Website Privacy Notice

This is the privacy notice on the processing of your personal data on the fonify.co website, issued under the Turkish Personal Data Protection Law No. 6698 (KVKK). Where the General Data Protection Regulation (GDPR) applies to you, it also serves as our Article 13 disclosure.

Fonify (Defsoft Bilişim Teknolojileri Anonim Şirketi) is referred to below as "Fonify" or the "Company".

As Defsoft Bilişim Teknolojileri Anonim Şirketi (the "Company"), acting as data controller under the Turkish Personal Data Protection Law No. 6698 (the "Law"), we process your personal data on the fonify.co website (the "Website") within the framework described below.

This notice is prepared to fulfil our obligation under Article 10 of the Law and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform.

• Legal name: Defsoft Bilişim Teknolojileri Anonim Şirketi
• Address: Üniversiteler Mah. İhsan Doğramacı Bul. No: 31 İç Kapı No: 24 Çankaya/Ankara, Türkiye
• MERSIS: 0272118846700001
• Tax office / Tax no: Doğanbey Tax Office / 2721188467
• Email: [email protected]
• Contact point: [email protected]

A separate privacy notice is published for the personal data processing carried out within the Fonify application (app.fonify.co). This notice covers the fonify.co website only.

The following categories of personal data are processed on our Website:

• Device and access data: IP address, browser type and version (userAgent), operating system, device type, language preference
• Usage data: page views, session duration, click data, pages visited, visit count and first-visit information
• Interaction records: heatmap and session replay data collected through Microsoft Clarity (mouse movement, clicks, and in-page navigation; text you type into form fields is masked)
• Location data: approximate geographic location derived from the IP address (country level)
• Attribution data: campaign parameters, referring site address, and landing page recording which channel brought you to our site
• Cookie data: cookie identifiers and the preference recorded when you answer the cookie notice (see our Cookie Policy for details)

Personal data collected through the contact, demo request, plan wizard, and partnership application forms is covered by a separate Form Privacy Notice.

Your personal data is collected through the following automated methods:

• Cookies and your browser's local storage (see our Cookie Policy for details)
• Usage statistics collected through Google Analytics 4
• Heatmap and session replay data collected through Microsoft Clarity
• Server access logs: HTTP access information recorded automatically by our hosting infrastructure (IP address, access time, HTTP header information)
• Visit measurement request: an automated record containing the page address, browser information, and visit count, sent once every twenty-four hours per browser

Your personal data is processed for the following purposes and on the following legal grounds:

• Device and access data (server logs): recording traffic information under Turkish Law No. 5651 on the Regulation of Publications on the Internet. Legal obligation (Art. 5/2-ç)
• Device and access data: securing the website, preventing abuse and automated attacks, applying rate limiting. Legitimate interest (Art. 5/2-f)
• Usage data and interaction records: monitoring website performance, detecting errors, and improving the user experience. Legitimate interest (Art. 5/2-f)
• Attribution data: measuring which channel our marketing activity produces results through. Legitimate interest (Art. 5/2-f)
• Cookie data: storing your cookie and language preferences and securing form submissions. Legitimate interest (Art. 5/2-f)

You can decline non-essential cookies through the Reject option in the cookie notice bar on our site, or through your browser settings. If you decline, Google Analytics and Microsoft Clarity measurement will not run in your browser.

Domestic transfers:

• Authorised public authorities: device and access data, where information and documents must be provided under applicable legislation. (Art. 8/2-a, Art. 5/2-ç)

International transfers:

Our Website's hosting and measurement infrastructure runs on service providers located outside Türkiye. The following data is therefore transferred abroad:

• Vercel Inc. (USA): hosting and content delivery infrastructure. Device and access data and server access logs are processed on this infrastructure.
• Google Ireland Limited: usage data within Google Analytics 4.
• Microsoft Corporation (USA): interaction records within Microsoft Clarity.

These transfers are carried out within the framework of Article 9 of the Law. You can prevent the Google Analytics and Microsoft Clarity transfers from taking place by using the Reject option in the cookie notice bar.

Under Article 11 of the Law, you have the following rights as a data subject:

• a) to learn whether your personal data is processed
• b) to request information if your personal data has been processed
• c) to learn the purpose of processing and whether the data is used in accordance with that purpose
• ç) to know the third parties, in Türkiye or abroad, to whom your personal data is transferred
• d) to request rectification if your personal data is processed incompletely or inaccurately
• e) to request erasure or destruction of your personal data under Article 7 of the Law
• f) to request that operations carried out under (d) and (e) be notified to third parties to whom your data has been transferred
• g) to object to a result to your detriment arising from analysis of your data exclusively by automated systems
• ğ) to claim compensation for damage arising from unlawful processing of your personal data

Where the GDPR applies, you also hold the corresponding rights of access, rectification, erasure, restriction of processing, data portability, and objection.

You can submit requests relating to the rights above through the following methods:

a) By email: from your registered email address, or with a secure electronic or mobile signature, to [email protected].

b) In writing: in person or through a notary, together with documents establishing your identity, to the following address:

Üniversiteler Mah. İhsan Doğramacı Bul. No: 31 İç Kapı No: 24 Çankaya/Ankara, Türkiye

Your application will be concluded free of charge as soon as possible and within thirty (30) days at the latest, depending on its nature. Where the process incurs an additional cost, the fee set out in the tariff determined by the Personal Data Protection Board may be charged.

Your application must contain the following:

• Full name, and signature if the application is in writing
• Turkish ID number for citizens of the Republic of Türkiye; nationality, passport number, or identification number if any, for foreign nationals
• Residential or business address for service of notice
• Email address, telephone, and fax number for notification, if any
• Subject of the request

You can also use the form on the Data Deletion Request page to request erasure of your data.

Cookies and similar technologies are used on our Website. For detailed information about our use of cookies, see our Cookie Policy.

This notice may be updated in line with legal developments or changes in our data processing activities. The current text is always published at fonify.co/en/legal.