Privacy Policy and KVKK Information Notice
Updated
This notice explains how personal data is processed when you visit www.istanbultranslators.com, contact us, or use our sworn translation, notarisation and apostille services. It is our information notice under Article 10 of the Turkish Personal Data Protection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles of the Obligation to Inform, and, for visitors in the European Economic Area, our notice under Articles 13 and 14 of the EU General Data Protection Regulation ("GDPR").
1. Data controller
The data controller is Burak Ünal, who runs Istanbul Translators (www.istanbultranslators.com) as a sole proprietorship. Address: Merkez Mahallesi Hasat Sokak No:12/2, Şişli, 34384 İstanbul, Türkiye. Email: contact@istanbultranslators.com. Telephone: +90 539 415 31 39.
Istanbul Translators is a sworn translation office. We are not a notary, a court, a consulate or a law firm. When a translation is notarised, the notary acts as a public official and processes your data as a separate data controller under the Notary Law No. 1512; the same applies to the authority that issues an apostille.
2. Personal data we process
- Identity and contact: name and surname, email address, telephone and WhatsApp number, and, if we deliver documents to you, a postal address.
- The content of the documents you give us for translation. Depending on the document this can include identity numbers, passport details, dates and places of birth, family and civil status, education, employment, financial, property, company and court information, about you and about other people named in the document (for example a spouse, children or parents).
- Special categories of personal data, only where they appear in a document you ask us to translate: for example health information in a medical report, criminal record information in a criminal record certificate, or religion or blood group on older civil registry documents.
- Order and transaction data: the language pair, document type, certification level (sworn, notarised, apostille) and deadline you ask for, quotes, invoices, payment and delivery records.
- Corporate clients: the name, position and contact details of the people who place or follow orders for their company.
- Transaction security and technical data: IP address, browser and device information and request logs, and, only with your consent, analytics cookie data (see the Cookie Policy).
- Records of your choices: the date, time and version of this notice you acknowledged on our contact form, and your cookie choice.
3. How we collect it
Partly by automated means (the website contact form, cookies and server logs) and partly by non-automated means: email, telephone, WhatsApp, documents you hand over at our office or send us, and information we receive from notaries and authorities while we complete your order.
4. Purposes and legal bases
- Answering your enquiry and preparing a quote: necessary to take steps before a contract (KVKK Art. 5/2(c); GDPR Art. 6(1)(b)).
- Providing the service you order (translating and proofreading, certifying the translation as a sworn translator, arranging notarisation and apostille if you ask for them, and delivering the result): performance of a contract (KVKK Art. 5/2(c); GDPR Art. 6(1)(b)).
- Personal data of other people named in your documents: processed only to translate the document you give us, as part of performing our contract with you and in our legitimate interest in carrying out the work you request (KVKK Art. 5/2(c) and (f); GDPR Art. 6(1)(b) and (f)). Please share only documents you are entitled to share.
- Special categories of personal data in your documents: processed only to translate that document, where the translation is necessary for the establishment, exercise or protection of a right (for example in a court, residence, citizenship or recognition procedure), or otherwise with your explicit consent, which we ask for separately (KVKK Art. 6/3; GDPR Art. 9(2)(a) and (f)).
- Legal obligations such as invoicing, tax and accounting records, and requests from authorities (KVKK Art. 5/2(ç); GDPR Art. 6(1)(c)).
- Establishing, exercising or defending legal claims (KVKK Art. 5/2(e); GDPR Art. 6(1)(f)).
- Website security, keeping records of notices and choices, quality control and improving our service: our legitimate interests, which do not override your rights (KVKK Art. 5/2(f); GDPR Art. 6(1)(f)).
- Analytics cookies: only with your explicit consent, which you can withdraw at any time without affecting earlier processing (KVKK Art. 5/1; GDPR Art. 6(1)(a)).
We do not use your data for automated decisions that produce legal effects for you, we do not send marketing messages without your consent, and we do not sell personal data. Please do not write health or criminal record details in the contact form: send the document itself through the channel we agree with you.
