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GDPR notice
How we process the personal data of visitors and clients in the EU/EEA under the General Data Protection Regulation (GDPR).
Last updated:
Controller
Hakan Caba, a self-employed professional based in Turkey who provides services under the siteupwell brand. Address: Patika Yol Sok. 26/7 Ataşehir / İstanbul. Email: hello@siteupwell.com.
Purposes and legal bases
- Preparing your inspection and quote: steps you ask us to take before a contract (Art. 6(1)(b)) or, if you contact us for a company, our legitimate interest in answering business enquiries (Art. 6(1)(f))
- Arranging and holding calls: the same bases as above
- Answering questions and improving our service: legitimate interests (Art. 6(1)(f))
- Keeping our forms secure and preventing spam and abuse, using a keyed hash of your IP address, your browser’s user agent and the result of our spam check: legitimate interests (Art. 6(1)(f))
- Issuing tax receipts and keeping the accounting records the law requires of us: legitimate interests (Art. 6(1)(f)) or, where EU or Member State law requires it, legal obligation (Art. 6(1)(c))
- Seeing which pages and campaigns bring enquiries, using the page you sent a form from and any campaign tags: legitimate interests (Art. 6(1)(f))
- Measuring how the site is used with Google Analytics 4: consent (Art. 6(1)(a) GDPR and Art. 5(3) of the ePrivacy Directive), which you can withdraw at any time in “Cookie settings”
Recipients and transfers
We share data only with the providers named in our Privacy policy: Hostinger International Ltd. (Cyprus) hosts our site on servers in the United States, Google Cloud EMEA Limited (Ireland) provides our email, calendar and video calls, and Cal.com, Inc. (US) runs our booking calendar; if you become a client, we also use Notion Labs, Inc. (US) for project tracking. If you message us on WhatsApp, WhatsApp (Meta) handles your number and messages. With your consent, we use Google Analytics 4, a Google service; Google relies on the EU–US Data Privacy Framework for transfers to the US. siteupwell is based in Turkey. Because our site is hosted in the United States, your data is transferred outside the EU/EEA; for this transfer, we rely on the EU Standard Contractual Clauses in Hostinger’s data processing agreement. Where our other providers or any subcontractors process data outside the EU/EEA, they rely on the EU Standard Contractual Clauses and, where they are certified, the EU–US Data Privacy Framework. You can ask us for a copy at hello@siteupwell.com.
Retention
Enquiries that don’t lead to a project are deleted 24 months after their last status change, which is usually our last exchange with you. We delete the keyed hash of your IP address and your browser’s user agent 30 days after you send a form; our hosting provider keeps its server logs, which may include IP addresses, under its own retention policy. Emails about such an enquiry are deleted from our mailbox in a monthly clean-up after the enquiry itself is deleted. Calls you book in our booking calendar stay in our Cal.com account while it is open; you can ask us to delete yours at any time. Client records, such as contracts, receipts and business correspondence, are kept for 10 years from the end of the year they were created: Turkish tax law requires 5 years for tax records, and claims can be brought for up to 10 years. Then we delete or anonymize them. We keep a record of each deletion, without personal data, for 3 years. Google Analytics keeps analytics data for 14 months.
Your rights
You have the right to access, rectify, erase, restrict and port your data, and to object to processing (Art. 15–21 GDPR). Where we rely on consent, you can withdraw it at any time. You can also lodge a complaint with your local supervisory authority. You can object at any time to processing based on our legitimate interests. You don’t have to give us your data, but we can’t answer a request without the required form fields. We don’t make decisions about you based solely on automated processing.
Contact
Send requests to hello@siteupwell.com. We respond within one month.