Privacy Notice on The Processing of Personal Data
Last Updated: September 17, 2026
As WAGONN Bilgi Teknolojileri ve Danışmanlık Limited Şirketi (“WAGONN” or the “Company”), we prioritize the security and confidentiality of your personal data in accordance with the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and relevant data protection legislation.
This Privacy Notice has been prepared in compliance with Article 10 of the KVKK and the Communiqué on Principles and Procedures to Be Followed in Fulfillment of the Obligation to Inform to inform you regarding the purposes, legal grounds, collection methods, transfers, and your statutory rights regarding the processing of personal data collected through our website (wagonn.net), corporate software solutions, and communication channels.
1. Identity of the Data Controller
- Company Name: WAGONN BİLGİ TEKNOLOJİLERİ VE DANIŞMANLIK LİMİTED ŞİRKETİ
- Address: Esentepe Mh. Büyükdere Cd. No: 199/6 Levent 199 Kat: -1 Levent, Şişli, İstanbul, 34330, Türkiye
- Phone: +90 (850) 532 7379
- Email: [email protected] / [email protected]
2. Categories of Processed Personal Data
Depending on your interactions with our website, software products, and service requests, the following categories of personal data may be processed:
- Identity Data: Full name.
- Contact Data: Business email address, phone number, corporate title, and company name.
- Customer Transaction & Request Data: Messages submitted via contact forms, demo and proposal requests, inquiries regarding WAGONN enterprise modules (e.g., Thalamus ERP, Synapse).
- Transaction Security Data: IP address, access logs, date and time stamps, cookie identifiers, and system verification tokens.
3. Purposes and Legal Grounds for Processing Personal Data
Your personal data is processed pursuant to the legal grounds set forth in Article 5 of the KVKK for the following purposes:
| Data Category | Processing Purpose | Legal Basis under KVKK (Article 5) |
|---|---|---|
| Identity, Contact, Inquiry Data | Responding to inquiries submitted via contact/demo forms, preparing commercial proposals, and managing pre-contractual procedures. | Article 5/2-(c): Directly related to the conclusion or performance of a contract. |
| Identity, Contact Data | Managing enterprise customer relations, handling inquiries and feedback, and conducting business development activities. | Article 5/2-(f): Processing is necessary for the legitimate interests of the data controller, provided it does not harm fundamental rights and freedoms. |
| Transaction Security (IP, Logs) | Fulfilling statutory log-retention requirements under Law No. 5651, ensuring network and website security, and detecting potential cyber threats. | Article 5/2-(ç): Necessary for compliance with a legal obligation to which the data controller is subject. |
| Contact, Marketing Data | Sharing updates on new product releases, event invitations, corporate newsletters, and commercial communications (upon explicit consent). | Article 5/1: Explicit Consent (Consent may be withdrawn |
4. Methods of Data Collection
Personal data is collected automatically or semi-automatically through digital channels, including:
- Contact, request, demo, and support forms available on wagonn.net,
- Direct electronic communications via email ([email protected], [email protected]), phone calls, or physical correspondence,
- Strictly necessary, functional, analytical, and marketing cookies utilized across our web platforms.
5. Transfer of Personal Data
Your personal data may be shared in accordance with Articles 8 and 9 of the KVKK exclusively for the purposes specified above with:
- Service Providers & IT Vendors: Third-party partners providing enterprise hosting, cloud infrastructure, cyber security, and technical maintenance services (strictly limited to service fulfillment requirements).
- Authorized Public Institutions: Competent judicial, regulatory, and public authorities to fulfill statutory duties or resolve legal disputes upon formal request.
(Note: In the event third-party cloud infrastructure or cookie providers are located outside Türkiye, transfers are executed pursuant to Article 9 of the KVKK via explicit consent or standard contractual clauses approved by the Personal Data Protection Board).
6. Data Security and Retention
WAGONN implements appropriate technical and organizational measures (including end-to-end encryption, perimeter firewalls, access logs, and role-based privilege matrices) in accordance with Article 12 of the KVKK to prevent unlawful data processing or unauthorized access.
Your personal data is retained only for the duration required to achieve the stated processing purposes or as mandated by statutory limitation periods under Turkish law. Upon expiration of these periods, data is securely erased, destroyed, or anonymized.
7. Rights of the Data Subject under Article 11 of the KVKK
Under Article 11 of the KVKK, you have the right to:
- Learn whether your personal data is being processed,
- Request information if your personal data has been processed,
- Learn the purpose of data processing and whether data is used in accordance with its purpose,
- Know the third parties to whom personal data is transferred domestically or abroad,
- Request rectification of incomplete or inaccurate data,
- Request the deletion or destruction of personal data under the conditions laid down in Article 7 of the KVKK,
- Request notification of rectification, deletion, or destruction operations to third parties to whom data has been transferred,
- Object to results that emerge to your detriment exclusively through automated analysis,
- Claim compensation for damages incurred due to unlawful processing of personal data.
8. Application Procedures
To exercise your statutory rights under the Communiqué on Principles and Procedures for Application to the Data Controller, you may submit your request:
- In Writing: By delivering an application with a wet-ink signature in person or via registered notary public to Esentepe Mh. Büyükdere Cd. No: 199/6 Levent 199 Kat: -1 Levent, Şişli, İstanbul, 34330, Türkiye,
- Electronically: Via email sent from your email address currently registered in our records to [email protected].
Your request will be evaluated and finalized free of charge within 30 (thirty) days at the latest, depending on the nature of the request.