Information regarding personal data processing under Article 10 of the Turkish Personal Data Protection Law No. 6698.
Effective Date: 03 May 2026 · Last Updated: 03 May 2026
Template note: This document is a template prepared in accordance with Article 10 of the Turkish Personal Data Protection Law No. 6698 (KVKK). Placeholder fields (such as registry information, actual data processing purposes, and third-party transfers) must be completed with company-specific details and reviewed by a KVKK expert before publication.
This Privacy Notice is prepared under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") to inform you about the processing of your personal data by Yirmibir Group ("the Group" or "Data Controller").
01 Data Controller
Your personal data is processed by the Data Controller, whose contact details appear below, in accordance with KVKK and related legislation.
Legal Name: Yirmibir Şirketler Grubu A.Ş.
Address: Mithatpaşa Mah. Gazi Paşa Cad. No:74 K:4, Merkez/Zonguldak, Türkiye
The following categories of personal data are processed for the purposes stated in this Notice:
Identity information: First and last name
Contact information: Email address, phone number, postal address
Transaction security information: IP address, website access logs, cookie records
Professional experience: Education, work experience, and reference information shared as part of a curriculum vitae (in connection with career applications)
Other: Personal data contained in the messages or requests sent to us
03 Purposes of Personal Data Processing
Your personal data is processed for the following purposes:
Responding to inquiries and managing client relationships
Evaluating investor and partnership inquiries
Evaluating job applications and managing human resources processes
Operating, securing, and analyzing the performance of the website
Fulfilling legal obligations and responding to requests from authorized institutions
Conducting intra-group coordination and reporting processes
04 Legal Grounds for Processing
Your personal data is processed based on one or more of the following legal grounds in accordance with KVKK Articles 5 and 6:
Explicitly provided for in laws (Article 5/2-a)
Direct relevance to the establishment or performance of a contract (Article 5/2-c)
Necessity for the data controller to fulfill a legal obligation (Article 5/2-ç)
Necessity for the legitimate interests of the data controller (Article 5/2-f)
Your explicit consent (Article 5/1)
05 Transfer of Personal Data
Your personal data may be shared with the following parties within the framework of KVKK Articles 8 and 9:
Authorized public institutions: When required under a legal obligation
Affiliated companies: For intra-group coordination and operational processes (Mycb Teknoloji, Yirmibir Yapay Zeka, Yirmibir Bilişim, Simutarget Inc.)
Service providers: Website hosting, email service, analytics, and technical infrastructure providers ([relevant providers placeholder])
Yurt dışı aktarımı: Simutarget Inc. (Delaware, USA) iştiraki kapsamında ve KVKK Madde 9 hükümleri çerçevesinde
06 Method of Collection
Your personal data is collected through forms on our website, emails sent directly to us, cookies, and similar automated technologies, on the legal grounds set out in KVKK Articles 5 and 6.
07 Your Rights Under KVKK Article 11
Under KVKK Article 11, you may exercise the following rights by applying to the Data Controller:
To learn whether your personal data is being processed
If processed, to request information about such processing
To learn the purpose of processing and whether the data is used in accordance with that purpose
To know the third parties, domestic or international, to whom your data has been transferred
To request correction of incomplete or inaccurate processing
To request deletion or destruction of your personal data within the conditions set out in KVKK Article 7
To request notification of corrections, deletions, or destructions to third parties to whom your data has been transferred
To object to outcomes adverse to you that arise from analysis of your data exclusively through automated systems
To claim compensation in case of damage suffered due to unlawful processing of your personal data
08 Application
Under KVKK Article 13 and the Communiqué on the Procedures and Principles of Application to the Data Controller, you may submit your rights-related applications through the following channels:
Postal mail: Mithatpaşa Mah. Gazi Paşa Cad. No:74 K:4, Merkez/Zonguldak, Türkiye
Your applications will be concluded within 30 days at the latest, in accordance with KVKK Article 13/2, and the response will be communicated in writing or electronically.