Personal Data and General Confidentiality Agreement

Personal Data and General Privacy Policy

Last Updated: February 1, 2025

This Privacy Policy describes how Smart M LTD (hereinafter referred to as the "Company") collects, processes, stores and protects personal data of users within the scope of services provided through hostingservisi.com.tr.

1. Data Controller

Company Name: Smart M LTD
Registration: Hong Kong SAR, China
Address: 22/F, 3 Lockhart Road, Wan Chai, Hong Kong
Email: info@hostingservisi.com.tr
Website: https://hostingservisi.com.tr

2. Personal Data Collected

The following personal data is collected in order to provide our services:

• Identity Information: Name, surname, company name, tax identification number
• Contact Information: Email address, phone number, postal address
• Financial Information: Billing details, payment method information (credit card details are not stored directly by us; they are processed through PCI DSS compliant payment providers)
• Account Information: Username, password (stored encrypted), account preferences
• Technical Information: IP address, browser type, operating system, access dates and times, pages visited
• Service Usage Information: Hosting account details, domain registrations, resource usage statistics, support requests

3. Purposes of Processing Personal Data

Personal data collected is processed for the following purposes:

• Provision and management of hosting, server and domain services
• Creation and management of customer accounts
• Billing, payment transactions and accounting processes
• Provision of technical support services
• Notifications regarding service interruptions, maintenance and updates
• Fulfillment of legal obligations
• Improvement and analysis of service quality
• Prevention of fraud and abuse
• Marketing and campaign notifications with user consent

4. Legal Basis for Processing

Your personal data is processed based on the following legal grounds:

• Necessity for the performance of the service agreement
• Fulfillment of legal obligations
• Our legitimate interests (service security, fraud prevention)
• Your explicit consent (for marketing communications)

5. Cookies

The following types of cookies are used on our website:

• Essential Cookies: Cookies necessary for the proper functioning of the website (session management, security)
• Analytics Cookies: Cookies used to collect visitor statistics and measure site performance
• Functional Cookies: Cookies used to remember user preferences such as language selection and theme choice

You can disable cookies through your browser settings; however, some site functions may be restricted in this case.

6. Sharing of Personal Data

Your personal data will not be shared with third parties except in the following circumstances:

• Data Center Providers: For server infrastructure services (Hetzner Online GmbH, Germany)
• Payment Providers: PCI DSS compliant payment institutions for secure payment processing
• Domain Registrars: For domain registration procedures as required by ICANN rules
• Legal Requirements: In case of court orders, legal obligations or requests from authorized public institutions
• SSL Certificate Providers: For SSL/TLS certificate issuance procedures

Your personal data will never be sold or rented to third parties for marketing purposes under any circumstances.

7. Data Security

The following technical and administrative measures are implemented to ensure the security of your personal data:

• Secure data transmission with SSL/TLS encryption
• Firewall and DDoS protection systems
• Regular security updates and patch management
• Access control mechanisms and authorization
• Database encryption and regular backups
• Staff privacy training and access restrictions
• 24/7 server monitoring and security auditing

8. Data Retention Period

Your personal data is retained during the service period and for the following periods after termination of service, within the framework of legal obligations:

• Account Information: 1 year from account closure
• Invoice and Payment Records: 5 years as required by law
• Support Requests: 2 years from the last transaction
• Technical Logs: Maximum 1 year
• Communication Records: 3 years from last communication

Data whose retention period has expired is securely deleted or anonymized.

9. User Rights

You have the following rights regarding your personal data:

• To learn whether your personal data is being processed
• To request information if your personal data has been processed
• To learn the purpose of processing your personal data and whether it is used in accordance with its purpose
• To know the third parties to whom your personal data is transferred domestically or abroad
• To request correction of your personal data if it has been processed incompletely or incorrectly
• To request deletion or destruction of your personal data
• To object to a conclusion arising against you through the analysis of processed data exclusively by automated systems
• To claim compensation for damages arising from the unlawful processing of your personal data

To exercise your rights, you can send an email to info@hostingservisi.com.tr. Your requests will be responded to within 30 days at the latest.

10. International Data Transfer

Our server infrastructure is located in Germany (Hetzner Online GmbH). Your data is protected in accordance with the European Union General Data Protection Regulation (GDPR) standards. Our company is registered in Hong Kong and also complies with obligations under the Hong Kong Personal Data (Privacy) Ordinance (PDPO).

11. Childrens Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal data from individuals under 18. If such a situation is detected, the relevant data will be deleted immediately.

12. Policy Changes

The Company reserves the right to update this Privacy Policy without prior notice. Changes take effect on the date they are published on the website. In case of significant changes, a notification will be sent to your registered email address.

13. Governing Law and Dispute Resolution

This policy is governed by the laws of the Hong Kong Special Administrative Region. Hong Kong courts shall have jurisdiction over any disputes that may arise between the parties.

14. Contact

For questions or requests regarding our privacy policy, you can contact us:

Smart M LTD
Address: 22/F, 3 Lockhart Road, Wan Chai, Hong Kong
Email: info@hostingservisi.com.tr
Web: https://hostingservisi.com.tr