1. Data controller
Smarter Moment Limited A.Ş. is the data controller for the activities described in this notice. You may submit requests to turkayaltintas@smartermoment.com. Registered address: Ankara / Türkiye.
For end-user data submitted by a SmarterMoment customer, that customer is generally the data controller and Smarter Moment Limited A.Ş. acts as processor on documented instructions. Smarter Moment Limited A.Ş. remains a controller for limited processing carried out for its own security, contract, billing, and legal compliance purposes.
2. Categories of data
- Website data: IP address, request time, browser and device data, error and security logs, session identifier, and cookie or local-storage preferences.
- Demo and quote data: name, company, work email, optional phone and website, traffic range, request details, language, notice record, and evidence of any optional marketing consent.
- Account data: company and domain, authorised user name, email, one-way password hash, plan, permissions, session, usage, and account transaction data.
- Subscription and payment data: billing identity, tax and contact data, address, subscription and provider transaction references. SmarterMoment does not store full card numbers or CVV.
- Support data: request content, correspondence, actions, and resolution records.
- Customer-submitted service data: product, order, customer, behavioural event, communication preference, and integration records. The relevant SmarterMoment customer determines the scope and legal basis.
3. Purposes and legal bases
| Activity | Purpose | Legal basis under Law No. 6698 |
|---|---|---|
| Site sessions and technical logs | Operate and secure the site, authenticate users, and prevent abuse | Article 5/2-f legitimate interests and, where applicable, Article 5/2-ç legal obligation |
| Demo and quote requests | Assess and respond to requests and prepare scope and pricing | Article 5/2-c steps directly related to forming a contract and Article 5/2-f legitimate interests |
| Accounts and subscriptions | Create accounts, provide services, authorise users, and provide support | Article 5/2-c contract formation or performance |
| Billing and dispute records | Meet financial duties and establish, exercise, or protect rights | Articles 5/2-ç and 5/2-e |
| Marketing communications | Send product, campaign, event, and opportunity messages through selected channels | Article 5/1 explicit consent and consent required by Turkish e-commerce rules |
4. Collection methods
Data is collected electronically and partly by automated means through forms, account and panel actions, API and SDK integrations, support correspondence, payment-provider notifications, and server or security logs. Data supplied offline is processed by non-automated means when it forms part of a filing system.
We do not request sensitive personal data. Do not place health, biometric, political, or similar sensitive data in demo or support fields.
5. Disclosures and international transfers
Data may be disclosed only as necessary to hosting, security, communication, email, payment, and support vendors; professional advisers under confidentiality duties; and competent authorities when legally required.
An international transfer is made only where an appropriate mechanism under Article 9 of Law No. 6698 applies. If a transfer is added to a relevant process, the recipient, purpose, and mechanism will be reflected in this notice or a process-specific notice.
6. Retention
- Unsuccessful demo and quote records: up to 24 months after the last interaction.
- Contract, account, subscription, and financial records: up to 10 years after the relationship, subject to mandatory periods.
- Marketing consent, refusal, and evidence: 3 years after the consent ends.
- Technical security logs: up to 24 months unless an incident or legal duty requires longer retention.
- Data is deleted, destroyed, or anonymised when the applicable period ends.
7. Your rights
To exercise your rights under Article 11 of Law No. 6698, send a request identifying you and describing the request to turkayaltintas@smartermoment.com from your registered email address or use another written method accepted by law. Available registered email and postal details appear in the controller card on this page.
Requests are answered free of charge as soon as possible and no later than thirty days. A fee may apply only where permitted by the official tariff.
8. Security and updates
Risk-appropriate measures include access controls, encryption, logging, backups, and network and application security. No internet transmission can be guaranteed absolutely secure.
This notice will be updated before a materially changed processing activity begins. The current version is published on this page.