Privacy Policy
This document explains how personal data processed through the RTMPlatform website and the RTMPlatform mobile app is handled by GrowthPulse Analitik Çözümler Ltd. Şti., the legal entity behind the product.
Contents
- 1. Data Controller
- 2. Data Collection and Processing Purposes
- 3. Service Providers
- 4. International Data Transfer
- 5. Legal Basis for Processing
- 6. Data Retention Periods
- 7. Your Rights as a Data Subject (KVKK Art. 11)
- 8. How to Submit a Request
- 9. Withdrawing Your Consent
- 10. Data Security Measures
- 11. Cookies
- 12. RTMPlatform Mobile App
- 13. Contact and Complaints
1. Data Controller
RTMPlatform is a product operated by GrowthPulse Analitik Çözümler Yazılım ve Yönetim Danışmanlığı Ltd. Şti., the legal data controller under Turkey's KVKK (Law No. 6698 on the Protection of Personal Data).
Controller Details:
- Legal name: GrowthPulse Analitik Çözümler Yazılım ve Yönetim Danışmanlığı Ltd. Şti.
- Address: Yenişehir Mah. Ankara Cad. No:403/1, 34912 Pendik/İstanbul, Türkiye
- Phone: +90 (216) 218 00 90
- Mersis No: 0411115787200001
- General email: info@growthpulse.com.tr
- Website: www.growthpulse.com.tr
- KVKK Officer: Cemil Bilgiç
- KVKK contact: kvkk@growthpulse.com.tr
2. Data Collection and Processing Purposes
We collect personal data through the following channels on the RTMPlatform website (for the mobile app, see Section 12):
Demo Request Form
Data collected
- • Name and surname
- • Work email address
- • Company name
- • Role or job title
- • Company size
- • Country
- • Modules of interest
- • Free-text message
- • Consent status
- • IP address and cookie identifiers
Purpose
- • Scheduling personalized product demos
- • Evaluating fit between the platform and the requester's operation
- • Preparing scope and pricing proposals
- • Statistical analysis of inquiry patterns
Retention: Form submission date + 2 years; for requests that lead to a sales conversation, 3 years after that conversation ends
Email Communication
Data collected
- • Email address
- • Name and title
- • Email body and attachments
- • Send and receive timestamps
Purpose
- • Formal communication and information exchange
- • Proposal and contract delivery
- • Project coordination
- • Invoicing and payment notifications
Retention: Last communication + 3 years (commercial records kept for 10 years per Turkish Commercial Code)
3. Service Providers
We work with the following service providers to run the website and respond to your requests.
Providers
- • Google Cloud (website hosting)
- • EmailJS (delivery of the demo request form to us by email)
- • Google Analytics and Google Tag Manager (site usage statistics, only with your cookie consent)
Data Shared
- • Information you enter in the demo request form (EmailJS)
- • Connection details such as IP address and browser type (Google Cloud)
- • Cookie identifiers and page view data (Google Analytics, with your consent)
Safeguards
- • All transfers occur over encrypted connections (TLS)
- • Providers process data only to deliver their service to us
- • We do not process form submissions with AI systems and do not share them for model training
4. International Data Transfer
To provide our services, some personal data is transferred outside Turkey to the following regions:
- • European Union (Google Cloud, Microsoft Azure West Europe)
- • United States (Google Analytics, only with your cookie consent)
- • EmailJS (delivery of the demo request form; servers outside Turkey)
Data collected
- • Demo request form content
- • Email correspondence
- • Connection and cookie data
Transfers are made under KVKK Article 9 on the basis of the data subject's explicit consent, and via Data Processing Agreements aligned with GDPR Standard Contractual Clauses (SCC) where applicable. For US providers, the EU-US Data Privacy Framework applies where adhered to by the provider.
All transfers occur over encrypted channels. Recipients are bound by contractual commitments not to sub-transfer data or use it for unauthorized purposes.
If you do not consent to international data transfer, contact us at kvkk@growthpulse.com.tr to request alternative handling.
5. Legal Basis for Processing
Personal data is processed under the following legal bases defined in KVKK Articles 5 and 6:
Explicit Consent (KVKK Art. 5/1-a, Art. 6/2)
Processing of demo request form data, international data transfer, and analytics cookies.
