1. Who we are
Calculativa Yazılım ve Veri Analitiği Limited Şirketi (“Calculativa”, “we”, “us”) is a Limited Şirket (Limited Liability Company) incorporated in İstanbul, Türkiye on 14 March 2022, registered with the İstanbul Ticaret Sicili Müdürlüğü under number 3382451, MERSİS number 0998641372000001, tax number (VKN) 0998641372 (Zincirlikuyu Vergi Dairesi), with its registered office at Analitik Sokak No: 18, Kat: 4, Levent, Beşiktaş, 34330 İstanbul, Türkiye.
We are the data controller for personal data collected through this website and in the course of our own business administration. Where we process personal data on behalf of a client under a service agreement — for example, employee data processed to run payroll, or supplier data processed to maintain their ledger — we act as a data processor, and the client remains the controller.
For any question about this policy or about how we handle your data, contact info@calculativa.com.
2. What personal data we collect
2.1 Data you give us directly
- Enquiry data — name, company name, work e-mail address, telephone number, the service you are interested in and the contents of your message, submitted through our contact form or by e-mail.
- Engagement data — where you become a client, the identification and verification information required to onboard you, including identity documents, proof of address, corporate structure and beneficial-ownership details.
- Correspondence — records of e-mail, telephone and meeting communications with us.
2.2 Data collected automatically
- Technical data — IP address, browser type and version, device type, operating system, referring page and the pages you view. Server logs are generated automatically when you request a page and are used for security and troubleshooting.
- Anti-abuse data — a short-lived, in-memory record of the IP addresses that have recently submitted our contact form, used only to rate-limit automated abuse.
This website does not use advertising, profiling or third-party analytics cookies. See our Cookie Policy for detail.
3. Why we process your data, and on what legal basis
- To respond to your enquiry — legal basis: your consent, given when you submit the contact form, and our legitimate interest in responding to business enquiries.
- To provide our services and administer the contract — legal basis: performance of a contract with you, or steps taken at your request before entering into a contract.
- To meet anti-money-laundering, counter-terrorist-financing, accounting and tax obligations — legal basis: compliance with a legal obligation to which we are subject.
- To secure our website and prevent abuse — legal basis: our legitimate interest in maintaining the integrity and availability of our systems.
4. Who we share data with
We do not sell personal data and we do not share it for advertising purposes. We disclose personal data only to:
- Service providers acting on our instructions — including our hosting provider, e-mail delivery provider and professional advisers. Each is bound by a written data-processing agreement.
- Competent authorities — where disclosure is required by law, including reporting obligations under applicable anti-money-laundering legislation.
- A successor entity — in the event of a merger, acquisition or transfer of business, subject to the protections in this policy.
5. International transfers
Our infrastructure is located within the European Economic Area. Where a service provider processes personal data outside the EEA, we rely on an adequacy decision of the European Commission or on Standard Contractual Clauses together with any supplementary measures required by the circumstances of the transfer.
6. How long we keep data
- Enquiries that do not become engagements — retained for up to 24 months from last contact, then deleted.
- Client records, accounting and tax documentation — retained for the period required by applicable Turkish law, which under the Turkish Commercial Code and Tax Procedure Law is generally 5 to 10 years from the end of the relevant financial year.
- Customer due-diligence records — retained for the period prescribed by applicable anti-money-laundering legislation, generally 5 years from the end of the business relationship.
- Server logs — retained for up to 90 days.
7. How we protect data
Personal data is encrypted in transit using TLS and encrypted at rest. Access is granted on a least-privilege, role-based basis and limited to the named team assigned to an engagement. Access is reviewed periodically and revoked promptly when a role changes. All personnel are bound by written confidentiality obligations. We maintain logging, backup and incident-response procedures, and will notify affected individuals and the supervisory authority of a personal data breach where the applicable thresholds are met.
8. Your rights
Under Article 11 of the Turkish Personal Data Protection Law (KVKK) and, where it applies to you, under the General Data Protection Regulation, you have the right to learn whether your personal data is processed and to request access to it; to have inaccurate data corrected; to have data erased or destroyed; to restrict or object to processing; to receive your data in a portable format; and, where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of processing carried out beforehand.
To exercise any of these rights, contact info@calculativa.com. We respond within one month. There is no charge unless a request is manifestly unfounded or excessive.
If you believe we have not handled your data lawfully, you may lodge a complaint with the Turkish Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu — KVKK), or with the supervisory authority in your country of residence.
9. Children
Our services are provided to businesses. This website is not directed at children and we do not knowingly collect personal data relating to anyone under 16.
10. Changes to this policy
We review this policy periodically and will update the “last updated” date above when it changes. Material changes affecting how we process your data will be communicated directly where we hold contact details for you.