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TEMPLATE DRAFT
This text is a template draft. Before real use it must be reviewed by the responsible person and legal counsel, and the highlighted fields must be filled in. It is not legal advice.
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1. Identity of the data controller
Under Personal Data Protection Law No. 6698 (“KVKK”), the data controller is the person/organisation below. “Elazığ Badem Şekeri” is an informational and storytelling site prepared by the Gacker team for the GakCoding event held in Elazığ on 1 November 2026.
| Item | Value |
|---|---|
| Name / title | [DATA CONTROLLER NAME — FILL IN] |
| Address | [ADDRESS FOR SERVICE — FILL IN] |
| [CONTACT E-MAIL — FILL IN] | |
| Phone | [PHONE — FILL IN] |
| KEP (registered e-mail) | [KEP (REGISTERED E-MAIL) ADDRESS — FILL IN] |
| VERBIS | [VERBIS REGISTRATION NO. / EXEMPTION — FILL IN] |
- Item
- Name / title
- Value
- [DATA CONTROLLER NAME — FILL IN]
- Item
- Address
- Value
- [ADDRESS FOR SERVICE — FILL IN]
- Item
- Value
- [CONTACT E-MAIL — FILL IN]
- Item
- Phone
- Value
- [PHONE — FILL IN]
- Item
- KEP (registered e-mail)
- Value
- [KEP (REGISTERED E-MAIL) ADDRESS — FILL IN]
- Item
- VERBIS
- Value
- [VERBIS REGISTRATION NO. / EXEMPTION — FILL IN]
2. Personal data processed, purposes and legal grounds
The site has no accounts, membership, forms or payments, and collects no data for analytics or advertising. The data processed is listed below.
| Data | Purpose | Legal ground |
|---|---|---|
| Access logs: IP address, date-time, requested page, browser/device information | Serving the site, information security, preventing abuse and excessive requests | KVKK Art. 5/2-f (legitimate interest); Art. 5/2-a where statutory log-retention duties of hosting providers apply |
| Messages you type to the AI assistant and the assistant's replies | Letting the assistant answer your question | KVKK Art. 5/1 (explicit consent; the assistant asks for it on first use). Please do not include personal data in messages. |
| If you e-mail us: e-mail address, your name, message content | Answering and keeping a record of your request | KVKK Art. 5/2-f (legitimate interest); for rights requests Art. 5/2-ç (legal obligation) |
| Producer (business) details: name, address, contact, web/social links | Presenting local producers and helping visitors reach them | The producer's written approval / explicit consent (KVKK Art. 5/1); information about legal entities is not personal data |
- Data
- Access logs: IP address, date-time, requested page, browser/device information
- Purpose
- Serving the site, information security, preventing abuse and excessive requests
- Legal ground
- KVKK Art. 5/2-f (legitimate interest); Art. 5/2-a where statutory log-retention duties of hosting providers apply
- Data
- Messages you type to the AI assistant and the assistant's replies
- Purpose
- Letting the assistant answer your question
- Legal ground
- KVKK Art. 5/1 (explicit consent; the assistant asks for it on first use). Please do not include personal data in messages.
- Data
- If you e-mail us: e-mail address, your name, message content
- Purpose
- Answering and keeping a record of your request
- Legal ground
- KVKK Art. 5/2-f (legitimate interest); for rights requests Art. 5/2-ç (legal obligation)
- Data
- Producer (business) details: name, address, contact, web/social links
- Purpose
- Presenting local producers and helping visitors reach them
- Legal ground
- The producer's written approval / explicit consent (KVKK Art. 5/1); information about legal entities is not personal data
Your theme, music and notice preferences and your assistant conversation history are kept only in your own browser storage and are not sent to us. See Cookies and Similar Technologies Policy for details.
3. Recipients of personal data and purposes of transfer
- Hosting provider: [HOSTING PROVIDER NAME — FILL IN] (server location: [SERVER LOCATION (COUNTRY) — FILL IN]). Purpose: publishing the site and keeping access logs. The provider acts as a data processor.
- AI (LLM) service provider: [AI (LLM) PROVIDER NAME — FILL IN] (processing country: [LLM PROCESSING COUNTRY — FILL IN]). Purpose: generating replies to the messages you type to the assistant. Only after you consent to the assistant are your messages and conversation context sent to this provider.
- Competent public authorities: where required by applicable law, under KVKK Art. 8 and limited to the scope of the request.
Your data is not sold and not shared with third parties for advertising.
4. Transfer abroad (KVKK Art. 9)
The AI service provider's servers may be outside Türkiye. In that case the messages you type to the assistant are transferred abroad in line with KVKK Art. 9. The transfer relies on an adequacy decision of the Personal Data Protection Board or, if none exists, on appropriate safeguards. Safeguard used on this site: [CROSS-BORDER TRANSFER SAFEGUARD — FILL IN].
The provider's policy on retaining messages and using them for model training: [LLM PROVIDER RETENTION / TRAINING POLICY — FILL IN]. If you do not want your messages transferred abroad, do not use the assistant; the rest of the site works without it.
5. Method of collection and legal ground
Your data is collected wholly or partly by automated means, electronically: through server access logs when you visit, when you type into the assistant, and when you contact us by e-mail. Legal grounds are shown in the table in section 2. Where processing relies on explicit consent you may withdraw it at any time; withdrawal does not affect the lawfulness of earlier processing.
6. Retention
- Access logs: at most [ACCESS LOG RETENTION PERIOD — FILL IN] at the hosting provider.
- Assistant messages: not stored permanently on the site's server; the conversation history stays in your browser's session storage until the tab is closed. For retention at the provider see section 4.
- E-mail correspondence: for the time needed to resolve the request and within limitation periods; afterwards deleted, destroyed or anonymised.
7. Your rights as a data subject (KVKK Art. 11)
Under KVKK Art. 11 you may apply to the data controller to:
- learn whether your personal data is processed,
- request information if it has been processed,
- learn the purpose of processing and whether it is used accordingly,
- know the third parties in Türkiye or abroad to whom data is transferred,
- request correction if data is incomplete or inaccurate,
- request deletion or destruction under the conditions in KVKK Art. 7,
- request that correction and deletion/destruction be notified to third parties to whom data was transferred,
- object to a result against you arising from analysis exclusively by automated systems,
- claim compensation if you suffer damage due to unlawful processing.
8. How to apply
You may send your requests in writing, in line with the “Communiqué on Procedures and Principles of Application to the Data Controller”, with a document identifying you, to the controller's address by hand or via notary; or to [CONTACT E-MAIL — FILL IN] via the KEP address ([KEP (REGISTERED E-MAIL) ADDRESS — FILL IN]), a secure electronic signature or mobile signature, or from the e-mail address you previously gave the controller.
Your application is concluded as soon as possible and at the latest within thirty days, depending on the nature of the request. If the process requires an extra cost, the tariff set by the Board may apply. If you find the reply insufficient or receive none in time, you may complain to the Personal Data Protection Authority within the periods stated in legislation.
Note on children: we do not knowingly collect personal data from people under 18. We recommend that minors use the site and assistant together with a parent/guardian. See Privacy Policy.