Performance of Contract (KVKK Art. 5/2-c)
Contract execution, project delivery, invoicing, and payment processing for customers.
Legal Obligation (KVKK Art. 5/2-ç)
Tax and commercial record retention (10 years under Turkish Tax Procedure Code and Commercial Code).
Legitimate Interest (KVKK Art. 5/2-f)
Customer relationship management, service quality measurement, statistical analysis, and security monitoring — provided these do not infringe on fundamental rights.
6. Data Retention Periods
We retain personal data only for as long as necessary for the purposes described above or as required by law.
| Data collected | Retention | Purpose |
|---|---|---|
| Demo request form data | Submission date + 2 years; for requests that lead to a sales conversation, 3 years after that conversation ends | Explicit consent |
| Active customer data | Contract duration + 3 years | Contract, legitimate interest |
| Email correspondence | Last email + 3 years | Consent, contract |
| Commercial documents | Issue date + 10 years | Turkish Commercial Code Art. 82 |
| Financial documents (invoices, etc.) | Issue date + 10 years | Tax Procedure Code Art. 253 |
After the retention period, data is securely destroyed. Backup systems are also purged on a mandated schedule. Destruction is logged, and you may request confirmation.
7. Your Rights as a Data Subject (KVKK Art. 11)
Under KVKK Article 11, you have the following rights regarding your personal data:
Right to Information
Learn whether your personal data is being processed, for what purpose, whether it has been transferred internationally, and how long it is kept.
Right to Rectification
Request correction of inaccurate data or completion of incomplete data. Rectification is free and processed within 30 days.
Right to Erasure
Request deletion or anonymization of your data when processing purpose no longer applies, retention period has ended, or consent has been withdrawn (subject to legal retention obligations).
Right to Object
Object to marketing activities or international data transfer. Processing will stop where no overriding legal obligation exists.
Right to Compensation
Claim compensation for damages resulting from KVKK-violating processing, and file a complaint with the Turkish Personal Data Protection Authority (KVKK).
8. How to Submit a Request
You can exercise your rights by submitting a request through the following channels:
Send from your registered email address to kvkk@growthpulse.com.tr
Postal Mail
GrowthPulse Analitik Çözümler Ltd. Şti. — KVKK Başvuruları — Cemil Bilgiç, Yenişehir Mah. Ankara Cad. No:403/1, 34912 Pendik/İstanbul, Türkiye
In person
At the above address, by appointment
Phone (information only)
+90 (216) 218 00 90 — for information about the process; formal applications must be submitted in writing
Your request must include: Turkish ID (TCKN) and a copy for identity verification, signed request letter, contact details (address, email, phone), and the specific request type (information, correction, deletion, objection, etc.).
Processing timeline:
- Acknowledgement of receipt: within 5 business days
- Identity verification: within 5 business days
- Response: within 30 days (KVKK legal maximum)
- Response method: written or electronic, as you prefer
9. Withdrawing Your Consent
You may withdraw any consent you have previously given at any time. Withdrawal methods:
Email: Send a message titled 'CONSENT WITHDRAWAL' to kvkk@growthpulse.com.tr including your full name, Turkish ID number, registered phone, registered email, and the scope of consent you wish to withdraw.
Phone: Call +90 (216) 218 00 90 (identity verification required)
Written request: Postal mail to the address above
Effect of withdrawal: Processing based on that consent will stop (unless a legal obligation requires continued processing). Marketing communications will cease. Data already collected will be deleted at the end of applicable retention periods.
Exceptions: Data required for ongoing contractual relationships, legal retention obligations (tax and commercial records for 10 years), and active legal proceedings cannot be deleted until the obligation ends.
10. Data Security Measures
Technical Measures
- • TLS/SSL encryption for all data transfers
- • Encrypted storage for databases and backups
- • Role-based access control with multi-factor authentication
- • Access logs reviewed periodically
- • Firewall and monitoring systems protecting infrastructure
- • Regular vulnerability assessments
- • Scheduled backups stored in secure environments
Administrative Measures
- • KVKK training for all personnel
- • Signed confidentiality undertakings
- • Regular security awareness training
- • Written data processing and retention policies
- • Incident response procedure
- • Periodic internal KVKK compliance audits
In case of a data breach: The Turkish Personal Data Protection Authority (KVKK) will be notified within the legally prescribed timeline. Affected individuals will be notified as soon as reasonably possible with details of the breach, data categories affected, measures taken, and recommended mitigations.
