Privacy Notice

This notice explains how we process personal data when you visit imaginers.io or contact the Imaginers studio by e-mail. It is our information notice under article 10 of the Turkish Personal Data Protection Law No. 6698 (KVKK). If you are in the European Union or the European Economic Area, please also read the GDPR section below.

In short

We process very little personal data. Our site has no user accounts, no payments and no advertising or tracking cookies. We count visits with a tool that uses no cookies. We process two kinds of data: the technical data needed to deliver and protect the site, and the information you send us by e-mail. We do not sell personal data, and we do not share it for advertising.

Who is responsible for your data

The data controller is Digimental Teknoloji Anonim Şirketi, the company that operates Imaginers. In this notice, "we" and "us" mean this company.

Registered address: Ayazağa Mah. Kemerburgaz Cad. Bilişim Vadisi 7C Blok No:7D İç Kapı:15, 34485 Sarıyer / İstanbul, Türkiye

E-mail: info@imaginers.io

You can send any question about your personal data to this address.

What we process, why, and on what legal basis

1. When you visit the site

Data: your IP address, the date and time of your visit, the pages and files you request, and the technical information your browser sends with each request. Examples are the browser type, the operating system and the address of the page that linked to us. Our hosting provider may also record whether a request looks automated or harmful.

Purpose: to deliver the pages and videos to your device, to keep the site secure and available, and to detect and block attacks and misuse.

Legal basis: our legitimate interest in running a secure website, under article 5(2)(f) of the KVKK.

How we collect it: by fully automated electronic means, when your browser connects to the site. Cloudflare, our hosting and security provider, records this data in its server logs. Cloudflare may also place a few strictly necessary security cookies. Our Cookie Notice explains them.

Visit statistics: we count visits with Cloudflare Web Analytics. It does not place cookies or similar records on your device and does not build a profile of you. It shows us which pages are viewed, which site or link brought visitors to us, the type of device and browser, the country, and how fast the pages load. We only see totals. The legal basis is our legitimate interest in understanding how the site is used and keeping it fast, under article 5(2)(f) of the KVKK.

2. When you contact us by e-mail or through our contact form

Data: your e-mail address and name, and the company you work for and your role if you share them. We also process the content, attachments, date and time of your message, and any other information you choose to include. If you use the contact form, we also record the page you sent it from.

Purpose: to read and answer your message, to discuss a possible project, and to prepare a proposal or a contract. We also keep business correspondence as the law requires.

Legal bases:

1. Article 5(2)(c) of the KVKK, where the processing is directly related to concluding or performing a contract with you.
2. Article 5(2)(f) of the KVKK, our legitimate interest in answering enquiries. This includes messages you send on behalf of a company.
3. Article 5(2)(ç) of the KVKK, our legal obligation to keep business correspondence under article 82 of the Turkish Commercial Code No. 6102.

How we collect it: from you, by partly automated electronic means, through the e-mail you send us or the contact form on our site. The form delivers your message to us as an e-mail through Cloudflare.

Please do not send us sensitive personal data, such as information about your health.

3. When you exercise your rights

Data: the information in your request. Examples are your name and surname, signature, identity number, address, e-mail address and phone number. We also process the content of your request and our reply.

Purpose: to confirm your identity, to handle and answer your request, and to be able to show that we handled it correctly.

Legal bases: our legal obligation to answer requests under article 13 of the KVKK, under article 5(2)(ç) of the KVKK. Where needed, also the establishment, exercise or protection of a right, under article 5(2)(e) of the KVKK.

How we collect it: from you, through the channel you use for your request.

Who receives your data

We share personal data only with the following groups of recipients, and only for the purposes described above.

1. Cloudflare, Inc., our hosting, content delivery and security provider. Cloudflare processes visit data on our behalf to deliver and protect the site.
2. Our e-mail service providers. They receive, forward and store the e-mails we send and receive on our behalf.
3. Courts, enforcement offices and competent public authorities, when the law requires it, or when we need to establish, exercise or defend a legal claim. In such cases we may also share data with our lawyers.

Under article 8 of the KVKK, these transfers rely on the same legal bases as the processing they serve.

We do not embed content from other platforms on our site. We only link to our pages on Instagram and YouTube. These platforms receive data from you only if you follow such a link. Their own privacy policies then apply.

Transfers outside Türkiye

Cloudflare runs a global network. When you visit the site, a Cloudflare data centre outside Türkiye may handle your request. Cloudflare states that it stores data mainly in the United States and the European Economic Area. Our e-mail service providers may also store messages on servers outside Türkiye. For these reasons, the data described above may be transferred abroad.

