This policy explains the principles under which Milore Tekstil Gıda ve Toptan Ticaret Limited Şirketi ("Roicool") processes and protects the personal data of visitors to roicool.com (the "Site") and of people who contact us through it. Which data is processed, for what purpose and on what legal ground is set out in detail in our KVKK Privacy Notice. The Turkish text prevails.
1. Scope
This policy covers visits to the Site, the forms on it (contact, proposal, meeting, e-book, partner application), the free tools, your cookie choices and the e-mails you exchange with us. Data we process on behalf of our clients as part of the services we provide them is covered by the service agreement and by our client's own privacy notice, not by this policy.
2. Our principles
We process personal data in line with the principles in Article 4 of Law No. 6698 on the Protection of Personal Data ("KVKK"): lawfully and fairly; accurately and, where necessary, kept up to date; for specified, explicit and legitimate purposes; relevant, limited and proportionate to those purposes; and kept only as long as the law requires or the purpose needs.
In practice: on our forms only the fields we need to answer you are required; approval for commercial messages is a separate, unticked box; non-essential cookies stay off until you allow them; ad tools never receive your raw contact details, only hashed values and only with your permission; form requests are automatically anonymised after 24 months.
3. What we collect (summary)
- What you give us: your name, e-mail, phone, company, website, message and the choices you make on a form.
- What is collected automatically: strictly necessary cookies; with your permission, analytics and marketing cookies and campaign and click information; your IP address for security (briefly, and in hashed form).
- What third parties give us: in the partner program, prospect details that an approved partner registers with us.
The Site is not directed at people under 18 and we do not knowingly collect children's data.
4. How we protect data
Some of the technical and organisational measures we take under KVKK Art. 12:
- The Site and the admin panel are reached only over an encrypted connection (HTTPS); the panel has role-based access and only authorised staff who need it see personal data.
- Forms and tools are protected against automated abuse with Cloudflare Turnstile, rate limits and hidden trap fields; abuse logs keep IP addresses only in hashed form.
- Secrets and access keys are kept only in the server environment, never in the code repository.
- We sign contracts with confidentiality and data-security obligations with the providers that process data for us.
- Data whose retention period has ended is deleted, destroyed or anonymised under our Data Retention and Destruction Policy.
If a data breach occurs, we notify the people concerned and the Personal Data Protection Board as soon as possible, as KVKK Art. 12(5) requires.
5. Sharing
We do not sell personal data. We share it only as far as needed with the service providers listed in our KVKK Privacy Notice (hosting, CRM, e-mail, form security and, with your permission, measurement and advertising), with authorised public bodies and with our advisers. Transfers abroad are made in line with KVKK Art. 9; the list, tool by tool, is on International Data Transfers.
6. Visitors outside Türkiye
People in the European Union and the United Kingdom should also read our GDPR Privacy Notice; visitors in the United States our US State Privacy Notice.
7. Cookies
How we use cookies and similar technologies, how long each one is kept and how to change your choices is explained in our Cookie Policy. You can change your choices at any time through "Cookie settings" at the foot of every page.
8. Links to other sites
The Site links to other sites (for example Ossvy, our social media accounts and our clients' sites). Their owners are responsible for their privacy practices; we recommend reading their own texts.
9. Your rights and contact
You can use your rights under KVKK Art. 11 with our data-subject request form or through the channels in our KVKK Privacy Notice. Questions: info@roicool.com.
10. Changes
We update this policy when our practices change; the current text and its date are on this page. All our legal texts are listed on Legal.