Effective Date: March 1, 2025
SCALIBIT.COM INFORMATION ON THE LAW ON PROTECTION OF PERSONAL DATA
We, as SCALIBIT.COM (“SCALIBIT”), place importance on protecting the confidentiality and security of your personal data. In this regard, we wish to inform you about your personal data in accordance with the provisions of the Law No. 6698 on the Protection of Personal Data (LPPD/KVKK), which was enacted to safeguard personal data, privacy, and fundamental rights and freedoms. You can get more information about SCALIBIT’s purposes for processing your personal data by reviewing SCALIBIT’s Notice on Protection and Processing of Personal Data at the website www.scalibit.com/legal (“Notice on PPD”).
1. Purposes of Processing and Transferring Personal Data
SCALIBIT processes your personal data collected by us in the capacity of data controller under the Law on the Protection of Personal Data in accordance with the following information and purposes.
Personal data refers to all information about an identified or identifiable natural person. Data about race, ethnicity, political opinion, philosophical belief, religion, sect or other beliefs, dress, membership in association, foundation or union, health, sexual life, criminal conviction and security measures, and biometric and genetic data are recognized as sensitive personal data.
We would like to notify you that SCALIBIT may process your personal data for the purposes of providing our services to our clients, recording your suggestions and complaints, planning and executing the commercial and working strategies of SCALIBIT, conducting the necessary operations by our relevant business units to fulfill the commercial activities executed by SCALIBIT, and managing associated business operations in accordance with the Law on the Protection of Personal Data.
SCALIBIT acts as a Data Controller only for customer account, billing, authentication, and communication-related information collected during registration and service use. We do not act as a Data Controller or a Data Processor for any data stored or transmitted on customer-managed or self-managed servers, including but not limited to Virtual Machines (VPS, VDS, Dedicated Cloud Servers), Cloud Services (Cloud Hosting, Cloud Servers, Cloud Backup), Cloud Compute (Standard Performance, High Performance, High Frequency), Optimized Cloud Compute (General Purpose, CPU Optimized, Memory Optimized, Storage Optimized), and Dedicated Servers or Bare Metal systems.
For managed environments (such as Shared Web Hosting: cPanel Hosting, CWPpro Hosting, WordPress Hosting) or temporary technical support cases where SCALIBIT personnel may require limited, purpose-bound access, SCALIBIT may act as a temporary Data Processor in accordance with the principles set forth under Articles 5, 6, and 8 of the Law No. 6698 (KVKK) and our Data Processing Addendum (DPA).
SCALIBIT does not access, review, or process customer-stored data on unmanaged servers or instances. Customers are solely responsible for the data they upload, process, or store within their hosting environments. SCALIBIT’s role in such cases is limited to providing and maintaining the underlying infrastructure and network services.
As the Data Controller, we can process your personal data for the following purposes:
Negotiating, concluding and executing contracts,
Presenting products and services,
Customizing the products and services provided in line with the demands; upgrading and improving the products and services in accordance with customer needs and legal and technical developments,
Identifying users in the system based on the products and services provided,
Providing call center and remote support services, monitoring the numbers and contents of calls,
Communicating the new or existing products and services, managing the sales and marketing activities,
Conducting market research,
Creating statistics and analyzing usage,
Paying, collecting and selecting the method of collection of product, service and maintenance charges,
Establishing contact/communication with the relevant individuals,
Managing the business relationships with cooperation partners, suppliers, resellers and service providers,
Submitting reports in line with cooperation,
Assessing the business partnership application process of resellers,
Developing commercial strategies and making the plans of the Company,
Contacting the relevant individuals to conduct satisfaction measurement surveys for SCALIBIT,
Creating records on participants of events/trainings organized by SCALIBIT and issuing their certificates/participant documents,
Managing judicial/administrative processes, giving responses to requests received from public authorities and organizations, fulfilling legal obligations in accordance with legal regulations and resolving legal disputes,
To enforce our Terms of Service, Anti-Spam Policy, Use Policy or any other applicable policies,
To protect our operations or those of our affiliates and ensure the safety of the Site, SCALIBIT’s confidential and proprietary information, and SCALIBIT employees,
To manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our contract terms or laws or regulations,
To comply with applicable law and legal process, and to respond to requests from public and/or government authorities,
Managing investor relationships,
If the Company conducts a merger or demerger transaction or it is transferred partly or fully; ensuring the consequences arising from such legal transaction,
Introducing Company employees, Natural Person Resellers/Clients and Authorized Officers of Resellers/Clients in social media posts,
Conducting job interviews, assessing job applications,
Establishing, managing and terminating employment relationship/contract,
Enabling Company employees to benefit from the primary and secondary rights arising from employment contracts and assessing their performances and activities,
Opening user accounts and providing internal ID and meal cards for employees,
Arranging the transportation of Company employees, monitoring the pool cars of the Company,
Creating participant records, if an individual attends an event on behalf of the Company,
Creating training participation and certification records for employees,
Creating and following up visitor records,
Ensuring the internal and environmental security of the Company, its website and applications,
Conducting website usage analysis,
As may be otherwise disclosed at the time of collection,
Creating personal data inventory,
Assessing and responding to all questions, requests, suggestions, complaints and applications received in writing, orally or electronically, including those related to personal data.
