KVKK information notice

This notice is provided by Efalign Sağlık Teknolojileri in its capacity as data controller, pursuant to Article 10 of the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform, to inform visitors of the www.efalign.com website. It covers www.efalign.com only; separate notices are published on the iLigner product website (www.iligner.com) and its portals (portal.iligner.com, my.iligner.com, partner.iligner.com).

1. Data controller

The data controller is Efalign Sağlık Teknolojileri, established in İstanbul, Türkiye [MERSİS no — to be completed by counsel]. Contact channel: [email protected].

2. Personal data processed

Only the following personal data is processed through this website; the site opens no user accounts and neither requests nor collects health data or any other special categories of personal data:

• Identity data: the name and surname you enter in the contact form;
• Contact data: email address and — only if you choose to provide it — phone number;
• Inquiry data: the category you select (partnership, distribution, press, other), the message text, the site language you were using and your marketing-communication preference;
• Transaction-security data: IP address, browser/device information and request logs kept by our infrastructure providers, and the result of the Cloudflare Turnstile bot check.

The contact form’s draft feature keeps your entries (name, email, phone, category, message) only in your own browser’s localStorage for at most 15 minutes; the draft is never transmitted to us and is deleted upon successful submission.

3. Purposes of processing

• receiving, evaluating, answering and routing the requests, questions and applications you submit through the contact form;
• conducting and tracking correspondence about your request;
• sending promotional announcements about Efalign and its iLigner and Perla brands, only where your explicit consent exists;
• securing the site, blocking bot and spam traffic, and detecting and fixing faults;
• fulfilling legal obligations and establishing, exercising and protecting rights.

4. Legal grounds

Your personal data is processed on the following legal grounds set out in KVKK Article 5:

• KVKK Art. 5/2(c): processing necessary in direct connection with the establishment or performance of a contract — taking pre-contract steps at your request;
• KVKK Art. 5/2(f): processing necessary for our legitimate interests, provided it does not harm your fundamental rights and freedoms — answering inquiries and keeping the site secure;
• KVKK Art. 5/1 (explicit consent): marketing communications and — to the extent required, as explained below — transfers abroad;
• KVKK Art. 5/2(a), (ç) and (e): processing expressly provided for by law, necessary for compliance with our legal obligations, or necessary for the establishment, exercise or protection of a right.

5. Method of collection

Your personal data is collected in electronic form, through your completion of the contact form on the site and through technical records generated automatically by our infrastructure providers’ systems while the site operates. No data is collected through this site by any other channel.

6. Transfers of personal data

Your personal data is not sold to third parties and is not shared for their own marketing purposes. Limited to the purposes above, it may be transferred to:

• the authorized teams within the company and the company’s own back-office system, so that your request can be answered;
• our infrastructure providers for hosting, content delivery/security, email delivery and — if enabled — analytics (DigitalOcean — EU/Frankfurt; Cloudflare; Postmark; Plausible; Google only if ever enabled and only with your explicit consent).

Some of these providers are established abroad, and the site infrastructure is hosted in the European Union (Frankfurt). Transfers abroad are made in reliance on the conditions of KVKK Article 9 — including your explicit consent where required and, where available, safeguards accepted by the Turkish Personal Data Protection Board. [KVKK Art. 9 transfer basis and safeguards — to be confirmed by counsel]

7. Retention period

Your personal data is retained for as long as the processing purposes require and, in any event, for the limitation and retention periods prescribed by the applicable legislation; at the end of that period it is deleted, destroyed or anonymized in accordance with KVKK Article 7. Processing based on marketing consent continues until the consent is withdrawn.

8. Rights of the data subject (KVKK Art. 11)

Under KVKK Article 11, everyone has the right, by applying to the data controller, to:

• learn whether their personal data is processed;
• request information if it has been processed;
• learn the purpose of the processing and whether the data is used in accordance with that purpose;
• know the third parties, in Türkiye or abroad, to whom the data is transferred;
• request correction of personal data that is incomplete or inaccurate;
• request deletion or destruction of personal data under the conditions of KVKK Article 7;
• request that corrections, deletions and destructions be notified to the third parties to whom the data has been transferred;
• object to a result arising against the person through analysis of the processed data exclusively by automated systems;
• claim compensation for damage suffered due to unlawful processing of personal data.

9. How to apply

You may submit requests concerning the rights above to [email protected], together with information sufficient to verify your identity, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. Your application is concluded free of charge as soon as possible and within thirty days at the latest, depending on its nature; if the process additionally requires a cost, the fee in the tariff determined by the Personal Data Protection Board may be charged. If your application is rejected, you find the answer insufficient or no answer is given in time, you retain the right to lodge a complaint with the Personal Data Protection Board.

10. Updates

This notice is updated when our processing activities or the legislation change; the current version is published on this page with its last-updated date. The Turkish text prevails.