1 Data Controller Identity

The data controller responsible for the processing of your personal data is:

As the data controller, Real Panel determines the purposes and means of processing your personal data and is responsible for establishing and managing the data recording system (veri kayıt sistemi).

2 Personal Data Categories

In accordance with KVKK Article 10, we inform you that the following categories of personal data may be processed:

Real Panel does not process any special categories of personal data (sensitive data) as defined in KVKK Article 6, such as health data, biometric data, religious beliefs, or political opinions.

3 Processing Purposes

Your personal data is processed for the following purposes, as required by KVKK Article 10(1)(c):

3.1 Core Business Purposes

• Processing and responding to quote requests for sandwich panel products.
• Providing technical support, product specifications, and installation guidance.
• Managing customer relationships and business partner communications.
• Executing and fulfilling sales orders, including export documentation and logistics coordination for deliveries to Romania, Bulgaria, Georgia, North Macedonia, and Kosovo.

3.2 Website & Technical Purposes

• Ensuring the proper functioning and security of realpanel.com.tr.
• Analyzing website traffic and user behavior to improve content and user experience.
• Operating interactive tools that may be offered on the Site (such as a panel selector wizard or U-value calculator).
• Delivering embedded video content (installation guides) via YouTube integration.

3.3 Marketing & Communication Purposes

• Sending product updates, industry news, and newsletters (only with your explicit consent).
• Measuring the effectiveness of digital advertising campaigns.
• Inviting you to trade fairs, events, and product demonstrations.

3.4 Legal & Compliance Purposes

• Fulfilling legal obligations under Turkish commercial law, tax law, and KVKK.
• Responding to requests from judicial or administrative authorities.
• Maintaining records required by Turkish legislation (Turkish Commercial Code No. 6102, Tax Procedure Law No. 213).
• Resolving disputes and enforcing contractual rights.

4 Legal Basis for Processing

Your personal data is processed based on one or more of the following legal grounds as specified in KVKK Article 5(2):

5 Data Collection Methods

As required by KVKK Article 10(1)(ç), we inform you that personal data is collected through the following channels:

5.1 Direct Collection (From You)

• Contact form submissions on realpanel.com.tr
• Quote request form (Teklif Talep Formu) submissions
• Email, phone, and written correspondence
• In-person meetings, trade fair and event interactions
• Business card exchanges

5.2 Automatic Collection (During Website Visits)

• Cookies and similar tracking technologies (see our Cookie Policy)
• Server logs recording IP address, browser, and device information
• Google Analytics tracking scripts
• Interaction logs from any interactive tools offered on the Site

5.3 Indirect Collection (From Third Parties)

• Public business directories and trade registries
• Trade fair and exhibition organizer attendee lists
• Business partner referrals and introductions
• Social media platforms (LinkedIn) for B2B communication purposes

6 Data Recipients & Transfers

In accordance with KVKK Articles 8 and 9, your personal data may be shared with the following categories of recipients, strictly within the scope of the processing purposes stated above:

6.1 Domestic Transfers (KVKK Art. 8)

• Group companies and affiliates — for coordinated business operations and shared services.
• Service providers — web hosting, IT infrastructure, CRM systems, email delivery, and accounting software providers acting as data processors under contractual obligations.
• Professional advisors — lawyers, auditors, and tax consultants under professional confidentiality obligations.
• Authorized public institutions — Turkish courts, tax authorities, and other bodies authorized by law to request personal data.

6.2 International Transfers (KVKK Art. 9)

• Hosting and infrastructure providers — the Site, its databases, and form submissions are hosted on servers located in Frankfurt, Germany, operated by our hosting provider under data processing agreements.
• Export market partners — authorized distributors and logistics partners in Romania, Bulgaria, Georgia, North Macedonia, and Kosovo, solely when necessary to fulfill your order or quote request.
• Technology service providers — Google (Analytics, Maps, Ads), Meta (Facebook Pixel), YouTube, and LinkedIn, whose servers may be located outside Türkiye.

For international transfers, we ensure appropriate safeguards are in place as required by KVKK Article 9, including contractual commitments from receiving parties to maintain adequate data protection standards, or your explicit consent where applicable.

