Verilogy is developed with privacy by design and privacy by default concepts at the core of
every step that we took along the way.
This privacy policy explains who we are, how we collect, share and use Personal Information,
and how you can exercise your privacy rights.
We recommend that you read this privacy policy in full to ensure you are fully informed.
However, to make it easier for you to review the parts of this privacy policy that apply to you,
we have divided up the document into sections that are specifically applicable to everyone
(Section 1), Professionals (Section 2), Compliance Team Members (Section
3), Visitors (Section 4) and to everyone ( Section 5).
1. Introduction
A. Who We Are
Verilogy is an online privacy management platform (the "Services") operated by Verilogy
Teknoloji A.Ş., a company headquartered in Istanbul in the Republic of Turkey ("we," "us,"
"our," and "Verilogy").
Our Services enable Professionals to manage their data protection compliance projects. We also
provide other related services, such as Verilogy Privacy Policy and Verilogy Training mobile
apps. Find out more about our Services here.
In this privacy policy, these terms have the following meanings:
"Compliance Team Member" is a person or a group a Professional provides compliance
services through our Services. In other words, Compliance Team Members are Professionals’
instructor’s employees or whom a Professional has given us information. For example, if you
are a lawyer, your instructor’s employees who are involved in the compliance project would be
considered a Compliance Team Member.
"Compliance Projects" are projects a Professional may create or manage on our platform and
all associated information related to those Projects (for example, email addresses, phone
numbers).
"Professionals" means any person or entity that is registered with us to use the Services such
as lawyers and advisors.
"Personal Information" means any information that identifies or can be used to identify
Professionals, Compliance Team Members, or a Visitors, directly or indirectly. Examples of
Personal Information include, but are not limited to, first and last name, email address, IP
address or other demographic information.
"Website(s)" means any website(s) we own and operate (such as www.verilogy.com) or any
web pages, interactive features, applications, widgets, blogs, social networks, social network
"tabs," or other online, mobile, or wireless offerings that post a link to this privacy policy.
"Visitor" means any person who visits any of our Websites.
2. Privacy for Professionals
This section applies to the Personal Information we collect and process from a Professional or
potential Professional through the provision of the Services. If you are not a Professional,
the Visitors or Compliance Team Members section of this policy may be more applicable to
you and your data. In this section, "you" and "your" refer to Professionals and potential
Professionals.
A. Information We Collect
The Personal Information that we may collect broadly falls into the following categories:
(i) Information you provide to us
In the course of engaging with our Services, you may provide Personal Information about you
and your Compliance Team Members. Personal Information is often, but not exclusively,
provided to us when you sign up for and use the Services, consult with our customer service
team, send us an email, or communicate with us in any other way.
We will let you know prior to collection whether the provision of Personal Information we are
collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if
any, of not providing the information. By giving us this information, you agree to this
information being collected, used and disclosed as described in our Terms of Use and in this
privacy policy.
This information may include:
o Registration information: You need a Verilogy account to use the Services as a Professional.
When you register for an account, you will be asked to provide certain basic information, such
as your name, email address, username, password, company name, location, and phone number
(for using two-factor authentication).
o Billing and communications information: If you purchase our Services, you may also need
to provide us with payment and billing information, such as your credit card details and billing
address. Verilogy will also maintain a record of your billing transactions and purchases, and
any communications and responses.
o Information we process on your behalf: In order to send an transactional email or use certain
features in your account, you need to invite your team members that provides us information
about them, such as their names and email addresses and phone number. We use and process
this information to provide the Services in accordance with your instructions.
(ii) Information we collect automatically
When you use the Services, we may automatically collect certain information about your device
and usage of the Services. We use cookies and other tracking technologies to collect some of
this information.
This information may include:
o Device information: We collect information about the device and applications you use to
access the Services, such as your IP address, your operating system, your browser ID, and other
information about your system and connection.
o Log data: We log information about our customers and their users when you use one of the
Services including Internet Protocol (“IP”) address.
o Product usage data: We keep track of user activity in relation to the types of Services our
customers and their users use, the configuration of their computers, and performance metrics
related to their use of the Services.
(iii) Information we collect from other sources
From time to time, we may obtain information about you or your Compliance Team Members
from third-party sources and our joint marketing partners. We take steps to ensure that such
third parties are legally or contractually permitted to disclose such information to us.
o Examples of the information we receive from other sources include demographic information
(such as age and gender), device information (such as IP addresses), location (such as city and
state), and online behavioral data (such as information about use of social media websites, page
view information and search results and links). We use this information, alone or in
combination with other information (including Personal Information) we collect, to enhance
our ability to provide relevant marketing and content to you and to develop and provide you
with more relevant products, features, and services.
