INTERNATIONAL GDPR (GENERAL DATA PROTECTION REGULATION) AGREEMENT
1. Introduction:
This agreement governs the processing, protection, and management of personal data collected by TURKWISE LLC (hereinafter referred to as "the Company") through its website and associated services, including XP software and related platforms, in compliance with Turkey's Personal Data Protection Law No. 6698 (KVKK) and relevant international data protection regulations.
2. Purpose of the Agreement:
The purpose of this agreement is to ensure that personal data collected from individuals interacting with the Company's services is processed lawfully and transparently, in compliance with applicable laws, and to inform individuals ("Data Subjects") of their rights concerning their personal data.
3. Data Controller:
TURKWISE LLC, located at 112 Capitol Trail Suite A1345, Newark DE 19711, EIN: 37-2152169, is the data controller responsible for the protection of personal data collected via its website (xpsoftware.net) and related services.
4. Personal Data Collected:
The Company collects the following personal data:
Identification information (name, surname)
Contact information (email address, phone number)
Demographic data
Usage data (cookies, IP addresses, location data)
Financial and transactional information for billing purposes
Professional or employment-related information for service agreements.
5. Legal Grounds for Data Processing:
Personal data is processed based on the following legal grounds:
The explicit consent of the Data Subject
Necessity for the performance of a contract
Legal obligations of the data controller
Legitimate interests of the Company (marketing, customer support, etc.)
The establishment, use, or protection of a legal right.
6. Purposes of Data Processing:
Personal data collected by TURKWISE LLC is processed for the following purposes:
To provide, maintain, and improve the Company’s services and products
To fulfill legal and regulatory obligations
To enhance the user experience through personalized content and features
To communicate with users for support, marketing, and customer service purposes
To process payments and manage financial transactions
To improve security measures and prevent fraudulent activity.
7. Transfer of Personal Data:
The Company may transfer personal data to third parties located inside or outside of Turkey, including but not limited to:
Payment service providers
Hosting and IT service providers
Legal and regulatory authorities upon request
Marketing and communication partners.
International transfers of personal data shall be conducted in accordance with the provisions of KVKK, GDPR (for users in the European Union), and other relevant data protection laws.
8. Data Security:
TURKWISE LLC implements appropriate administrative, technical, and physical security measures to protect personal data from unauthorized access, alteration, disclosure, or destruction. These measures include:
Encryption technologies for sensitive data
Firewalls and secure network infrastructure
Regular audits and monitoring of systems
Access control measures, including user authentication and role-based access.
9. Rights of the Data Subject:
Data Subjects have the following rights under KVKK and relevant international laws:
The right to be informed about the processing of their personal data
The right to access their personal data and obtain a copy
The right to request the rectification of inaccurate data
The right to request the deletion or anonymization of personal data (subject to legal retention requirements)
The right to object to the processing of personal data in certain circumstances
The right to withdraw consent for data processing at any time.
Requests concerning these rights should be submitted in writing to privacy@xpsoftware.net or by mail to TURKWISE LLC’s address.
10. Retention Period:
Personal data is retained for as long as necessary to fulfill the purposes outlined in this agreement, or as required by law. Once the purpose of processing is no longer valid, data is either securely deleted or anonymized.
11. Changes to This Agreement:
TURKWISE LLC reserves the right to modify this agreement to reflect changes in the law or operational practices. Updated versions will be posted on the website, and users will be notified accordingly.
12. Governing Law:
This agreement shall be governed by the laws of Turkey, and any disputes arising from this agreement will be resolved by the competent courts of Turkey unless otherwise stipulated by applicable international laws.
13. Contact Information:
For any questions, requests, or concerns regarding this agreement or your personal data, you may contact us at:
TURKWISE LLC
112 Capitol Trail, Suite A1345
Newark, DE 19711
E-mail: privacy@xpsoftware.net
Phone: +90 533 709 72 90