Disclosure of Personal Information
We may disclose personal data about Site visitors, users of our Services, or our suppliers or customers as permitted or required by law, and for the following business purposes:
As necessary to identify, contact, or bring legal action against someone who may be violating our Terms of Service, Acceptable Use Policy or other user policies,
To protect ourselves, our subscribers, and the general public. We specifically reserve the right to disclose any and all information (including personal data) to law enforcement in the event that a crime is committed, is suspected, or if we are compelled to do so by lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process,
In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings),
In connection with certain essential purposes described above (e.g., to comply with legal obligations).
Disclosure to Competent Authorities and Legal Requests
SCALIBIT may disclose Customer Data, Service Details, account information, or associated IP address data to competent public authorities, judicial bodies, regulatory institutions, or other legally authorized entities (including but not limited to law enforcement agencies, prosecutors, courts, and data protection regulators) when such disclosure is required to comply with applicable Turkish laws, regulations, or enforceable legal requests.
All disclosures are carried out within the scope of Law No. 6698 on the Protection of Personal Data (KVKK), particularly in accordance with Article 8(1), regarding data transfers to authorized public institutions and organizations, as well as other relevant legislation. Such disclosures are strictly limited to the purpose of fulfilling legal obligations and only upon receipt of an official and verifiable request. SCALIBIT carefully reviews each request to ensure that it is lawful, proportionate, and limited in scope in accordance with the principles of necessity and data minimization under Article 4 of the KVKK.
Unless prohibited by law or court order, SCALIBIT will make reasonable efforts to notify the affected individual before disclosing personal data, particularly where the request may directly affect the rights or freedoms of the concerned person. SCALIBIT maintains detailed records of all such disclosures to ensure accountability and transparency under Turkish data protection principles.
We can transfer your personal data to the following individuals and entities for the above-mentioned purposes under the LPPD and other legislation:
Companies and representatives to which we grant authorization to act for and on behalf of us,
Supervisory and regulatory authorities, relevant public authorities and similar organizations as well as individuals or entities authorized in accordance with the provisions of the Turkish Commercial Law and other relevant legislation and legally-authorized public and/or private law legal entities, being limited to the purposes requested by them according to their legal authorizations,
Business partners, suppliers and contractors, banks, credit risk and financial organizations and other natural or legal entities, for the designated purposes,
Third parties that provide us with consulting services including but not limited to tax and similar consultants, mandatory individuals, authorities, organizations and inspectors in relation with the legal monitoring processes, and domestic and overseas business partners, third party service providers and authorized individuals and entities in connection with the above-mentioned purposes.
Transfer of Personal Data Abroad
In accordance with Article 9 of the Law No. 6698 on the Protection of Personal Data (KVKK), SCALIBIT may transfer personal data abroad where it is necessary for legitimate business and operational purposes, including the provision of Services, technical support, billing, infrastructure management, and compliance operations.
Such transfers are carried out only to countries deemed by the Personal Data Protection Authority (KVKK) to provide an adequate level of protection, or, if the destination country is not recognized as providing such protection, with the explicit consent of the data subject or under a written undertaking ensuring adequate protection and subject to the approval of the Authority, in accordance with Article 9(2) and 9(3) of the Law.
SCALIBIT implements appropriate technical and organizational measures to protect personal data during these transfers and ensures compliance with the principles of lawfulness, fairness, data minimization, and purpose limitation as set forth in Article 4 of the KVKK. All international transfers are conducted transparently and documented in accordance with applicable regulations.
SCALIBIT remains committed to transparency and ensures that all data subjects are informed about how and where their personal data may be processed, stored, or transferred as part of its infrastructure operations in Türkiye and abroad.
