1. DATA CONTROLLER INFORMATION
Under the EU General Data Protection Regulation ("GDPR"), your personal data is processed by SCARLET SPACE TECHNOLOGIES INC. ("Scarlet" or "Company") as the data controller.
Contact Information:
Address: Maslak Mah. AOS 55. Sk 42 Maslak A Blok No: 2 İç Kapı No:9 Sarıyer İstanbul , Turkey
Email: info@scarletspace.com.tr
Phone: +90 541 744 62 77 (Corporate)
2. DATA PROTECTION OFFICER
Our company has appointed a Data Protection Officer to manage GDPR compliance processes:
Email: info@scarletspace.com.tr
3. PURPOSES AND LEGAL BASIS FOR PROCESSING
3.1. Processing Purposes
- Responding to communication requests
- Providing training and course services
- Evaluating business partnership opportunities
- Improving website performance
- Fulfilling legal obligations
- Taking security measures
3.2. Legal Basis (GDPR Article 6)
- Contract Performance: Course and training services
- Legitimate Interest: Website analytics, security
- Consent: Marketing communications, cookies
- Legal Obligation: Accounting, tax records
4. TYPES OF PERSONAL DATA COLLECTED
- Identity Data: First name, last name
- Contact Data: Email address, phone number
- Technical Data: IP address, cookie identifiers, login data
- Profile Data: Username, preferences, feedback
- Usage Data: Website usage information
- Marketing and Communication Data: Marketing preferences
5. DATA SHARING AND INTERNATIONAL TRANSFERS
5.1. Third Parties
Your data may be shared with third parties in the following categories:
- Service Providers: Cloud storage, email services
- Professional Advisors: Law firms, accountants
- Regulatory Authorities: Within the framework of legal obligations
5.2. International Transfers
When your data is transferred to countries outside the EU, appropriate safeguards are provided in accordance with Articles 44-49 of GDPR:
- European Commission Adequacy Decisions
- Standard Contractual Clauses (SCC)
- Approved Codes of Conduct
6. YOUR DATA SUBJECT RIGHTS
6.1. Fundamental Rights
- Right to Information: Receiving information about data processing
- Right of Access: Requesting access to your processed data
- Right to Rectification: Requesting correction of incorrect data
- Right to Erasure: Data deletion under "right to be forgotten"
- Right to Restrict Processing: Stopping data processing
- Right to Data Portability: Transferring your data to another provider
- Right to Object: Objecting to data processing
6.2. Automated Decision Making
You have the right not to be subject to fully automated decision-making processes, including profiling. We will inform you if such a situation exists.
7. DATA RETENTION PERIODS
We will retain your personal data only for the following periods:
- Communication Records: 3 years
- Course and Training Records: 7 years
- Website Logs: 12 months
- Marketing Data: Until consent is withdrawn
- Accounting Records: 10 years (legal obligation)
8. DATA SECURITY MEASURES
Technical and organizational measures taken for data security:
8.1. Technical Measures
- AES-256 encryption
- TLS/SSL protocols
- Secure server infrastructure
- Regular security updates
- Penetration testing
8.2. Organizational Measures
- Staff training programs
- Access control policies
- Data breach response plans
- Regular security audits
9. DATA BREACH NOTIFICATION
In case of a breach that threatens personal data security:
- Notification to the relevant supervisory authority within 72 hours
- Data subjects will be informed in case of high-risk breaches
- Necessary measures will be taken immediately
10. EXERCISING YOUR RIGHTS
10.1. Application Methods
To exercise your GDPR rights:
- Email: info@scarletspace.com.tr
- Mail: Maslak Mah. AOS 55. Sk 42 Maslak A Blok No: 2 İç Kapı No:9 Sarıyer İstanbul , Turkey
- Online Form: GDPR request form on our website
10.2. Response Times
Your requests will be responded to within 1 month. This period may be extended by 2 more months for complex situations.
11. RIGHT TO COMPLAINT
If you believe your GDPR rights have been violated:
- Turkey: Personal Data Protection Board (KVKK)
- EU: Data protection authority in your country
Effective Date: 19.04.2026
Last Updated: 19.04.2026