This English version is provided for convenience only. The Turkish text is the legally binding version; in the event of any discrepancy, the Turkish text prevails.
1. Data controller
Under Turkish Law No. 6698 on the Protection of Personal Data ("KVKK"), your personal data are processed by Incasso Mentor Enformasyon ve Danışmanlık Hizmetleri Anonim Şirketi (Adalet Mah. Manas Blv. Folkart Towers A Kule No: 47 B, İç Kapı No: 3509, Bayraklı / İzmir, Türkiye; e-mail info@incassomentor.com; KEP [KEP adresi — aanvullen]) as data controller, to the extent described below. This notice is issued pursuant to Article 10 of the KVKK and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform.
2. Whose data do we process?
- Customer representatives and staff: individuals who complete request forms, correspond with us or sign the agreement.
- Third-party contact persons: officers and contact persons of debtor or buyer companies passed to us by our customers. We receive these data from our customer, who is responsible for its own information obligations towards those persons.
- Persons in data lists: officers of European companies listed by virtue of their function, compiled from public trade registers and credit information sources.
- Website visitors: technical data kept only in server logs (see the Cookie Policy).
3. Categories of personal data
| Identity | Name, surname, title / role |
|---|---|
| Contact | E-mail, telephone, business address, city |
| Customer transaction | Content of the request, service type and package chosen, correspondence, pro forma and invoice details, messages |
| Finance | Invoice amounts, due dates and payment details, receivable details in a collection file (company data, but personal data in the case of sole traders) |
| Legal transaction | Dispute status in a collection file, contracts and correspondence, powers of attorney |
| Transaction security | IP address, browser details, time of transaction, system logs, form submission ID |
| Document content | Personal data contained in invoices, shipping documents and correspondence uploaded with a request |
We do not request special categories of personal data (KVKK Art. 6); please ensure that documents you send us do not contain such data.
4. Purposes and legal bases
| Purpose | Legal basis (KVKK Art. 5(2)) |
|---|---|
| Receiving the request, preparing a quotation, concluding and performing the contract (report, monitoring, collection, list) | (c) Necessary for the conclusion or performance of a contract |
| Invoicing, accounting and tax records, keeping commercial books | (ç) Compliance with a legal obligation (Tax Procedure Law, Commercial Code) |
| Retaining correspondence, exercising rights in the event of a dispute | (e) Establishment, exercise or protection of a right |
| Information security, prevention of abuse and fake requests, server logs | (f) Legitimate interests of the data controller |
| Service information and commercial electronic messages to existing business customers | (f) Legitimate interests; Law No. 6563 Art. 6(2) — right to opt out reserved |
| Transfer to infrastructure and service partners abroad | KVKK Art. 9 — safeguards described in section 5 and/or explicit consent |
5. Transfers of personal data
5.1 Within Türkiye
Your data may be transferred, within our legal obligations, to our accountant, our legal advisers and, on request, to competent public authorities (courts, tax office, Personal Data Protection Board).
5.2 Abroad
By the nature of our services (information on, and collection from, companies in Europe), your data are transferred abroad:
| Recipient | Country / region — purpose |
|---|---|
| Cloud database and application infrastructure | European Union (Ireland) — storage of request forms and customer records |
| E-mail sending and receiving infrastructure | European Union / United States — delivery of notifications and correspondence |
| Credit information source | European Union / United Kingdom — identification of the company enquired about for reports and monitoring; the identity of the enquiring customer is not passed to the source |
| Collection partners and law firms | Country of the debtor — handling of the collection file (name and contact details of the creditor's representative, debtor contact persons, documents) |
Transfers abroad are made pursuant to Article 9 of the KVKK: to countries for which the Personal Data Protection Board has issued an adequacy decision; otherwise under appropriate safeguards such as the standard contract published by the Board or binding undertakings; and, in occasional cases where these are not available, on the basis of your explicit consent. The consent box on the request form covers this explicit consent. You may withdraw your consent at any time; withdrawal does not affect the lawfulness of processing carried out before it and may make performance of the service impossible.
6. Method of collection
Your personal data are collected by automated and partly automated means through the request forms on the site, e-mail and telephone correspondence, documents you upload, credit information sources and public trade registers. The site uses no cookies or tracking tools.
7. Retention periods
- Contract and invoice records: 10 years under Article 82 of the Commercial Code and Article 253 of the Tax Procedure Law.
- Collection files and correspondence: 10 years from closure of the file, the general limitation period (Code of Obligations Art. 146).
- Requests that do not lead to a contract: at most 2 years from the request date.
- Server and transaction logs: at most 2 years (obligations under Law No. 5651 reserved).
- Consent and opt-out records for commercial electronic messages: 3 years from the opt-out date.
At the end of the period, data are deleted, destroyed or anonymised.
8. Your rights (KVKK Art. 11)
By applying to the data controller you have the right to:
- learn whether your personal data are processed;
- request information if they are;
- learn the purpose of processing and whether the data are used in line with it;
- know the third parties to whom the data are transferred, in Türkiye or abroad;
- request rectification of incomplete or inaccurate data;
- request erasure or destruction under the conditions of Article 7 of the KVKK;
- request that rectification, erasure or destruction be notified to third parties to whom the data were transferred;
- object to a result to your detriment arising from analysis exclusively by automated systems;
- claim compensation for damage suffered due to unlawful processing.
9. How to apply
Under the Communiqué on the Procedures and Principles of Application to the Data Controller, you may submit your request:
- in writing, by signed letter delivered by hand or through a notary to Adalet Mah. Manas Blv. Folkart Towers A Kule No: 47 B, İç Kapı No: 3509, Bayraklı / İzmir;
- from your registered e-mail (KEP) address to [KEP adresi — aanvullen];
- from the e-mail address you previously notified to us and which is recorded in our system, to info@incassomentor.com.
Your application must contain your name and surname, your Turkish ID number (Turkish citizens) or nationality and passport / ID number (foreign nationals), an address or e-mail for notification, your telephone number if any, and the subject of your request. Applications are concluded free of charge within 30 days at the latest; if the operation entails additional costs, the tariff set by the Board applies. If your application is refused, the reply is found insufficient or no reply is given in time, you have the right to lodge a complaint with the Personal Data Protection Board.
10. Data security and VERBİS
Your data are protected by technical and organisational measures including access authorisation, encrypted connections (TLS), regular backups and data processing agreements with our infrastructure providers. [VERBİS status: the company is exempt from registration in the Data Controllers Registry (VERBİS) because its annual number of employees and balance sheet total are below the thresholds set by the Board / VERBİS registration number: … — to be added]
11. Changes
This notice may be updated in line with changes in legislation and in our services. The current version and its effective date are published on this page.