2. Method and Legal Reason for Collection of Personal Data
SCALIBIT may collect personal data in writing, orally or electronically such as through websites, social media channels and electronic mail as well as during the promotion activities and meetings organized by our Company, in order to operate more efficiently and provide you with the best experience.
Our data collection process may be executed through (i) website, email, digital channels of third parties including recruitment portals or software; (ii) contracts, applications, forms, call centers, remote support, sales and marketing department, cookies at the websites, business cards and telephone etc.; or (iii) face-to-face meetings and interviews with the data subject.
Your personal data may also be processed and disclosed under the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law on the Protection of Personal Data and for the legal reasons and purposes described in Article 1 of this information text.
3. Cookies
Our Site uses cookies. More information about our use of cookies can be found in our cookie policy https://www.scalibit.com/legal/cookie-policy.
4. Children
The Site is not for use by children under the age of 18 years and SCALIBIT does not knowingly collect, store, share or use the personal data of children under 18 years. If you are under the age of 18 years, please do not provide any personal data, even if prompted by the Site to do so. If you are under the age of 18 years and you have provided personal data, please ask your parent(s) or guardian(s) to notify SCALIBIT and SCALIBIT will delete all such personal data.
5. Security
We take measures, including data encryption, to protect the transmission of all sensitive end-user information. We make reasonable efforts to ensure the integrity and security of our network and systems. Nevertheless, we cannot guarantee that our security measures will prevent third-party 'hackers' from illegally obtaining this information. We take all reasonable measures to prevent such breaches of security, but given the resourcefulness of cyber-criminals we are unable to guarantee that our security is 100% breach-proof. You assume the risk of such breaches to the extent that they occur despite our reasonable security measures.
6. Retention of Your Personal Data
We apply a general rule of keeping personal data only for as long as required to fulfil the purposes for which it was collected. In general, we retain your personal data for a period of time corresponding to a statute of limitation, for example to maintain an accurate record of your dealings with us. However, in some circumstances we may retain personal data for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.
With respect to marketing, we retain your personal data for 18 months after your last request for service or other contact you initiate.
7. External Links
The Site may contain links to third party sites. Since SCALIBIT does not control nor is responsible for the privacy practices of those Sites, we encourage you to review the privacy policies of these third party sites. This Notice applies solely to personal data collected by our Sites or in the course of our business activities.
8. Your Rights about Processing the Personal Data
In relation with your personal data in accordance with Article 11 of the Law on the Protection of Personal Data, you, as personal data owner, are entitled:
To know whether your personal data has been processed or not,
If your personal data has been processed, to ask for information about processing of such data,
To know the purpose of processing your personal data and to know whether such data is used in accordance with the purpose,
To know the third parties domestically or abroad to whom such personal data has been disclosed,
If your personal data has been processed incompletely or wrongly, to ask for correction of it,
To ask for deletion or disposal of your personal data, although your personal data has been processed in accordance with the provisions stipulated in the Law on the Protection of Personal Data and the other relevant laws, but the reasons that require processing of your personal data have disappeared; and to ask for providing information to third parties to whom such personal data has been disclosed, in connection with such deletion or disposal,
To object to the occurrence of any negative results about the data owner through analysis of your processed data exclusively by automatic systems,
To ask for the indemnification of the loss suffered due to the processing of your personal data in violation of the law.
In certain cases, SCALIBIT may request identity verification or supporting documentation (such as a government-issued ID, passport, business registration certificate, tax identification number, or any other relevant document) to confirm account ownership, prevent fraud or abuse, ensure compliance with Turkish laws and KVKK requirements, or verify the legitimacy of a transaction or data-related request.
Such verification is performed exclusively through official SCALIBIT communication channels — such as the Client Portal or the authorized support ticket system — and handled only by personnel authorized to process such information. All submitted documents are used solely for verification purposes, stored securely, and retained only as long as required by applicable law or legitimate business necessity, including cooperation with authorized government bodies when necessary.
This information will never be used for profiling, marketing, or any unrelated processing activities. SCALIBIT applies strict confidentiality, purpose limitation, and data minimization principles in line with Article 4 of the KVKK.
9. Contact Information
If you have additional questions regarding your rights under the KVKK, please refer to the SCALIBIT Privacy Notice and contact us at kvkk@scalibit.com.
SCALIBIT.COM (SCALIBIT TECHNOLOGY)
Email: kvkk@scalibit.com
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