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Analytics Privacy Notice

DRAFT — PENDING LEGAL REVIEW. This text has not been reviewed by counsel and is not claimed to be compliant with any law.

1. Data controller

Data controller: Shopinger.
Address: (exact address to be added before production).
VERBİS registration: (VERBİS status to be confirmed before production).

This store is hosted on a platform operated by Shopinger. The analytics measurement described here is carried out by the platform, not by the store owner.

2. What is collected

When you visit this store, the following is recorded for each page view:

Page and visit data:

• the path of the page you view and its query string — the ?... part of the address: this includes the term you type into the store's search (?q=...) and any campaign / advertising identifiers present in the link you arrived on (utm_source, utm_medium, utm_campaign, utm_content, utm_term, gclid, fbclid, msclkid, ttclid, twclid, li_fat_id);
• the page title;
• the store's hostname;
• the referring address (referrer): its domain, path and query string;
• the event type (page view) and a timestamp;
• and, on stores where interaction events are enabled, a small set of platform-defined interaction events (for example, adding an item to the cart) — recorded as an event name only, with no additional detail about the product.

Device, browser and location data:

• your browser (e.g. Chrome), operating system (e.g. iOS) and device type (e.g. mobile), derived from your browser identification string (user-agent);
• your screen resolution;
• your browser's language preference;
• location derived from your IP address: country, region and city;
• a session id and a visit id: irreversible values derived by hashing your IP address and browser information together with a rotating secret (a salt).

Your raw IP address is not stored. The IP address is used only as an input to the session id and the location above; the analytics database has no column for an IP address.

No cookies are set. The analytics measurement places no cookie and stores no persistent identifier in your browser.

3. Purpose of processing

The data is processed solely for aggregate traffic measurement: how many visits a store receives, which pages are viewed, and where visitors arrive from. It is not used for ad targeting, profiling, or personalisation, and visitors are not tracked across other websites.

4. Method of collection and legal basis

The data is collected automatically, by a measurement script placed on store pages by the platform, which reports to the platform's own infrastructure.

Legal basis: legitimate interest of the data controller under KVKK Art. 5/2-(f) (aggregate, anonymous traffic measurement). (Final confirmation of this basis by counsel before production.)

5. Recipients and transfers

Analytics data is not transferred to any third party. The analytics tool (Umami) is self-hosted on the platform's own servers and the data stays on the platform's infrastructure. There is no third-party analytics provider, ad network, or data broker. Cross-border transfer status: Analytics data is processed on cloud infrastructure (AWS) in the Germany (Frankfurt) region, on the platform's self-hosted Umami instance. (The legal characterisation of any cross-border transfer to be clarified before production.)

6. Retention

The secret (salt) that derives the session id is rotated daily, which prevents the same visitor from being re-identified across days. Retention period for analytics records: Aggregate analytics records are retained for at most 14 months and then destroyed. (Exact period to be confirmed before production.)

7. Your rights (KVKK Art. 11)

Under Article 11 of the Law you have the right to: learn whether your personal data is processed; request information if it has been processed; learn the purpose of processing and whether the data is used in accordance with that purpose; know the third parties to whom the data is transferred, at home or abroad; request rectification of incomplete or inaccurate data; request erasure or destruction of the data; request that these actions be notified to the third parties to whom the data was transferred; object to a result adverse to you arising from analysis of the data exclusively by automated means; and claim compensation for damage arising from unlawful processing.

Request channel: kvkk@shopinger.co (to be confirmed before production).