This notice is given under Article 10 of Türkiye's Law No. 6698 on the Protection of Personal Data ("KVKK") and explains the personal data we process through roicool.com (the "Site"). The Turkish text prevails.
1. Data controller
Your personal data is processed by Milore Tekstil Gıda ve Toptan Ticaret Limited Şirketi ("Roicool"; Roicool is the brand under which the company provides digital marketing services) as data controller.
- Address: Halil Rıfat Paşa Mah. Yüzer Havuz Sok. Perpa Ticaret Merkezi No:1 İç Kapı No:2072, 34384 Şişli / Istanbul, Türkiye
- E-mail: info@roicool.com
- Phone: +90 531 407 28 45
2. What we process, why, and on what legal ground
Contact, proposal and meeting forms. Your full name, e-mail and message and, if you choose to give them, your company, phone, website and the service you are interested in; the page and language you submitted from, the time of submission, your browser information (user agent) and a record of your commercial-message choice. Purpose: to answer your request, prepare a proposal, arrange a meeting and follow your request up in our customer relationship management (CRM) system. Legal ground: processing directly related to entering into a contract (KVKK Art. 5(2)(c)) and our legitimate interest in answering you (Art. 5(2)(f)).
E-book download form. Your full name, e-mail, company and, if you choose, phone; which e-book you downloaded. Purpose: to give you the e-book and contact you about the topic. Legal ground: providing the content you asked for (Art. 5(2)(c)) and our legitimate interest (Art. 5(2)(f)).
Free tools. The web address you enter in the AI-readiness check is used only to run the check and is not stored. If you ask for the report by e-mail, we process your e-mail address, your name (if given), the score and the band; the report is sent only after you click the confirmation link we e-mail you (double opt-in). The AI-visibility check runs on our own product Ossvy, on ossvy.com; what you enter there is covered by Ossvy's own texts. Purpose: to send the report and contact you at your request. Legal ground: Art. 5(2)(c) and Art. 5(2)(f). Details: Free Tools Terms.
Partner program. The identity, contact, company and business details you give on the application form, and the details of a prospect company and its contact person that an approved partner registers. Purpose: to assess your application, enter into and perform the partner agreement, match registrations and calculate commission. Legal ground: entering into and performing a contract (Art. 5(2)(c)), our legal obligations (Art. 5(2)(ç); invoicing and accounting records) and our legitimate interest (Art. 5(2)(f)). We give the people a partner registers this notice when we first contact them.
Commercial electronic messages. If you tick the separate, unticked box on a form, we send you guides, event and service news by e-mail (and, on the partner form, by SMS). Legal ground: your approval under Law No. 6563 and your explicit consent (KVKK Art. 5(1)). We record your approval in the Message Management System (İYS); you can withdraw it at any time through the link in each message, through İYS or by writing to info@roicool.com. Details: Commercial Electronic Message Consent.
Cookies, site analytics and ad measurement. Every cookie and similar technology other than the strictly necessary ones stays off until you allow it in your cookie choices (Google Consent Mode v2 starts as "denied" in every language). The tag manager loads in every case: in Consent Mode's advanced mode, until you allow them, Google's tags may send count-only signals (for example that a page view happened) without setting cookies or identifiers. If you allow them: under Analytics, usage data such as page views, clicks and scrolling and the Google Analytics client and session IDs; under Marketing, ad click IDs (Google, Meta and, once enabled, Microsoft and LinkedIn), the Meta cookies _fbp and _fbc and, when you submit a form, your e-mail and phone hashed with SHA-256, are sent through a server-side Google Tag Manager (t.roicool.com, on our own server (Hetzner Online GmbH, Germany, EU)) to Google Analytics 4, Google Ads and Meta. Your raw e-mail, phone or name is never sent to these tools. Campaign parameters (UTM), your landing page and the referring site are kept in your browser's local storage for 90 days and stored with your request when you submit a form; click IDs are stored only with marketing consent. Purpose: to improve the Site, measure which channels bring enquiries and manage the ad budget. Legal ground: your explicit consent (Art. 5(1)); for strictly necessary cookies Art. 5(2)(c) and Art. 5(2)(f). Details: Cookie Policy and Explicit Consent.
Security. To protect the forms and tools against automated submissions, your IP address is used for short-term rate limiting, sent to Cloudflare Turnstile for form verification and kept only in hashed form in abuse logs. Purpose: the security of the Site, the forms and the data. Legal ground: our legitimate interest (Art. 5(2)(f)) and our data-security obligation (Art. 5(2)(ç), Art. 12).
Job applications. The CV and contact details you e-mail us for a job posting. Purpose: to assess your application. Legal ground: processing directly related to entering into a contract (Art. 5(2)(c)). Please do not include special categories of data (health, religion, association membership and the like) in your CV.
Data-subject requests. The request and identity-check details you send us to exercise your rights. Purpose: to conclude your request. Legal ground: our legal obligation (Art. 5(2)(ç), Art. 13).
We do not ask for special categories of personal data (KVKK Art. 6) on the Site.
3. How we collect data
Directly from you when you fill in a form on the Site; automatically from your browser through cookies, local storage and similar technologies when you use the Site (other than the strictly necessary ones, only with your permission); by e-mail or post for job applications and data-subject requests; and, for partner registrations, from the partner who registers you.
4. Who we share data with, and why
- Our service providers (data processors): the server hosting the Site, its content management system and its database (Hetzner Online GmbH, Germany, EU); Cloudflare, Inc. (US) for the domain, content delivery, the firewall, form security (Turnstile) and encrypted backups (Cloudflare R2, EU jurisdiction); our CRM system, which runs on our own server (open-source Twenty; there is no separate CRM provider); our e-mail delivery service, Resend (Plus Five Five, Inc., US); Functional Software, Inc. (Sentry, US) for error monitoring, set up to receive no personal data; with your permission, Google LLC / Google Ireland Limited and Meta Platforms Ireland Limited for measurement and advertising; the media server for the home page video (Cloudflare R2, Cloudflare, Inc.); Google Meet for meetings (Google Workspace; Google Ireland Limited / Google LLC). When an editor asks the admin panel's AI assistant about a request in the inbox, the assistant may pass that request's content to the AI provider enabled in the panel (Anthropic (default); OpenAI / Google / DeepSeek only if enabled). They process the data only on our behalf, on our instructions and for the purposes in this notice.
- Authorised public bodies: where a legal obligation requires it, and only to that extent.
- Our legal, accounting and audit advisers: as far as needed to meet our legal obligations and protect our rights.
Transfers abroad. Google, Meta, Cloudflare, Resend, Sentry, and the admin panel's AI provider may process data, and as our server is in Germany (EU) so is the data of the Site and the CRM, processed data on servers outside Türkiye. These transfers are made under KVKK Art. 9 on the basis of standard contracts notified to the Board (Art. 9(4)(c)). The list, tool by tool: International Data Transfers.
5. How long we keep data
We keep data for as long as the purpose requires and the law prescribes. Form requests are automatically anonymised in the Site's records 24 months after we receive them; the send-queue copy of a request that could not be passed to the CRM is deleted 30 days after the last attempt. Event data in Google Analytics 4 is deleted by Google after 14 months. People in the EU and the UK should also read our GDPR Privacy Notice. The other periods are in our Data Retention and Destruction Policy. When a period ends, the data is deleted, destroyed or anonymised.
6. Your rights under KVKK Art. 11
By applying to us you can:
- learn whether your personal data is processed;
- request information if it has been processed;
- learn the purpose of processing and whether it is used for that purpose;
- know the third parties in Türkiye or abroad to whom it is transferred;
- ask for it to be corrected if it is incomplete or wrong;
- ask for it to be erased or destroyed under the conditions in KVKK Art. 7;
- ask for corrections, erasure or destruction to be notified to the third parties it was transferred to;
- object to a result against you that arises solely from automated analysis;
- claim compensation for damage caused by unlawful processing.
Where processing is based on your explicit consent you can withdraw it at any time; you can change your cookie permissions through "Cookie settings" at the foot of every page.
7. How to apply
Use our data-subject request form, or send your request in writing, as set out in the Communiqué on the Procedures and Principles of Applications to the Data Controller, to Halil Rıfat Paşa Mah. Yüzer Havuz Sok. Perpa Ticaret Merkezi No:1 İç Kapı No:2072, 34384 Şişli / Istanbul, Türkiye, with a secure electronic or mobile signature, or from the e-mail address we have on record for you to info@roicool.com. We conclude your request as soon as possible and within 30 days at the latest, free of charge; if it involves an additional cost, the fee in the Board's tariff may be charged (KVKK Art. 13). If we reject your request, you find our answer insufficient or we do not answer in time, you can complain to the Personal Data Protection Board within 30 days of learning our answer and in any case within 60 days of your application (KVKK Art. 14).
8. Changes
We update this notice when our processing changes. The current text and its date are on this page; all our legal texts are listed on Legal.