(iv) Information from the use of our mobile apps
When you use our mobile apps, we may collect certain device and usage-related information in
addition to information described elsewhere in this privacy policy.
o Device information: We may collect information about the type of device and operating
system you use. We do not ask for, access, or track any location-based information from your
mobile device at any time while downloading or using our mobile apps or Services.
o Product usage data: We may use mobile analytics software (such as Firebase) to better
understand how people use our application. We may collect information about how often you
use the application and other performance data.
o Email: We need to process your email address and your name in order to send you the generated
privacy policy.
B. Use of Personal Information
We may use the Personal Information we collect through the Services or other sources for a
range of reasons, including:
o Set up a user account,
o Provide, operate and maintain the Services;
o To bill and collect money owed to us by you. This includes sending you emails, invoices,
receipts, notices of delinquency, and alerting you if we need a different credit card number. We
use third parties for secure credit card transaction processing, and those third parties collect
billing information to process your orders and credit card payments. To learn more about the
steps we take to safeguard that data, see the "Our Security" section of this privacy policy.
o To send you system alert messages. For example, we may inform you about temporary or
permanent changes to our Services, such as planned outages, or send you account, security or
compliance notifications, such as new features, version updates, releases, abuse warnings, and
changes to this privacy policy.
o To communicate with you about your account and provide customer support. For example, if
you use our mobile apps, we may ask you if you want to receive push notifications about activity
in your account. If you have opted in to these push notifications and no longer want to receive
them, you may turn them off through your operating system.
o To enforce compliance with our Terms of Use and applicable law, and to protect the rights and
safety of our Professionals and third parties, as well as our own. This may include developing
tools and algorithms that help us prevent violations.
o To meet legal requirements, including complying with court orders, valid discovery requests,
valid public authority requests, and other appropriate legal mechanisms.
o To provide information to representatives and advisors, including attorneys and accountants, to
help us comply with legal, accounting, or security requirements.
o To prosecute and defend a court, arbitration, or similar legal proceeding.
o To respond to lawful requests by public authorities, including to meet national security or law
enforcement requirements.
o To provide, support and improve the Services. For example, this may include sharing your or
your Compliance Team Membersinformation with third parties in order to provide and support
our Services or to make certain features of the Services available to you. When we share
Personal Information with third parties, we take steps to protect your information by requiring
these third parties to enter into a contract with us that requires them to use the Personal
Information we transfer to them in a manner that is consistent with this privacy policy and
applicable privacy laws.
o For our data analytics projects. Our data analytics projects use data from Verilogy accounts,
including Personal Information of Professionals, to provide and improve the Services. If you or
your Compliance Team Member prefers not to share this data, you can alter the security settings
on your account (as described here) to opt out of data analytics projects, or your Compliance
Team Member can opt out of data analytics projects at any time by emailing us
at privacy@verilogy.com. We will act as a data controller to process data for our data analytics
projects in reliance on our legitimate business interests of improving and enhancing our
products and services for our Professionals. As always, we take the privacy of Personal
Information seriously, and will continue to implement appropriate safeguards to protect this
Personal Information from misuse or unauthorized disclosure.
o Combined information. We may combine Personal Information with other information we
collect or obtain about you (such as information we source from our third-party partners) to
serve you specifically, such as to deliver a product or service according to your preferences or
restrictions, or for advertising or targeting purposes in accordance with this privacy policy.
When we combine Personal Information with other information in this way, we treat it as, and
apply all of the safeguards in this privacy policy applicable to, Personal Information.
o Other purposes. To carry out other legitimate business purposes, as well as other lawful
purposes about which we will notify you.
C. Cookies and Tracking Technologies
We and our partners may use various technologies to collect and store information when you
use our Services, and this may include using cookies and similar tracking technologies, such as
pixels and web beacons. They also allow us to collect information such as IP address, browser,
email and other similar details. We use this information to measure the performance of your
Projects, and to provide analytics information and enhance the effectiveness of our Services.
D. Compliance Projects
Your Projects are stored on a secure Verilogy server.
E. Other Data Protection Rights
You and your Compliance Team Members may have the following data protection rights:
o To access, correct, update or request deletion of Personal Information. Verilogy takes
reasonable steps to ensure that the data we collect is reliable for its intended use, accurate,
complete and up to date. You may contact us directly by emailing us at privacy@verilogy.com.
o You may object to processing of your Personal Information, ask to restrict processing of your
Personal Information or request portability of your Personal Information. Similarly, if Personal
Information is collected or processed on the basis of consent, the data subject can withdraw
their consent at any time. Withdrawing your consent will not affect the lawfulness of any
processing we conducted prior to your withdrawal, nor will it affect processing of your Personal
Information conducted in reliance on lawful processing grounds other than consent.
o The right to complain to a data protection authority about the collection and use of Personal
Information.
We respond to all requests we receive from individuals wishing to exercise their data protection
rights in accordance with applicable data protection law. We may ask you to verify your identity
in order to help us respond efficiently to your request. If we receive a request from one of your
Compliance Team Members we will respond directly to their request.
3. Privacy for Compliance Team Members
This section applies to the information we process about our ProfessionalsCompliance Team
Members as a data controller pursuant to fulfillment of the contract, as explained in the "Legal
Basis for Processing" section below. Our Services are intended for use by our Professionals. As
a result, for much of the Personal Information we collect and process about Compliance Team
Members through the Services, we act as a processor on behalf of our Professionals. Verilogy
is not responsible for the privacy or security practices of our Professionals, which may differ
from those set forth in this privacy policy. For purposes of this section, "you" and "your" refer
to Compliance Team Members.
A. Information We Collect
The Personal Information that we may collect or receive about you broadly falls into the
following categories:
(i) Information we receive about Compliance Team Members from our Professionals
A Professional may provide Personal Information about you to us through the Services. For
example, when a Professional invites the compliance team to the platform, they may provide
us with certain contact information or other Personal Information about you such as your name,
email address or telephone number. You may have the opportunity to update some of this
information by editing your profile.
(ii) Information we collect automatically
When you interact with a Project that you receive from a Professional, we may collect
information about your device and interaction with an email. We use cookies and other tracking
technologies to collect some of this information. Our use of cookies and other tracking
technologies is discussed more below, and in more detail in our Cookie Statement here.
o Device information: We collect information about the device and applications you use to
access emails sent through our Services, such as your IP address, your operating system, your
browser ID, and other information about your system and connection.
o Product usage data: We collect usage data about you whenever you interact with emails sent
through the Services, which may include dates and times you access emails and your browsing
activities (such as what pages are viewed). We also collect information regarding the
performance of the Services, including metrics related to the deliverability of emails and other
electronic communications our Professionals send through the Services. This information
allows us to improve the content and operation of the Services and facilitate research and
analysis of the Services.
B. Use of Personal Information
We may use the Personal Information we collect or receive about you for fulfilling our
contractual obligations including:
o Set up a user account,
o Provide, operate and maintain the Services;
o To enforce compliance with our Terms of Use and applicable law. This may include developing
tools and algorithms that help us prevent violations.
o To protect the rights and safety of our Professionals and third parties, as well as our own. For
example, sometimes we review the content of our ProfessionalsCompliance Projects to make
sure they comply with our Terms of Use.
o To meet legal requirements, including complying with court orders, valid discovery requests,
valid public authority requests, and other appropriate legal mechanisms.
o To provide information to representatives and advisors, including attorneys and accountants, to
help us comply with legal, accounting, or security requirements.
o To prosecute and defend a court, arbitration, or similar legal proceeding.
o To respond to lawful requests by public authorities, including to meet national security or law
enforcement requirements.
o To provide, support and improve the Services. For example, this may include sharing your
information with third parties in order to provide and support our Services or to make certain
features of the Services available to our Professionals. When we share Personal Information
with third parties, we take steps to protect your information by requiring these third parties to
enter into a contract with us that requires them to use the Personal Information we transfer to
them in a manner that is consistent with this privacy policy and applicable privacy laws.
o For our data analytics projects. Our data analytics projects use data from Verilogy accounts,
including your Personal Information, to provide and improve the Services. We use information,
like your purchase history, provided to us by Professionals, so we can make more informed
predictions, decisions, and products for our Professionals. For example, we use data from
Verilogy accounts to enable product recommendation, audience segmentation, and predicted
demographics features for our Professionals. If you prefer not to share this data, you can opt
out of data analytics projects at any time by emailing us at privacy@verilogy.com.
o Other purposes. To carry out other legitimate business purposes, as well as other lawful
purposes.
