Privacy Policy

Last updated: October 7, 2026

This policy explains how your personal data is processed when you visit ginocompany.com and when you contact us. It is our privacy notice under Türkiye’s Personal Data Protection Law No. 6698 (“KVKK”) and also includes the information required by the General Data Protection Regulation (“GDPR”) for visitors in the European Union.

1. Data controller

Gino Danışmanlık İsa Öğülener (“Gino Company”)
Esentepe Mah., Talatpaşa Cad. No:5, Kolektif House Levent, 34394 Şişli / Istanbul, Türkiye
Email: [email protected] · Phone: +90 545 185 22 25

2. Personal data we process

• Contact form: your full name, email address, the service you select and the information you share in your message; optionally, your company name, phone number and how you heard about us. If you opened the form from a package’s “Get a quote” button, that package is also sent with the form; if you came to the site through an ad or campaign link, the campaign information in that link (source, campaign and ad name) is sent as well.
• Email, phone and WhatsApp: your contact details and the content of the conversation when you write to us or call us. If you came to the site through an ad link, a short campaign code is added to the end of the prefilled message of the site’s WhatsApp button; you can see it and delete it before sending.
• Technical logs: when you access the site, your IP address, browser and device information, the requested page and the date and time. These logs are kept automatically by the site’s hosting and security service providers.
• Cookies and similar technologies (only with your consent): the pages you visit, where you came from, your device and browser information, your IP address, cookie identifiers and your actions on the site (such as sending the form or clicking a WhatsApp, phone or email link).

The required fields in the form (full name, email, what you need and your message) are necessary for us to respond to your request; without them we cannot get back to you. We do not ask for special categories of personal data (such as health, religious or biometric data); please do not share them in the form or in your messages. Analytics and marketing cookies only run if you consent through the cookie banner on the site; see our Cookie Policy for details.

3. Purposes and legal bases

• Responding to your request, preparing a quote and communicating with you: steps prior to entering into a contract and our legitimate interest (KVKK Art. 5(2)(c) and 5(2)(f); GDPR Art. 6(1)(b) and 6(1)(f)).
• Using your optional answer on the form about how you heard about us, together with campaign information (the campaign information sent with the form and the campaign code in the WhatsApp message), to assess which of our marketing channels and ads work: our legitimate interest (KVKK Art. 5(2)(f); GDPR Art. 6(1)(f)).
• If a contract is concluded, carrying out the project, invoicing and legal obligations: performance of the contract and our legal obligations (KVKK Art. 5(2)(c) and 5(2)(ç); GDPR Art. 6(1)(b) and 6(1)(c)).
• Keeping the site secure and operational: our legitimate interest (KVKK Art. 5(2)(f); GDPR Art. 6(1)(f)).
• Establishing, exercising or defending legal claims: KVKK Art. 5(2)(e); GDPR Art. 6(1)(f).
• Keeping visit statistics, measuring the results of our ads and showing you relevant ads (analytics and marketing cookies): your explicit consent (KVKK Art. 5(1); GDPR Art. 6(1)(a)). You can withdraw your consent at any time via “Cookie settings” at the bottom of every page; withdrawing it does not affect the lawfulness of processing carried out before then.

Apart from analytics and marketing cookies, none of the processing described here is based on your consent. If we ever need to carry out other processing that requires your explicit consent (such as marketing messages), we will ask for it separately in advance. We do not make automated decisions about you; if you consent to marketing cookies, Google and Meta may use this data in their own systems when choosing which ads to show you.

4. How we collect data

We collect personal data electronically: directly from you through the contact form, email, phone and WhatsApp, and automatically through technical logs and, if you have consented, cookies when you visit the site.

5. Recipients and transfers

We may share your personal data with the following recipients, only to the extent necessary for the purposes above:

• service providers we use for the hosting, content delivery and security of the site and for email (processors that handle data on our behalf and on our instructions);
• if you have consented to analytics and marketing cookies, Google and Meta, which provide these services (these companies may also process the data under their own privacy policies);
• if a contract is concluded, our accountant, for invoicing and legal obligations;
• competent public authorities, where required by law.

Some of our service providers have servers outside Türkiye (for example, the Cloudflare network through which the site is delivered and, if you have consented, Google and Meta), so your data may be transferred abroad.

6. Retention

We keep your data for as long as the purpose of processing requires. Contact and quote requests that do not lead to a contract are kept for 2 years after the request is closed. If a contract is concluded, data is kept for the term of the contract and for the periods required by law (for example, 10 years for commercial books and records). Technical logs are limited to the service providers’ short retention periods for security purposes. When the period ends, your data is deleted, destroyed or anonymized. How long cookies stay in your browser is set out in our Cookie Policy; data sent to Google and Meta is subject to these services’ retention periods.

7. Your rights

Under Article 11 of the KVKK, you can apply to us to exercise the following rights:

• To learn whether your personal data is processed
• To request information about the processing if it is
• To learn the purpose of processing and whether the data is used in line with that purpose
• To know the third parties in Türkiye or abroad to whom your data is transferred
• To request correction if your data is incomplete or inaccurate
• To request erasure or destruction of your data under the conditions of Article 7 of the KVKK
• To request that any correction, erasure or destruction be notified to the third parties to whom your data was transferred
• To object to a result against you arising from the analysis of your data exclusively by automated systems
• To claim compensation if you suffer damage due to unlawful processing

8. How to apply

You can send your requests in writing to our address above, or by email to [email protected] from the email address you previously gave us and that is registered in our records, together with information that allows us to verify your identity. We will respond free of charge within 30 days at the latest; if the request involves an additional cost, a fee may be charged according to the tariff set by the Personal Data Protection Board. If your application is rejected, you find the response insufficient, or we do not respond in time, you may file a complaint with the Personal Data Protection Board.

9. Visitors in the European Union (GDPR)

If you are in the European Union, under the GDPR you have the right to access your personal data, to request its rectification, erasure or the restriction of its processing, to data portability, to object to processing based on legitimate interests, and to withdraw your consent at any time where processing is based on consent. To exercise these rights, write to [email protected]. You may also lodge a complaint with the data protection supervisory authority in your EU member state. Gino Company is established in Türkiye; data you send us is processed in Türkiye.

10. Links and the map

When you click links to WhatsApp, LinkedIn, Instagram, Facebook, the App Store or Google Play, the privacy policy of that platform applies. The map on our Contact page is loaded from OpenStreetMap only when you select “Show map”; at that point your IP address is sent to the servers of the OpenStreetMap Foundation.

11. Changes

We may update this policy when needed. The current version is always published on this page; the date at the top shows the last update.