Privacy Policy

1. Who we are (data controller)

Subul is operated by Subul Global Danışmanlık E-Ticaret Limited Şirketi (Türkiye) and Subul Global Ltd (United Kingdom). For visitors and enquiries handled through this website, the primary data controller is our Türkiye entity, whose contact details appear at the end of this policy.

Where your data is processed in connection with the United Kingdom, Subul Global Ltd acts as controller for those activities.

2. What personal data we collect

We only collect data you choose to give us and limited technical data needed to run the site:

• Contact details you submit through our contact form — your name, email address, company or brand name, area of interest, an optional monthly ad-spend or revenue figure, and the content of your message.
• Communications — any correspondence you send us by email, phone, or messaging.
• Technical and usage data — such as your IP address, browser type, device, and pages viewed, collected automatically by our hosting and security infrastructure for reliability and fraud prevention.
• Preferences — your chosen language and light/dark theme, stored locally in your browser.

3. Why we use your data, and our legal basis

We process your personal data for the following purposes:

• To respond to your enquiry and discuss potential services — on the basis of steps taken at your request prior to a contract, and our legitimate interest in answering business enquiries (KVKK Art. 5).
• To operate, secure, and improve the website — on the basis of our legitimate interest in a safe, functioning site.
• To comply with legal obligations — where the law requires us to retain or disclose data.
• To send you information you have specifically requested — on the basis of your consent, which you may withdraw at any time.

4. Cookies and local storage

We use only essential and functional cookies and local storage — for example, to remember your language and theme preference. We do not currently use advertising or third-party tracking cookies. See our Cookie Policy for details.

5. Who we share your data with

We do not sell your personal data. We share it only with trusted service providers who help us operate, strictly for the purposes above:

• Hosting and content delivery — our website infrastructure provider.
• Email delivery — the provider that transmits contact-form messages to us.
• Professional advisers, and public authorities where required by law.

6. International transfers

Some of our service providers process data outside Türkiye and the United Kingdom (for example in the European Union or the United States). Where we transfer personal data abroad, we rely on appropriate safeguards — such as your explicit consent, contractual necessity, or standard contractual clauses — consistent with KVKK Art. 9 and UK GDPR requirements.

7. How long we keep your data

We keep enquiry and correspondence data for as long as necessary to respond to you and manage our relationship, and thereafter only as required to meet legal, accounting, or dispute-resolution obligations. When data is no longer needed, we delete or anonymise it.

8. How we protect your data

We apply appropriate technical and organisational measures — including encryption in transit, access controls, and vetted service providers — to protect your personal data against loss, misuse, and unauthorised access.

9. Your rights

Under KVKK Art. 11 and, where applicable, the UK GDPR, you have the right to:

• Learn whether your personal data is processed, and request information about it;
• Know the purpose of processing and whether it is used accordingly;
• Know the third parties to whom your data is transferred, at home or abroad;
• Request correction of incomplete or inaccurate data;
• Request deletion or destruction of your data;
• Object to processing, including to automated decisions producing a result against you;
• Request restriction or portability of your data (UK GDPR);
• Withdraw consent at any time; and
• Lodge a complaint with a supervisory authority.

10. Complaints

If you believe your data has been handled unlawfully, please contact us first using the details below. You also have the right to complain to the Turkish Personal Data Protection Authority (KVKK Kurumu, kvkk.gov.tr) or, for UK-related processing, the UK Information Commissioner’s Office (ICO, ico.org.uk).

11. Children

This website is intended for businesses and is not directed at children. We do not knowingly collect personal data from children.

12. Changes to this policy

We may update this Privacy Policy from time to time. The “last updated” date above shows the current version, and material changes will be reflected on this page.

Contact & data controller

For any question about these policies or your personal data — or to exercise your rights — contact the data controller: