Privacy Policy
This document explains how personal data collected through the RTMPlatform website is processed by GrowthPulse Analitik Çözümler Ltd. Şti., the legal entity behind the product.
Contents
- 1. Data Controller
- 2. Data Collection and Processing Purposes
- 3. AI-Assisted Data Processing
- 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. 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:
Contact Form
Data collected
- • Name and surname
- • Work email address
- • Phone number (optional)
- • Company/organization name
- • Role or job title
- • Message content
- • IP address and cookie identifiers
Purpose
- • Establishing initial contact
- • Evaluating service requests
- • Preparing responses and proposals
- • Following up with interested parties
Retention: Form submission date + 2 years
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 qualified leads, retention may extend until the sales relationship ends + 3 years)
Email Communication
Data collected
- • Email address
- • Name and title
- • Email body and attachments
- • Send and receive timestamps
- • Email open and click tracking (where enabled)
Purpose
- • Formal communication and information exchange
- • Proposal and contract delivery
- • Project coordination
- • Invoicing and payment notifications
- • Newsletter delivery (with separate consent)
Retention: Last communication + 3 years (commercial records kept for 10 years per Turkish Commercial Code)
Note on future communication channels: If we add WhatsApp, phone support, or call recording in the future, this policy will be updated with a clear notice. You will be re-informed and asked for fresh consent where legally required.
3. AI-Assisted Data Processing
We use AI systems to improve response quality and internal operations. These systems process data submitted through our forms.
AI Systems Used
- • OpenAI GPT (language model, response drafting)
- • Google Gemini (language model, classification)
- • Standard OCR tools (if invoice or document uploads are added later)
Scope of AI Processing
- • Contact form and demo form message content
- • Inquiry classification and intent analysis
- • Sentiment analysis for quality measurement
- • Summary generation for internal handoff
Safeguards
- • Personal data is anonymized before AI processing where feasible
- • We only use AI providers under contracts with appropriate data processing terms
- • AI provider retention and model-training policies are reviewed at the time of integration; we prefer providers that do not use our data for model training
- • All data transfers to AI providers occur over encrypted connections (TLS/SSL)
- • Credit card numbers, passwords, national ID numbers, and health data are never sent to AI providers
4. International Data Transfer
To provide our services, some personal data is transferred outside Turkey to the following regions:
- • United States (OpenAI, Google)
- • European Union (Google Cloud, Microsoft Azure West Europe)
Data collected
- • Form submission content
- • Email content processed by AI
- • Contact metadata
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, certain AI-assisted features of our response process may be limited. You may still contact us via email 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)
AI-assisted processing of inquiries, international data transfer, marketing communications, and newsletter subscriptions.
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 | Explicit consent |
| Contact form data | Submission date + 2 years | 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 |
| AI processing logs | 30 days after processing | Technical necessity |
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, which systems (including AI) use it, 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 automated profiling, marketing activities, AI-based processing, 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. New AI processing will not occur. 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. 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