Privacy Notice

As Efor Gübre Madencilik Sanayi Ticaret Anonim Şirketi (Efor Gübre), we attach great importance to the security of your personal data. We have prepared this privacy notice to inform you about the processing of your personal data pursuant to Turkish Personal Data Protection Law No. 6698 ("KVKK").

Data Controller

Your personal data is processed by Efor Gübre as the data controller.

Address: İçerenköy Destan Sk. No:6 34760 Ataşehir İstanbul

E-mail: info@eforcorp.com

Personal Data Processed

The following personal data that you share with us through our website or other communication channels is processed:

• Name and Surname
• E-mail Address
• Phone Number
• Message / Request Content
• IP Address
• Tax Address
• Tax Number
• Company Title

Data Processed in the Context of Bilge Toprak AI Assistant Use

If you use the AI-powered chat assistant named Bilge Toprak on our website, in addition to the data processed for general website use, the following data may also be processed:

• The full text of the messages and questions you write to the Bilge Toprak assistant,
• System responses provided by the Bilge Toprak assistant,
• An anonymous session ID generated to maintain the chat session, which does not directly identify you,
• Your chat language preference,
• Date and time information of messages,
• Question intent / classification and recommended product or information references generated by the system.

The Bilge Toprak AI assistant does not directly collect or process your IP address, browser information, location data, user account information, or contact information such as name-surname, phone number, or e-mail address. However, if you voluntarily and with your consent enter personal data such as name-surname, phone, e-mail, address, company information, commercial information, or other personal data into the chat field, this information will be processed as part and content of the chat conversation since the chat content is recorded.

Purposes of Processing

Your collected personal data is processed for the following purposes:

• Receiving, evaluating, and responding to your communication requests,
• Improving service quality and ensuring customer satisfaction,
• Managing request, suggestion, or complaint processes,
• Ensuring information security and technical infrastructure continuity,
• Fulfilling our legal obligations,
• Understanding and responding to questions submitted via the Bilge Toprak AI assistant and providing relevant product, service, or information recommendations,
• Providing, operating, ensuring technical continuity, and improving user experience of the AI-powered chat service,
• Evaluating chat records within the scope of measuring service quality, error detection, technical analysis, and system development,
• Anonymous or aggregated analysis of user requests and statistical reporting,
• Information security, system security, and fulfillment of legal obligations.

Method and Legal Basis of Processing

Your personal data is collected automatically through the contact form on the website or electronic communication channels.

In accordance with Articles 5 and 6 of KVKK:

• The presence of your explicit consent,
• The necessity of fulfilling the data controller's legal obligations,
• Enabling contact with you upon completion of the contact form and your request,

are the legal grounds on which your data is processed.

Personal data processed within the scope of the Bilge Toprak AI assistant is processed electronically and automatically through the chat interface on our website. Such data is processed based on the legal grounds of: the presence of your explicit consent under KVKK Art. 5/1; the necessity of processing for the legitimate interests of our Company as data controller, provided that your fundamental rights and freedoms are not harmed, under KVKK Art. 5/2-f; and where applicable, the fulfillment of legal obligations under KVKK Art. 5/2.

In cases where international data transfer is required via the Bilge Toprak assistant, such transfer will be carried out in accordance with the provisions of KVKK Art. 9 and subject to the necessary conditions; in cases where explicit consent is required, it will be carried out based on your explicit consent.

Transfer of Personal Data

Your collected data may be transferred:

• Only when necessary, to technical service providers from whom we receive services (such as hosting, software, or IT service companies),
• To authorized public institutions and organizations, within the scope of legal obligations.

Transfer in the Context of the Bilge Toprak AI Assistant

If you use the Bilge Toprak AI assistant, the following data:

• Messages you write to the chat field,
• Responses generated by the system,
• Anonymous session ID,
• Chat language,
• Message date and time information, and processing data generated by the system,

may be processed and transferred for the purposes of understanding your questions through the AI model, generating responses, providing product/information recommendations, measuring service quality, technical analysis, and error detection. Within this scope, your personal data may be transferred:

• For the purpose of providing AI processing services, to the Google Gemini API service offered by Google LLC, and to overseas servers located in the United States within this scope,
• For the purpose of storing chat records and conducting technical infrastructure services, to the server infrastructure service provider and to the server infrastructure located in Germany within this scope,
• Only limited to their duties, to authorized company personnel who carry out service quality, technical support, error analysis, and system improvement processes,
• To legally authorized public institutions and organizations, only for the purpose of fulfilling obligations arising from legislation.

International transfers within the scope of the Bilge Toprak assistant will be carried out in accordance with the provisions of KVKK Art. 9 and subject to the relevant transfer conditions. In cases where explicit consent is required, you will be separately informed before the chat service is initiated and your explicit consent will be obtained. If you do not provide explicit consent, you cannot use the Bilge Toprak AI assistant service; however, you may continue to use other sections of our website.

Data Retention Period

Your personal data is retained for the period required by the processing purposes; when this period expires or the relevant purpose ceases, it is deleted, destroyed, or anonymized in accordance with legislation.

Chat records, chat content, system responses, anonymous session ID, chat language, message date and time information, and processing data generated within the scope of the Bilge Toprak AI assistant are retained for 6 months / 180 days, limited to the purposes of measuring service quality, technical analysis, error detection, and system improvement. At the end of this period, the relevant records are automatically deleted, destroyed, or anonymized.

Rights of the Data Subject

Pursuant to Article 11 of KVKK, you have the following rights regarding your personal data:

• To learn whether your personal data is processed,
• To request information if it has been processed,
• To learn the purpose of processing and whether it is used in accordance with its purpose,
• To know the third parties to whom data has been transferred domestically or abroad,
• To request correction if it has been processed incompletely or incorrectly,
• To request deletion or destruction within the framework of the conditions stipulated in KVKK,
• To request notification to third parties to whom these processes have been transferred,
• To object to the emergence of an adverse outcome against you as a result of analysis of the processed data exclusively through automated systems,
• To request compensation in case you suffer damage due to unlawful processing of personal data.

You may submit your requests to exercise these rights in writing or through other methods determined by the Personal Data Protection Board, via info@eforcorp.com.