Privacy Policy

This policy explains how PATH İnternet Çözüm Hizmetleri A.Ş. ("PATH", "we", "us") collects and uses personal data when you visit path.com.tr, contact us or apply for a job with us. We process personal data in line with the Turkish Personal Data Protection Law No. 6698 ("KVKK") and, where it applies, the EU General Data Protection Regulation ("GDPR").

1. Who is responsible for your data

The data controller is PATH İnternet Çözüm Hizmetleri A.Ş., Bay Plaza İçerenköy, Çayıryolu Sok. No:5, Ataşehir, İstanbul, Turkey. You can reach us about anything in this policy at info@path.com.tr.

2. What we collect

• Contact form: your first and last name, email address, phone number, the reason you are contacting us and your message.
• Job applications: the details you submit through the application form on our Career page, such as your name, contact details, CV and anything else you choose to include.
• Emails and calls: what you share with us when you write to or call us.
• Usage data: your IP address, browser and device type, the pages you visit, the site that referred you and similar technical information, collected through cookies and our hosting provider's logs.

We do not ask for special categories of personal data. Please do not include them in your messages or applications.

3. Why we use it and our legal basis

• To answer your enquiry and prepare proposals. Taking steps at your request before entering into a contract (KVKK Art. 5/2-c; GDPR Art. 6(1)(b)) and our legitimate interest in responding to business enquiries (KVKK Art. 5/2-f; GDPR Art. 6(1)(f)).
• To assess job applications. Taking steps before an employment contract and our legitimate interest in recruiting (KVKK Art. 5/2-c and 5/2-f; GDPR Art. 6(1)(b) and (f)).
• To keep the site and forms secure. Our legitimate interest in preventing spam, fraud and abuse (KVKK Art. 5/2-f; GDPR Art. 6(1)(f)).
• To understand how the site is used and measure our advertising. Your consent where applicable law requires it (KVKK Art. 5/1; GDPR Art. 6(1)(a)).
• To meet legal obligations and to establish, exercise or defend legal claims (KVKK Art. 5/2-ç and 5/2-e; GDPR Art. 6(1)(c) and (f)).

4. Cookies

The site uses the cookies below. Strictly necessary cookies are not used to track you. You can delete or block cookies in your browser settings, opt out of Google Analytics with the Google Analytics opt-out add-on, and manage ad personalisation in Google My Ad Center.

5. Who we share it with

We do not sell your personal data. We share it only with:

• Service providers that run parts of the site for us: Cloudflare (hosting and delivery), Google (Analytics, Ads and reCAPTCHA), the customer relationship management system that receives contact form submissions, and the recruitment platform behind our job application form. They process data on our instructions.
• Professional advisers such as lawyers and auditors, under confidentiality obligations.
• Public authorities when the law requires it.

6. International transfers

Some of our service providers store or process data outside Turkey, including in the European Union and the United States. Where we transfer personal data abroad, we do so in line with KVKK Article 9 and Chapter V of the GDPR, using safeguards such as standard contractual clauses.

7. How long we keep it

We keep personal data only as long as we need it for the purposes above, or longer where the law requires it or it is needed for a legal claim. Enquiries that do not lead to a business relationship and unsuccessful job applications are deleted, destroyed or anonymised once they are no longer needed.

8. How we protect it

We use technical and organisational measures appropriate to the risk, including encrypted connections (HTTPS), access controls and spam protection on our forms. No method of transmission over the internet is completely secure, but we work to protect your data and review our measures regularly.

9. Your rights

Under KVKK Article 11 you have the right to:

• learn whether we process your personal data and, if so, request information about it;
• learn the purpose of the processing and whether the data is used for that purpose;
• know the third parties in Turkey or abroad to whom it is transferred;
• ask us to correct incomplete or inaccurate data, and to notify the recipients of that correction;
• ask us to delete or destroy your data when the reasons for processing no longer apply, and to notify the recipients;
• object to a result against you that arises solely from automated analysis of your data;
• claim compensation if you suffer damage because of unlawful processing.

If the GDPR applies to you, you also have the right to access, rectify, erase, restrict and port your data, to object to processing based on our legitimate interests, and to withdraw your consent at any time without affecting earlier processing.

To use these rights, write to us at info@path.com.tr or to our address above. We will reply as soon as possible and within 30 days at the latest. You can also complain to the Turkish Personal Data Protection Authority (kvkk.gov.tr) or, if you are in the EU, to your local data protection authority.

10. Children

This site is meant for businesses and job seekers, and is not directed at children. We do not knowingly collect children's data.

11. Links to other sites

The site links to other sites such as LinkedIn, X and Instagram. Their own privacy policies apply when you visit them.

12. Changes to this policy

We may update this policy from time to time. The date at the top shows when it last changed.