5. Recipients
Only the data each recipient needs, for the purposes above:
- notaries in Türkiye, when you ask for a notarised translation, and the authorities that issue apostilles, when you ask for an apostille;
- sworn translators and proofreaders who work with us on a specific language pair, under confidentiality obligations;
- courier companies, banks and payment providers, when your order requires them;
- our IT service providers: website hosting and delivery of contact-form emails (Amazon Web Services, servers in Frankfurt, Germany), our email provider and, only with your consent, Google (Google Analytics);
- Meta (WhatsApp), if you choose to contact us on WhatsApp;
- our accountant and legal advisers, and courts or authorities where the law requires.
6. Transfers abroad
Some recipients are located outside Türkiye (for example our hosting provider in Germany, Google and Meta), and you may yourself be abroad, or ask us to send a translation abroad. Personal data is transferred abroad only in line with KVKK Article 9 (as amended by Law No. 7499): on the basis of an adequacy decision, appropriate safeguards such as standard contracts notified to the Personal Data Protection Authority, or, for incidental transfers, one of the exceptions in Article 9/6, including your explicit consent or a transfer that is necessary to perform a contract with you. Transfers out of the EEA follow Chapter V of the GDPR.
7. Retention
- Enquiries and quotes that do not lead to an order: 2 years after our last contact.
- Documents you send for translation and the translations we deliver: up to 2 years after delivery, so that we can issue additional certified copies or corrections at your request, unless you ask us to delete them earlier and no legal obligation prevents it.
- Invoices, accounting and tax records: the periods set by the Turkish Commercial Code and the Tax Procedure Law (up to 10 years).
- Records needed for possible legal claims: until the statutory limitation periods end (generally 10 years under the Turkish Code of Obligations).
- Website server logs: 14 days, unless needed to investigate a security incident.
- Records of notices acknowledged and consents given: as long as the related processing continues, then for the limitation period.
When a period ends, or the reason for processing no longer exists, we delete, destroy or anonymise the data under the Regulation on the Deletion, Destruction or Anonymisation of Personal Data, at the latest in the next periodic destruction cycle. Records kept by notaries and other public authorities are governed by their own legislation.
8. Confidentiality and security
Sworn translators take an oath before a notary and are bound to keep the content of the documents they translate confidential. We use encrypted connections (HTTPS), limit access to the people who work on your order, bind our translators and service providers to confidentiality and data protection terms, and store documents securely. If personal data is obtained by others unlawfully, we notify the Personal Data Protection Board within 72 hours and the persons concerned as soon as possible.
9. Your rights
Under KVKK Article 11 you have the right to: learn whether your personal data is processed; request information about it; learn the purpose of processing and whether it is used accordingly; know the third parties in Türkiye or abroad to whom it is transferred; request correction of incomplete or inaccurate data; request deletion or destruction under Article 7; request that third parties to whom data was transferred are notified of a correction or deletion; object to a result against you arising exclusively from automated analysis; and claim compensation for damage caused by unlawful processing.
If the GDPR applies to you, you also have the rights of access, rectification, erasure, restriction, data portability and objection, the right to withdraw consent at any time, and the right to lodge a complaint with your supervisory authority.
10. How to apply
Use our KVKK application form and send it in writing to the address in section 1, by email to contact@istanbultranslators.com from the email address registered with us, with a secure electronic or mobile signature, or by registered electronic mail (KEP). We reply free of charge within 30 days at the latest (a fee under the Board's tariff may apply only if the reply involves an extra cost). If you are not satisfied with the reply, or receive none in time, you may complain to the Personal Data Protection Board (www.kvkk.gov.tr) within the periods in KVKK Article 14.
11. Children
This website is not directed at children. Documents of minors, such as birth certificates or school records, are given to us by their parents or legal guardians, who act on the child's behalf.
12. Versions and changes
We may update this notice; the date of the current version is shown at the top. Translations are provided for convenience; if they differ, the Turkish version prevails: KVKK Aydınlatma Metni.