Data Protection Notice

1. Identity of the data controller

Your personal data is processed by Socreathink Medya Planlama ve Stratejik Dijital Pazarlama A.Ş. ("So CreaThink", the "Company") as data controller, within the scope described below.

• ▸Company: Socreathink Medya Planlama ve Stratejik Dijital Pazarlama A.Ş.
• ▸Address: Adalet Mah. Manas Bulvarı, Folkart Towers B Kule Kat 25 No 2511, Bayraklı/İzmir
• ▸Email: [email protected]
• ▸Phone: 0545 340 31 48
• ▸Website: socreathink.com

2. Personal data we process

When you complete a form on our website or contact us by email or phone, we process the following personal data:

• ▸Identity: first and last name.
• ▸Contact: email address, phone number, company name and website address.
• ▸Customer transaction: the service you request, your industry, the advertising budget and goals you state, and any free-text message you submit.
• ▸Transaction security and marketing analysis: the page on which the form was submitted, the referrer showing how you reached the site, and campaign tags where present (utm_source, utm_medium, utm_campaign).
• ▸Candidate details: the portfolio, LinkedIn or personal site link you provide when applying through our careers page; your answer to the application question; and any CV or portfolio file you choose to upload, together with the information it contains.

We do not collect special categories of personal data through this website. Please do not include such information in our forms.

3. Purposes of processing

Your personal data is processed for the following purposes:

• ▸Receiving, assessing and responding to your enquiry.
• ▸Fulfilling free audit and report requests.
• ▸Preparing proposals, conducting contract negotiations and concluding agreements.
• ▸Delivering our services and managing client relationships and support.
• ▸Measuring and improving service quality.
• ▸Meeting our legal obligations and providing evidence in potential disputes.
• ▸Sending commercial electronic messages where you have given explicit consent.

4. Method of collection and legal grounds

Your personal data is collected electronically, by wholly or partly automated means, through the contact, proposal and free report forms on our website, and by email and telephone.

Processing is based on the following grounds set out in Article 5(2) of the Law:

• ▸(c) Directly related to the conclusion or performance of a contract: assessing your proposal request and concluding a service agreement.
• ▸(ç) Necessary for compliance with a legal obligation of the data controller: tax, commercial and accounting obligations.
• ▸(e) Necessary for the establishment, exercise or protection of a right: providing evidence in potential disputes.
• ▸(f) Necessary for the legitimate interests of the data controller, provided that it does not harm your fundamental rights and freedoms: enquiry follow-up and service improvement.

Commercial electronic messages and non-essential cookies rely solely on your explicit consent under Article 5(1). You may withdraw your consent at any time.

5. Transfer of personal data

Your personal data may be transferred in accordance with Article 8 of the Law, limited to the purposes above:

• ▸To our hosting and email infrastructure providers (as data processors, so the service can be delivered technically).
• ▸To professional advisers such as our accountant, lawyer and independent auditor (to meet legal obligations).
• ▸To public authorities and judicial bodies legally authorised to request it.

We do not sell or rent your personal data to third parties for marketing purposes.

Where a transfer abroad is required, Article 9 of the Law applies: an adequacy decision, appropriate safeguards (standard contractual clauses, binding corporate rules) or another condition set out in the Law is required.

6. Retention periods

Your personal data is kept for as long as necessary for the purpose of processing and for the minimum periods required by applicable legislation:

• ▸Proposal and contact enquiries that do not lead to a contract: up to 2 years from the date of the enquiry.
• ▸Client records and contract-related data: 10 years from the end of the legal relationship, under Article 82 of the Turkish Commercial Code No. 6102 and Tax Procedure Law No. 213.
• ▸Records of commercial electronic messages based on consent: for the evidentiary period set out in legislation after consent is withdrawn.
• ▸Job applications and any CV file attached to them: up to 2 years from the date of the application. They are deleted earlier upon your request.

At the end of the period your personal data is deleted, destroyed or anonymised.

7. Your rights under Article 11

By applying to the data controller, you may exercise the following rights:

• ▸To learn whether your personal data is being processed.
• ▸To request information if your personal data has been processed.
• ▸To learn the purpose of processing and whether the data is used in line with that purpose.
• ▸To know the third parties in Türkiye or abroad to whom your data has been transferred.
• ▸To request correction of incomplete or inaccurate data.
• ▸To request deletion or destruction of your data under the conditions of Article 7.
• ▸To request that correction, deletion and destruction be notified to third parties to whom the data has been transferred.
• ▸To object to a result against you arising from analysis of your data solely by automated systems.
• ▸To claim compensation for damage arising from unlawful processing of your data.

8. How to apply

You may submit your requests in line with the Communiqué on the Procedures and Principles of Application to the Data Controller:

• ▸By sending a signed written application in person or through a notary to Adalet Mah. Manas Bulvarı, Folkart Towers B Kule Kat 25 No 2511, Bayraklı/İzmir.
• ▸By sending an application signed with a secure electronic signature or mobile signature to our registered electronic mail (KEP) address.
• ▸By emailing [email protected] from the email address you previously provided and that is registered in our systems.

Your application must clearly state your name and surname, your signature (for written applications), your Turkish ID number if you are a Turkish citizen, your address for notification, your email address and phone number if any, and the subject of your request.

Your request will be concluded free of charge as soon as possible and within thirty days at the latest. If the process incurs an additional cost, the fee set by the Personal Data Protection Board may be charged.

If your application is rejected, you find the response insufficient, or no response is given in time, you may file a complaint with the Personal Data Protection Board within thirty days of learning the response and in any case within sixty days of the application date.

9. Updates

This notice may be revised in line with changes in legislation and our business processes. The current version is always published on this page.