12. RTMPlatform Mobile App
Who this section is for. The RTMPlatform mobile app is for field staff of companies that use RTMPlatform. You cannot create an account in the app; your account is created by the company you work for, and you connect to the app with the address your company gives you.
Roles. For employee data processed in the app, the data controller is the company that created your account. GrowthPulse processes this data as a data processor, under its contract with that company and on its instructions. Please send requests about your data to your company first; we forward any request we receive to your company. The app's error reports (described below) are processed by GrowthPulse to keep the service reliable.
Data the app processes.
- Account details: your username and password, to sign you in. Session information is kept in your device's secure storage.
- Device details: a random installation number the app generates on first launch, your device's name and model, its operating system version, and the app version. These are used for session security and troubleshooting. The app does not read your device's hardware identifier or advertising identifier.
- Camera: used only when you take a photo for a survey question or scan a barcode. The photo you take is sent to your company's system as part of your answer. The app does not access your photo library and does not record audio.
- Location: collected only while the app is open, and only at the moment of a record (starting a task, completing a task or survey). It is attached to the record to show that the visit took place on site. The app does not track your location in the background and does not keep a route history.
- Work records: the surveys you answer, the tasks you complete, and when you did so.
- Error reports: if the app closes unexpectedly, the technical details of the error, your device model, operating system version, and app version are recorded. These reports are used to fix the error; your username, photos, and location are not added to them.
What the app does not do. It does not access your contacts, photo library, or microphone. It does not show advertising. It does not track you across other companies' apps or websites. It does not sell your data.
Where data is kept and who it is shared with.
- Account, device, photo, location, and work records are kept on RTMPlatform servers dedicated to your company and are not mixed with other customers' data. The country where these servers are located is set in the contract with your company and can be chosen to meet your company's requirements.
- Error reports are kept on servers in the European Union (Germany) operated by our error-monitoring provider, Sentry (Functional Software, Inc.).
- App updates are delivered through the Apple App Store and Expo (650 Industries, Inc., United States); when the app checks for updates, these providers see technical connection details such as your IP address.
- Data processed in the mobile app is not sent to AI providers.
Retention. Your company decides how long account, photo, location, and work records are kept; when the contract ends, the data is deleted or returned to your company within the period set in the contract. Error reports are deleted after 90 days at most. Records waiting on your device while you are offline are removed from the device once they are sent; uninstalling the app removes all app data from your device.
Managing permissions. You can turn off camera and location access at any time in your device's Settings. With a permission turned off, you may not be able to complete tasks that require a photo or location; the rest of the app keeps working.
Deleting your account and data. Your account is created and closed by your company. You can ask your company's administrator to close your account or delete your data. If you cannot reach your company, write to kvkk@growthpulse.com.tr; we will pass your request to your company and tell you the outcome.
Children. The app is for business use and is not directed at anyone under 18.
Your rights. The rights and request channels in Sections 7 and 8 of this policy also apply to the mobile app.
13. Contact and Complaints
For any KVKK-related inquiry, complaint, or rights request, contact us:
Email: kvkk@growthpulse.com.tr
Phone: +90 (216) 218 00 90 (Monday–Friday, 09:00–18:00 TRT)
Postal Mail: GrowthPulse Analitik Çözümler Ltd. Şti., KVKK Başvuruları — Cemil Bilgiç, Yenişehir Mah. Ankara Cad. No:403/1, 34912 Pendik/İstanbul, Türkiye
Filing a complaint with KVKK Authority: If you believe your rights have been violated, you may file a complaint with the Turkish Personal Data Protection Authority after first applying to us. If we reject your request or fail to respond within 30 days, you have 60 days from that point to file with the Authority.
KVKK Authority:
- Online: https://kvkk.gov.tr
- Address: Kişisel Verileri Koruma Kurumu, Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No:4, 06520 Balgat–Çankaya/Ankara, Türkiye