Article 9 of the KVKK sets the conditions for such transfers. A transfer is possible if the KVKK Board has made an adequacy decision for the country concerned, or if appropriate safeguards are in place. One such safeguard is a standard contract announced by the KVKK Board and notified to it within five business days of signature. We aim to rely on these safeguards for the transfers described here. We do not ask for your explicit consent to these transfers on the site.

You can ask us at any time which safeguards apply by writing to info@imaginers.io.

How long we keep your data

1. Visit data in Cloudflare's server logs: Cloudflare keeps this data for the periods set in its own policies. If we save an extract of these logs to investigate a security incident, we keep that extract for up to 90 days. We keep it longer only if a legal claim or a request from an authority requires it.
2. Business correspondence, such as messages about a project, a proposal or a contract: 10 years. The period starts at the end of the calendar year in which the message was sent or received. Article 82 of the Turkish Commercial Code requires this.
3. Other messages, such as general questions or comments on our films: 2 years after our last exchange with you.
4. Requests about your rights: 3 years after we close the request.

When a period ends, we delete, destroy or anonymise the data within three months at the latest.

Your rights under the KVKK

You have the rights set out in article 11 of the KVKK. For example, you can learn whether we process your data, ask for information about it, and ask us to correct or delete it. If unlawful processing causes you damage, you can claim compensation.

How to make a request

You can send your request in one of these ways:

1. in writing, with your signature, to our registered address above;
2. by e-mail to info@imaginers.io. Please send it from an e-mail address that you gave us before and that is in our records. You can also sign it with a secure electronic signature or a mobile signature.

Your request should include:

1. your name and surname, and your signature if the request is in writing;
2. your Turkish identity number if you are a citizen of Türkiye, or otherwise your nationality and your passport number or identity number;
3. your home or business address for notifications;
4. your e-mail address, phone number or fax number for notifications, if you have one;
5. what you are asking for.

Please attach any documents that support your request.

The Turkish rules provide that requests are made in Turkish. We will also handle requests written in English.

We answer as soon as possible, and within 30 days at the latest, depending on the nature of the request. Answering is free of charge. Only if the answer involves an extra cost may we charge the fee set by the KVKK Board. If we reject a request, we explain why.

Complaints to the KVKK Board

You can complain to the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu). You can do this if we reject your request, if you find our answer insufficient, or if we do not answer in time. You must complain within 30 days of learning our answer, and in any case within 60 days of the date of your request. Before you complain to the Board, you must first apply to us. You can find more information at kvkk.gov.tr.

Information for visitors in the EU and the EEA (GDPR)

If you are in the European Union or the European Economic Area, the General Data Protection Regulation (GDPR) may apply to our processing of your data. Where it applies, the following information also applies.

Controller: Digimental Teknoloji Anonim Şirketi, with the contact details given above.

Legal bases under the GDPR:

1. Visiting the site: Article 6(1)(f), our legitimate interest in delivering a secure and working website.
2. E-mail enquiries and projects: Article 6(1)(b), where we take steps at your request before a contract or perform a contract with you. Article 6(1)(f), our legitimate interest in answering business enquiries and keeping business records.
3. Requests about your rights: Article 6(1)(c), our legal obligation under the GDPR, and Article 6(1)(f).

Your rights under the GDPR: you can ask for access to your data, and ask us to correct or erase it. You can ask us to restrict its processing, and you can receive your data in a portable format. You can object to processing that is based on our legitimate interest. You can withdraw your consent at any time, without affecting processing that took place before.

Deadline: we answer within one month. For complex requests, we may extend this period by two further months. If we do, we will tell you within the first month and explain why.

Transfers: we are based in Türkiye, outside the EU and the EEA. When you contact us, your data is processed in Türkiye. Cloudflare may process visit data in other countries, including the United States. For data from the European Economic Area, Cloudflare states that it relies on the Data Privacy Framework between the European Union and the United States. Cloudflare also states that it uses the standard contractual clauses of the European Commission.

Automated decisions: we do not make decisions about you based solely on automated processing, including profiling.

Providing data: you do not have to give us any personal data. If you want an answer to your message, we need your e-mail address and the information in your message.

Complaints: you can complain to a data protection authority in the EU or the EEA. This can be the authority where you live or work, or where you think an infringement took place. A list of these authorities is available on the website of the European Data Protection Board.

Security

We take technical and organisational measures to protect personal data against loss, misuse and unauthorised access.

Changes to this notice

We may update this notice when our processing changes. The date at the top shows the current version. If we want to use your data for a new purpose, we will inform you before we start.

Contact

For any question about this notice or your personal data, write to info@imaginers.io.