C. Cookies and Tracking Technologies
We and our partners may use various technologies to collect and store information when you
interact with a Professional’s Compliance Project and this may include using cookies and
similar tracking technologies, such as pixels and web beacons. For example, we use web
beacons in the emails we send on behalf of our Professionals. When you receive and engage
with a Professionals Compliance Project, web beacons track certain behavior such as whether
the email sent through the Verilogy platform was delivered and opened and whether links
within the email were clicked. They also allow us to collect information such as your IP address,
browser, email, and other similar details. We use this information to measure the performance
of our ProfessionalsCompliance Projects, and to provide analytics information and enhance
the effectiveness of our Services.
D. Legal Basis for Processing
We process Personal Information about you as a data controller as described in this section with
regard to fulfilling our contractual obligations including:
o Set up a user account,
o Provide, operate and maintain the Services;
o To enforce compliance with our Terms of Use and applicable law. This may include developing
tools and algorithms that help us prevent violations.
o To protect the rights and safety of our Professionals and third parties, as well as our own. For
example, sometimes we review the content of our Professionals’ Compliance Projects to make
sure they comply with our Terms of Use.
o To meet legal requirements, including complying with court orders, valid discovery requests,
valid public authority requests, and other appropriate legal mechanisms.
o To provide information to representatives and advisors, including attorneys and accountants, to
help us comply with legal, accounting, or security requirements.
o To prosecute and defend a court, arbitration, or similar legal proceeding.
o To respond to lawful requests by public authorities, including to meet national security or law
enforcement requirements.
o To provide, support and improve the Services. For example, this may include sharing your
information with third parties in order to provide and support our Services or to make certain
features of the Services available to our Professionals. When we share Personal Information
with third parties, we take steps to protect your information by requiring these third parties to
enter into a contract with us that requires them to use the Personal Information we transfer to
them in a manner that is consistent with this privacy policy and applicable privacy laws.
o For our data analytics projects. Our data analytics projects use data from Verilogy accounts,
including your Personal Information, to provide and improve the Services. We use information,
like your purchase history, provided to us by Professionals, so we can make more informed
predictions, decisions, and products for our Professionals. For example, we use data from
Verilogy accounts to enable product recommendation, audience segmentation, and predicted
demographics features for our Professionals. If you prefer not to share this data, you can opt
out of data analytics projects at any time by emailing us at privacy@verilogy.com.
o Other purposes. To carry out other legitimate business purposes, as well as other lawful
purposes.
E. Other Data Protection Rights
You may have the following data protection rights:
o To access, correct, update or request deletion of your Personal Information. Verilogy takes
reasonable steps to ensure that the data we collect is reliable for its intended use, accurate,
complete, and up to date. You may contact us directly at any time about accessing, correcting,
updating or deleting your Personal Information, or altering your data, by submitting a request
to us from privacy@verilogy.com. We will consider your request in accordance with
applicable laws.
o You can object to processing of your Personal Information, ask us to restrict processing of your
Personal Information or request portability of your Personal Information. Again, you can
exercise these rights by emailing us at privacy@verilogy.com.
o You have the right to complain to a data protection authority about our collection and use of
your Personal Information.
If you no longer want to be contacted by one of our Professionals through our Services, please
directly contact us to update or delete your data from privacy@verilogy.com.
We respond to all requests we receive from individuals wishing to exercise their data protection
rights in accordance with applicable data protection laws. We may ask you to verify your
identity in order to help us respond efficiently to your request.
4. Privacy for Visitors
This section applies to Personal Information that we collect and process through our Websites
and in the usual course of our business, such as in connection with our recruitment, events, sales
and marketing activities. In this section "you" and "your" refers to Visitors.
A. Information We Collect
(i) Information you provide to us on the Websites
Certain parts of our Websites may ask you to provide Personal Information voluntarily. For
example, we may ask you to provide certain Personal Information (such as your name, company
name and contact details) in order to sign up for a free or paid Verilogy account or otherwise
submit inquiries to us. We may also collect Personal Information, such as your contact and job
details through business or marketing interactions we may have with you. You may choose to
provide additional information when you communicate with us or otherwise interact with us,
and we will keep copies of any such communications for our records.
The Personal Information that you are asked to provide, and the reasons why you are asked to
provide it, will be made clear to you at the point we ask you to provide your Personal
Information. We will also let you know prior to collection whether the provision of the Personal
Information we are collecting is compulsory or may be provided on a voluntary basis and the
consequences, if any, of not providing the information.
