Privacy Statement
Description
Kutibo Teknoloji ve Danışmanlık Limited Şirketi (“Triem”, “Company”, “We”, or “Us”) prioritizes the confidentiality and security of the data provided by our clients and visitors. This policy outlines our data processing standards in compliance with the Law on Protection of Personal Data (KVKK) and the General Data Protection Regulation (GDPR).
1. Data Controller Information
Legal Name:
Kutibo Teknoloji ve Danışmanlık Limited Şirketi
Address:
Huzur, Maslak Ayazağa Cd. No:4/B, 34485, Sarıyer / İstanbul, Türkiye
E-mail:
3. Client Responsibility and PII Exclusion
Anonymization:
The Client is solely responsible for ensuring that all MMM data sets are fully anonymized or aggregated before transfer.
Audit & Recourse:
Triem employs reasonable technical measures to ensure incoming MMM data does not contain Personally Identifiable Information (PII). However, the ultimate responsibility lies with the Client. Any administrative fines or legal costs arising from the Client's accidental sharing of PII shall be recoursed to the Client.
4. Data Collection and Infrastructure
Methodology:
Data is collected via API, FTP, Google Sheets, or CSV. We utilize Airbyte Cloud as a data integration service to facilitate transfers.
Storage & Location:
All data is hosted on Google Cloud Platform (GCP) dedicated servers located in Brussels, Belgium.
Cross-Border Transfer:
Data transfers to these servers are conducted in compliance with KVKK (Art. 9) and GDPR, utilizing Standard Contractual Clauses (SCCs) where necessary.
Isolation:
Client data is strictly segregated; no data is cross-used between different client models.
Security and Payments
Encryption:
Data is protected by industry-standard encryption, access logging, and firewalls.
Financial Data:
Payments are handled via bank transfer; no credit card or financial data is stored on our systems.
Data Retention and Deletion
Raw MMM Data:
All raw data sets provided by the Client are permanently deleted within 30 days following the termination of the Service Agreement.
Contact Data:
Personal contact information is retained as long as the business relationship continues or until a deletion request is made, subject to legal statute of limitations.
Confidentiality:
Mutual non-disclosure obligations regarding service outcomes and methodologies remain in effect for 10 (ten) years post-termination.
7. Data Subject Rights
In accordance with KVKK and GDPR, individuals (data subjects) have the right to:
Request access to their personal data,
Request rectification or erasure ("Right to be Forgotten"),
Object to or restrict processing,
Request data portability (under GDPR),
Withdraw consent at any time for marketing communications. To exercise these rights, please contact us at info@triem.ai.
8. Cookies
Detailed information regarding the use of cookies on our website can be found in our separate Cookie Policy.
9. Jurisdiction
This policy and all related data processing activities are governed by Turkish Law, with Istanbul (Çağlayan) Courts holding exclusive jurisdiction.
