc.com.


15. CONTACT

 

For any questions, requests, or data protection inquiries, please contact NUAGE TECHNOLOGY LLC using the contact information available on our website.

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