(ii) Information we collect automatically through the Websites
When you visit our Websites, we may also collect certain information automatically from your
device.
Specifically, the information we collect automatically may include your IP address, your
operating system, your browser ID, your browsing activity, and other information about your
system and connection and how you interact with our Websites and other websites. We may
collect this information as a part of log files as well as through the use of cookies or other
tracking technologies.
Our use of cookies and other tracking technologies is discussed more below, and in more detail
in our Cookie Statement here.
B. Use of Personal Information
We may use the information we collect through our Websites for a range of reasons, including:
o To provide, operate, optimize, and maintain our Websites.
o To send you information for marketing purposes, in accordance with your marketing
preferences.
o For recruitment purposes if you have applied for a role with Verilogy.
o To respond to your online inquiries and requests, and to provide you with information and
access to resources or services that you have requested from us.
o To manage our Websites and system administration and security.
o To improve the navigation and content of our Websites.
o To identify any server problems or other IT or network issues.
o To process transactions and to set up online accounts.
o To compile aggregated statistics about site usage and to better understand the preferences of
our Visitors.
o To carry out research and development to improve our products and services.
o To customize content and layout of the Websites.
o To carry out other legitimate business purposes, as well as other lawful purposes.
In addition, we may combine Personal Information with other information we collect or obtain
about you (such as information we source from our third-party partners) to serve you
specifically, such as to deliver a product or service according to your preferences or restrictions,
or for advertising or targeting purposes in accordance with this privacy policy. When we
combine Personal Information with other information in this way, we treat it as, and apply all
of the safeguards in this privacy policy applicable to, Personal Information.
C. Public Information and Third-Party Websites
Links to third-party websites. Our Websites include links to other websites, whose privacy
practices may be different from ours. If you submit Personal Information to any of those sites,
your information is governed by their privacy policies. We encourage you to carefully read the
privacy policy of any website you visit.
D. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to collect and use Personal Information about
you, including to serve interest-based advertising. For further information about the types of
cookies and tracking technologies we use, why, and how you can control them, please see our
Cookie Statement here.
E. Other Data Protection Rights
You have the following data protection rights:
o To access, correct, update, or request deletion of your Personal Information. Verilogy takes
reasonable steps to ensure that the data we collect is reliable for its intended use, accurate,
complete, and up to date. You may contact us directly at any time about accessing, correcting,
updating, or deleting your Personal Information, or altering your data or marketing preferences
by mailing us at privacy@verilogy.com .We will consider your request in accordance with
applicable laws.
o You can object to processing of your Personal Information, ask us to restrict processing of your
Personal Information or request portability of your Personal Information. Again, you can
exercise these rights by emailing us at privacy@verilogy.com.
o Similarly, if we have collected and processed your Personal Information with your consent,
then you can withdraw your consent at any time. Withdrawing your consent will not affect the
lawfulness of any processing we conducted prior to your withdrawal, nor will it affect
processing of your Personal Information conducted in reliance on lawful processing grounds
other than consent.
o You have the right to complain to a data protection authority about our collection and use of
your Personal Information.
We respond to all requests we receive from individuals wishing to exercise their data protection
rights in accordance with applicable data protection laws. We may ask you to verify your
identity in order to help us respond efficiently to your request.
5. General Information
A. How We Share Information
We may share and disclose your Personal Information to the following types of third parties for
the purposes described in this privacy policy (for purposes of this section, "you" and "your"
refer to Professionals, Compliance Team Members, and Visitors unless otherwise indicated):
(i) Our service providers
Sometimes, we share your information with our third-party service providers, who help us
provide and support our Services and other business-related functions.
For example, if it is necessary to provide Professionals something they have requested,
examples include analyzing data, hosting data, engaging technical support for our Services,
processing payments, and delivering content.
These third-party service providers enter into a contract that requires them to use your Personal
Information only for the provision of services to us and in a manner that is consistent with this
privacy policy.
In connection with our Services, we use a third-party service provider, EuroMessage. We use
Euromessage's API, which allows us to build features into our Verilogy application to enable
us to communicate with our Professionals through texting, which we use for two-factor
authentication for our application. If you are a Professional, Twilio may need to collect and
process certain Personal Information about you as a controller to provide such services. To
learn more about Euromessage’s privacy practices, please visit www.euromessage.com .
