Legal · KVKK + GDPR

Privacy Policy

This page explains how Smartix Trading Ltd. processes personal data through its website, our cookie usage, and your rights.

Last updated: April 2026

This Privacy Policy explains how Smartix Trading Ltd. ("Smartix", the "Company", "we") processes personal data in connection with its website and digital channels.

This policy is prepared for the website under the domain smartixtrading.com (the "Website").

Smartix uses the Website mainly for promotional purposes and to receive client applications. No online payments are collected through the Website. The Website includes a Google Form link for pre-assessment applications, offers an optional email newsletter subscription, and may involve limited data processing due to cookies and analytics/marketing technologies (cookie application, Google Analytics, Meta Pixel).

1. Data Controller

The data controller for your personal data is:

Smartix Trading Ltd.
Representative: Dr. Eyyup Kavalci
Address: Orkide Sokak, Reha Apt., B: 5, D: 6, Gönyeli, Lefkoşa, TRNC.
Email: eyyup.kavalci@smartixtrading.com
Phone: +90 533 821 07 27

Services provided by Smartix include:

  • AI Check-up Programme and artificial intelligence consultancy
  • Social media management and content production
  • Video and drone production
  • AI training and corporate consultancy

2. Categories of Personal Data We May Process

2.1 Website usage data (collected automatically)

  • IP address (may be partially masked depending on settings/tools)
  • Device / browser information and operating system
  • Date/time of access, pages viewed, referring page
  • Cookie identifiers and online identifiers (depending on your cookie preferences)

2.2 Data you submit via Google Forms

Through the Google Form link on the Website:

  • First and last name
  • Email address and/or phone number
  • Company name and field of activity
  • Information you provide in response to pre-assessment questions

Corporate use note: Google Forms is a service subject to Google's own privacy policy.

2.3 Newsletter subscription data (provided by you)

If you opt in to the newsletter via the checkbox in the pre-assessment form:

  • Email address
  • Consent/subscription record (date and method)

2.4 Special categories of personal data

We do not intend to collect special categories of personal data (e.g., health data) via the Website.

3. Purposes of Processing

We may process personal data for the following purposes:

  • To ensure the Website operates properly and securely
  • To measure performance and create visitor statistics (analytics)
  • To measure marketing activities and enable remarketing/targeting (marketing cookies) — subject to your preferences
  • To review pre-assessment applications submitted via Google Forms and to communicate with applicants
  • To send monthly email newsletters about artificial intelligence technologies and news (where you have provided consent)
  • To comply with legal obligations, manage disputes, and protect our rights

We process personal data based on the following legal bases, as applicable:

  • Consent (KVKK Art. 5/1, GDPR Art. 6(1)(a)): newsletter subscription; analytics and marketing cookies (based on your cookie application choices)
  • Contract / steps prior to entering into a contract (KVKK Art. 5/2-c, GDPR Art. 6(1)(b)): receiving and evaluating pre-assessment applications
  • Legitimate interests (KVKK Art. 5/2-f, GDPR Art. 6(1)(f)): website security and basic operational needs, subject to balancing tests
  • Legal obligation (KVKK Art. 5/2-ç, GDPR Art. 6(1)(c)): legal retention and mandatory disclosures

5. Cookies and Similar Technologies

The Website uses cookies and similar technologies. You can manage your preferences at any time via the cookie application using options such as "Accept", "Reject", or "Manage preferences". Analytics and marketing cookies are only enabled according to your selections (except for strictly necessary cookies, if any).

5.1 Tools we use

  • Google Analytics (GA4): Website traffic and usage analytics — only with your consent
  • Meta Pixel: Ad measurement, conversion tracking, and remarketing — only with your consent

These tools may collect online identifiers and technical data via cookies, subject to your cookie preferences.

6. Sharing / Disclosure of Personal Data

Your personal data may be shared, limited to the purposes above, with:

  • Technical service providers (e.g., hosting, website maintenance/support)
  • Cookie/analytics/marketing technology providers: cookie application, Google, Meta (subject to your preferences)
  • Public authorities and courts: where required by law
  • Google (Google Forms): when you choose to submit an application via the Form link on our Website

Smartix does not sell your personal data to third parties.

7. International Data Transfers

Due to services such as cookie application, Google Analytics, Meta Pixel, and Google Forms, certain data may be transferred to and processed on servers located outside your country.

  • Under GDPR: transfers are intended to rely on appropriate safeguards (e.g., Standard Contractual Clauses / SCCs and supplementary measures where applicable).
  • Under KVKK: international transfers are carried out in line with applicable requirements (e.g., consent or other lawful transfer mechanisms and safeguards).

You can limit such transfers by rejecting analytics/marketing cookies via the cookie application.

8. Data Retention

  • Pre-assessment application data: generally 1 year. If a long-term business relationship is established, certain records may be retained for as long as the relationship continues and as required by applicable laws.
  • Newsletter subscription data: for as long as you remain subscribed; if you unsubscribe, we delete/anonymize within a reasonable period (subject to legal obligations).
  • Website security/technical logs: for reasonable periods based on security and operational needs.

9. Your Rights (KVKK & GDPR)

9.1 Rights under KVKK (Art. 11)

You have rights such as learning whether your data is processed, requesting information, learning the purpose and whether it is used accordingly, knowing third parties to whom it is transferred, requesting correction/deletion, objecting, and requesting compensation for damages under the conditions set by law.

9.2 Rights under GDPR

Depending on your circumstances, you may have rights to access, rectification, erasure ("right to be forgotten"), restriction of processing, data portability, objection, and to withdraw consent at any time. You may also have the right to lodge a complaint with a supervisory authority.

9.3 How to contact us

Email: eyyup.kavalci@smartixtrading.com
Address: Orkide Sokak, Reha Apt., B: 5, D: 6, Gönyeli, Lefkoşa, TRNC.

We may request additional information for identity verification.

10. Newsletter & Marketing Emails

Newsletter subscription is based on your explicit consent, provided via the checkbox in the pre-assessment form. You can unsubscribe at any time by emailing eyyup.kavalci@smartixtrading.com or by using the unsubscribe link in the newsletter email.

11. Third-Party Links (Google Forms, etc.)

The Website may include links to third-party platforms. If you use those services, their own privacy policies and terms apply. Smartix is not responsible for third-party data processing practices.

12. Data Security

We implement appropriate technical and organizational measures to protect personal data. However, no method of transmission over the internet is 100% secure.

13. Children's Privacy

The Website is not intended for children. We do not knowingly collect personal data from persons under 18.

14. Updates to This Policy

We may update this Privacy Policy from time to time. The updated version becomes effective when published on the Website.

This website uses cookies to improve your experience and analyse traffic. Analytics and marketing cookies are only activated with your consent. You can manage your preferences at any time through the cookie settings.