1. The data controller
EGORA Digital, based in Évora, Portugal, website https://egoradigital.com, email egoradigital@gmail.com, is the data controller of the personal data described below.
2. Personal data we process
- Identity: name and surname.
- Contact: email address, and phone number if you call or message us.
- Customer transaction: business name, website address, project brief, services and package of interest, preferred next step, and our correspondence.
- Transaction security: IP address and server log records of visits to the website.
- Marketing (only with your explicit consent): how you use the website, measured by Google Analytics cookies.
3. Purposes
- Answering your enquiry and preparing a website review, recommendation or quote.
- Setting up and carrying out a contract for a project, and invoicing.
- Keeping the website secure and working.
- Meeting our legal obligations and establishing or defending legal claims.
- With your explicit consent, measuring how the website is used in order to improve it.
4. How we collect it, and the legal grounds
We collect personal data electronically: through the contact form on this website, by email, phone, WhatsApp or Instagram messages you send us, and through server logs recorded automatically when you visit.
We process it on these grounds of KVKK Article 5(2): processing is necessary for setting up or performing a contract with you (c); for us to meet a legal obligation (ç); for establishing, exercising or defending a right (e); and for our legitimate interests, provided your fundamental rights are not harmed (f). We do not process sensitive (special category) personal data.
Usage data from Google Analytics is collected only with your explicit consent (Article 5(1)), given in the cookie banner. You can withdraw it at any time with “Cookie settings” at the bottom of every page.
5. Who receives it, and transfers abroad
Your data may be shared, for the purposes above, with our service providers: our hosting provider (website and database), Resend (email notifications, United States), Cloudflare (website and demo sites), our email provider, Google (Google Analytics, only with your explicit consent); and with accountants, lawyers or authorities where the law requires it.
Because we are based in Portugal and some providers are located abroad, your data is processed outside Turkey (in the European Union and the United States). These transfers are made under KVKK Article 9: on the basis of appropriate safeguards where they are in place, and otherwise, as occasional transfers, because they are necessary for setting up or performing a contract with you (Article 9(6)(b)). Google Analytics data is transferred only with your explicit consent (Article 9(6)(a)).
6. Your rights under Article 11
You have the right to:
- learn whether your personal data is processed, and request information about it;
- learn the purpose of processing and whether it is used accordingly;
- know the third parties in Turkey or abroad to whom it is transferred;
- ask for it to be corrected if incomplete or inaccurate, and for third parties to be notified;
- ask for it to be deleted or destroyed under Article 7, and for third parties to be notified;
- object to a result against you arising from analysis exclusively by automated systems;
- claim compensation if you suffer damage because of unlawful processing.
7. How to apply
Under the Communiqué on the Procedures and Principles of Application to the Data Controller, you can apply in writing in Turkish, or by email to egoradigital@gmail.com from the email address you previously used with us. Please include your name and surname, a contact address and a clear description of your request.
We respond as soon as possible and within 30 days at the latest, free of charge (unless the request involves a separate cost, in which case the fee set by the Personal Data Protection Board may apply). If you are not satisfied with our answer, you can complain to the Personal Data Protection Board (kvkk.gov.tr).