(ii) Advertising partners
We may partner with third-party advertising networks and exchanges to display advertising on
our Websites or to manage and serve our advertising on other sites and may share Personal
Information of Professionals and Visitors with them for this purpose. We do not sell or market
to any of our ProfessionalsCompliance Team Members. We and our third-party partners may
use cookies and other tracking technologies, such as pixels and web beacons, to gather
information about your activities on our Websites and other sites in order to provide you with
targeted advertising based on your browsing activities and interests.
For more information about cookies and other tracking technologies, please see our Cookie
Statement here.
(iii) Any competent law enforcement body, regulatory body, government agency, court or other
third party where we believe disclosure is necessary (i) as a matter of applicable law or
regulation, (ii) to exercise, establish, or defend our legal rights, or (iii) to protect your vital
interests or those of any other person.
(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation,
liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our
obligations under this privacy policy, including your rights to access and choice. We will notify
you of the change either by sending you an email or posting a notice on our Website.
(v) Any other person with your consent.
B. Legal Basis for Processing Personal Information
Our legal basis for collecting and using the Personal Information described above will depend
on the Personal Information concerned and the specific context in which we collect it.
We will collect and use Personal Information from you where the processing is in our legitimate
interests and not overridden by your data-protection interests or fundamental rights and
freedoms. Typically, our legitimate interests include improving, maintaining, providing, and
enhancing our technology, products, and services; ensuring the security of the Services and our
Websites; and for our marketing activities.
If you are a Professional, we may need the Personal Information to perform a contract with you.
In some limited cases, we may also have a legal obligation to collect Personal Information from
you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform
a contact with you, we will make this clear at the relevant time and advise you whether the
provision of your Personal Information is mandatory or not, as well as of the possible
consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have
your consent to do so.
If you have questions about or need further information concerning the legal basis on which we
collect and use your Personal Information, please contact us using the privacy@verilogy.com .
C. Your Choices and Opt-Outs
Professionals and Visitors who have opted in to our marketing emails can opt out of receiving
marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our
marketing messages.
Also, all opt-out requests can be made by emailing us at privacy@verilogy.com . Please note
that some communications (such as service messages, account notifications, billing
information) are considered transactional and necessary for account management, and
Professionals cannot opt out of these messages unless you cancel your Verilogy account.
D. Our Security
We take appropriate and reasonable technical and organizational measures to protect Personal
Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction,
taking into account the risks involved in the processing and the nature of the Personal
Information. If you have any questions about the security of your Personal Information, you
contact us at privacy@verilogy.com .
Verilogy accounts require a username, password and mobile phone number to log in.
Professionals must keep their username and password secure, and never disclose it to a third
party. Because the information in a Professional’s Verilogy account is so sensitive, account
passwords are hashed, which means we cannot see a Professional’s password. We cannot resend
forgotten passwords either. We will only provide Professionals with instructions on how to
reset them.
E. International Transfers
(i) We operate in Turkey
Our servers and offices are located in Europe and Turkey, so your information may be
transferred to, stored, or processed outside EEA. While the data protection, privacy, and other
laws of the Turkey are comprehensive (KVKK) as those in your country, we take many steps
to protect your privacy, including offering our Professionals a Data Processing Agreement.
With respect to Personal Information received or transferred pursuant to the Data Processing
Agreements, we are subject to the regulatory enforcement powers of the Turkish Data
Protection Board. In certain situations, we may be required to disclose Personal Information in
response to lawful requests by public authorities, including to meet national security or law
enforcement requirements.
F. Retention of Data
We retain Personal Information where we have an ongoing legitimate business or legal need to
do so. Our retention periods will vary depending on the type of data involved, but, generally,
we'll refer to these criteria in order to determine retention period:
o Whether we have a legal or contractual need to retain the data.
o Whether the data is necessary to provide our Services.
o Whether our Professionals have the ability to access and delete the data within their Verilogy
accounts.
o Whether our Professionals would reasonably expect that we would retain the data until they
remove it or until their Verilogy accounts are closed or terminated.
When we have no ongoing legitimate business need to process your Personal Information, we
will either delete or anonymize it.
G. Changes to this Policy
We may change this privacy policy at any time and from time to time. The most recent version
of the privacy policy is reflected by the version date located at the top of this privacy policy.
All updates and amendments are effective immediately upon notice, which we may give by any
means, including, but not limited to, by posting a revised version of this privacy policy or other
notice on the Websites. We encourage you to review this privacy policy often to stay informed
of changes that may affect you.
I. Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we
have handled any privacy matter, please use privacy@verilogy.com to contact us.