7 Cross-Border Transfer Safeguards

When personal data is transferred to countries outside Türkiye, we apply one or more of the following safeguards in accordance with KVKK Article 9(2):

• Adequate country determination — where the KVKK Board has determined that the recipient country provides adequate protection.
• Contractual safeguards — standard contractual clauses and undertakings submitted to the KVKK Board by the data controller and the foreign recipient guaranteeing adequate protection.
• Explicit consent — where neither adequacy nor contractual safeguards apply, we may rely on your explicit, informed consent for the specific transfer.
• Legal exceptions — transfers necessary for the performance of a contract, for legitimate interests, or as required by law, as specified in KVKK Article 5(2) conditions.

Our primary hosting infrastructure is located in Frankfurt, Germany; this transfer is carried out under the safeguards described above. If you are located in the European Union, the processing of your personal data may also be subject to the EU General Data Protection Regulation ("GDPR"). Please see our Privacy Policy for details on how we process personal data under the GDPR, including your rights and the applicable legal bases.

8 Data Retention Periods

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Once the retention period expires, personal data is deleted, destroyed, or anonymized in accordance with KVKK Article 7 and the Regulation on the Deletion, Destruction, or Anonymization of Personal Data.

9 Technical & Administrative Security Measures

In accordance with KVKK Article 12, Real Panel implements the following technical and administrative measures to protect personal data against unlawful processing, unauthorized access, and accidental loss or destruction:

9.1 Technical Measures

• SSL/TLS encryption (HTTPS) for all data transmitted through the website.
• Firewall and intrusion detection systems protecting server infrastructure.
• Regular security vulnerability scans and penetration testing.
• Encrypted storage for databases containing personal data.
• Automated backup systems with secure offsite storage.
• Access control mechanisms with role-based permissions.
• Anti-virus and anti-malware software on all systems.

9.2 Administrative Measures

• Internal personal data processing policies and procedures.
• Regular employee training on KVKK obligations and data protection awareness.
• Confidentiality agreements with all employees who handle personal data.
• Data processor agreements with all third-party service providers (KVKK Art. 12(2)).
• Periodic internal audits of data processing activities.
• Data breach incident response procedures.
• Personal Data Retention and Destruction Policy in compliance with regulatory requirements.

10 Your Rights Under KVKK

Pursuant to KVKK Article 11, as a data subject, you have the following rights with respect to your personal data:

11 How to Exercise Your Rights

To exercise any of the rights listed above, you may submit an application to Real Panel using one of the following methods, as specified in the Communiqué on Application Procedures and Principles:

11.1 Application Methods

11.2 Application Requirements

Your application must include the following information:

• Your full name and surname (and Turkish Republic ID number for Turkish citizens, or nationality, passport number, or ID number for foreign nationals).
• Your residential or business address for notification purposes.
• Your email address, phone, and/or fax number (if available).
• The subject matter of your request, clearly stating which right(s) you wish to exercise.
• Any supporting documents or evidence related to your request.

11.3 Response Timeline

Real Panel will process your application free of charge within 30 days from the date of receipt. If additional research is required, the period may be extended by a further 30 days, in which case you will be notified. If the response requires additional costs (e.g., providing data on physical media), a fee may be charged in accordance with the tariff determined by the KVKK Board.

12 Supervisory Authority

If you are not satisfied with our response to your application, or if you believe your rights have been violated, you have the right to lodge a complaint with the Turkish Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu):

Under KVKK Article 14, you may file a complaint with the Board within 30 days of receiving our response to your application, or within 60 days of the date of your original application if no response has been provided. Complaints must first be directed to the data controller (Real Panel) before being filed with the Board.

13 Updates to This Disclosure

This KVKK Disclosure Text may be updated from time to time to reflect changes in our data processing activities, applicable legislation, or guidance from the Personal Data Protection Board. When material changes are made, the updated version will be published on this page with the revised date below.

We encourage you to review this page periodically. For significant changes that affect your rights, we may also notify you via email if your contact information is in our records.

14 Contact Information

For any questions, concerns, or requests regarding this KVKK Disclosure Text or our personal data processing activities: