Privacy Policy

1. Data Controller and Privacy Contact

The data controller responsible for personal data processed through this website is:

NANODRAG Teknoloji İç ve Dış Ticaret Sanayi Limited Şirketi
Saray Mah. 185 Cad. 7 No
06980 Kahramankazan, Ankara, Turkey
Telephone: +90 312 514 2488
Email: info@dragsys.com

For questions about this Privacy Policy or requests concerning personal data, please contact us at info@dragsys.com. No Data Protection Officer has been appointed; this contact is provided for privacy enquiries and data subject requests.

2. EU Representative under Article 27 GDPR

Where the EU General Data Protection Regulation (GDPR) applies to our processing, our representative in the European Union is:

NANODRAG TECHNOLOGY GmbH
Alfred-Herrhausen-Allee 3-5
65760 Eschborn, Germany
Telephone: +49 6196 400816
Email: info@drag-lab.de

The EU Representative acts as a contact point for data subjects and supervisory authorities in the European Union. The appointment does not make the EU Representative the controller of the personal data processed through this website and does not constitute the appointment of a Data Protection Officer.

3. Scope and Applicable Data Protection Law

This Privacy Policy applies when you visit the DragSYS website, submit a form, use live chat, subscribe to updates, respond to our communications or otherwise interact with us through the website. Personal data means information relating to an identified or identifiable natural person.

Our processing is primarily governed by Turkish Personal Data Protection Law No. 6698 (KVKK). The GDPR also applies where the relevant processing falls within its territorial scope, including where goods or services are offered to individuals in the European Union or their behaviour in the European Union is monitored.

4. Categories and Sources of Personal Data

Depending on how you use the website, we may process:

• identity and professional information, such as name, salutation, job title, department and company
• contact information, such as postal address, country, telephone number and email address
• enquiry, quotation, order, product, warranty, service and distributor-application information
• communications and content you submit through forms, email or live chat
• technical and usage information, such as IP address, device, browser, operating system, pages viewed, interactions, referrer and cookie or similar identifiers
• marketing preferences, subscription confirmation, campaign interaction and consent records

We obtain this information directly from you, automatically from your device when permitted, from the organisation you represent, and from authorised service providers used to operate and secure the website and communications.

5. Purposes and Legal Grounds

We process personal data for the following purposes:

• operating, securing, maintaining and improving the website
• answering enquiries and preparing quotations
• taking steps before a contract and administering customer, warranty, support and distributor relationships
• sending requested updates and marketing communications
• measuring website and advertising performance where consent has been given
• complying with legal obligations and establishing, exercising or defending legal claims

Under KVKK, processing is based, as applicable, on explicit consent or on another condition permitted by Articles 5 and 6, including processing required by law, necessary for establishing or performing a contract, necessary for compliance with a legal obligation, necessary for establishing, exercising or protecting a right, or necessary for our legitimate interests where this does not prejudice fundamental rights and freedoms.

Where the GDPR applies, the corresponding legal bases are consent under Article 6(1)(a), pre-contractual steps or contract performance under Article 6(1)(b), legal obligations under Article 6(1)(c), and legitimate interests under Article 6(1)(f). Our legitimate interests include secure website operation, effective business communication, customer support, service improvement and protection of legal rights.

6. Website Hosting and Server Logs

The website is hosted by a service provider using servers located in Germany. When you access the website, server logs may record:

• IP address
• date and time of access
• requested page or file and data transferred
• referrer URL
• browser, operating system and device information
• access status and error information

This information is processed to deliver the website, maintain stability, detect misuse and protect our systems. Server logs are generally deleted after no more than 14 days, unless longer retention is necessary to investigate an incident, comply with law or establish or defend legal claims.

7. Cookies and Consent Choices

We use cookies and similar technologies. Technologies necessary for the website to function may operate without optional consent where permitted by law. Analytics, advertising and optional communication technologies are activated only after you provide the relevant consent through the cookie banner.

You may accept, refuse or withdraw consent by category through the cookie banner and the Cookie Settings link in the website footer. Withdrawing consent does not affect processing carried out before withdrawal. Browser controls may also be used to delete or block cookies, although this may affect website functions.

Making this Privacy Policy available, or confirming that you have read it, does not by itself constitute consent to optional analytics, advertising technologies, live chat or marketing communications. Where a website form includes a separate, optional marketing-consent checkbox, selecting that checkbox and submitting the form constitutes an affirmative consent for the marketing purposes stated in the checkbox. The marketing-consent checkbox is not pre-selected and consent to marketing is not required in order to submit an enquiry, request a quotation or support, register a warranty, apply to become a distributor or purchase a product or service.

8. Website Forms

The website provides forms for contacting us, requesting a quotation, requesting technical support, registering a warranty and applying to become a distributor. Depending on the form, we may process contact and professional details, message content, product category, model, serial number, purchase and failure dates, technical issue, requested service, submitted files, distribution territory and other business information you choose to provide.

We use form data to respond, prepare quotations, take pre-contractual steps, perform contracts, provide support, administer warranty matters and assess potential distribution relationships. Please do not submit confidential personal data or special categories of personal data, including health information, unless specifically requested and an appropriate legal basis and secure method are available.

Where you separately opt in to marketing through a website form, we record the consent information needed to demonstrate when and how the consent was given and use the email address for the marketing purposes described below. Privacy information and marketing consent are presented separately so that the marketing choice remains voluntary.

9. Marketing Emails, Newsletter and Company Updates

If you expressly agree to receive marketing communications, including by selecting an optional marketing-consent checkbox on a website form, we may add your email address to our regular marketing and newsletter list and use it to send product information, offers, newsletters, company news, event information and other promotional communications relating to DragSYS and the products and services offered by NANODRAG Teknoloji İç ve Dış Ticaret Sanayi Limited Şirketi. The consent is voluntary and may be withdrawn at any time.

Where marketing consent is collected electronically outside the İleti Yönetim Sistemi (İYS), we handle the consent in accordance with the applicable Turkish commercial electronic communications rules, including the required confirmation to the recipient and registration of the consent in İYS within the applicable period. Marketing consent is not obtained through a pre-selected option and is not made a condition for receiving a product, service, quotation, support or warranty service.

Separate marketing consent is not required for communications that are necessary to respond to your request or administer an existing transaction, such as quotations, orders, delivery, payment, warranty, support, product-safety notices or legally required information. These communications are not used to promote unrelated products or services unless you have separately consented to such marketing.

Where the GDPR applies, marketing based on your consent is processed under Article 6(1)(a) GDPR. You may withdraw consent at any time with effect for the future. You may also object to processing for direct marketing at any time in accordance with Article 21 GDPR.

You may unsubscribe or object to marketing at any time by using the unsubscribe option provided in the email, replying to the message, contacting info@dragsys.com or, where applicable, exercising your preference through İYS. We record and respect opt-out requests and will stop sending marketing communications through the relevant channel after a valid objection, subject to communications that remain necessary for contractual, warranty, support, product-safety, legal or administrative purposes.

We may use authorised email-delivery, customer-relationship and business-communication service providers to send messages, manage recipient lists, maintain consent and objection records and measure campaign delivery or interaction where legally permitted. Such providers receive only the information required for those services and are subject to the safeguards described in this Policy.

10. Live Chat

We use Tawk.to to allow visitors to communicate with us directly. The service is activated only after you consent to the relevant optional technology. If you use live chat, it may process the name, email address, message and other information you enter, together with IP address, device, browser, access time and pages visited during the chat session.

The service is used to answer enquiries and provide support. Where applicable, consent supports activation of the service; subsequent handling may also be necessary for requested pre-contractual steps or contract performance.

Provider information: Tawk.to Privacy Policy

11. Microsoft Clarity

With your consent, we use Microsoft Clarity to understand website use and improve navigation, content and usability. Clarity may process page views, clicks, scrolling, mouse movements, device and browser characteristics, approximate location derived from the IP address, referring pages and session interactions. We configure the service to avoid intentionally collecting information entered into sensitive form fields.

Further information: Microsoft Privacy Statement

12. Google Analytics

With your consent, we use Google Analytics to measure website use and improve our content and services. It may process online and cookie identifiers, device and browser information, approximate location, referrer information, pages viewed, interactions and campaign information. IP address information is handled using the IP anonymisation and data-minimisation features applicable to Google Analytics.

User-level and event-level data associated with cookies and user identifiers is retained for up to 14 months in our Google Analytics settings, after which it is deleted automatically, subject to any shorter period applied by Google.

Further information: Google Privacy Policy

13. Google Ads Conversion Tracking

With your consent, we use Google Ads conversion tracking to measure whether an advertisement leads to an action on the website, such as a page visit, enquiry or submitted form. Google may process cookie and advertising identifiers, device and browser information, ad interactions, pages viewed and conversion events. We receive campaign and conversion information and do not seek to identify individual visitors through those reports.

If you are signed in to a Google account, Google may associate information with that account in accordance with its own settings and privacy information.

Further information: Google Privacy Policy

14. Recipients and Service Providers

Personal data is accessible to authorised employees and persons who require it for their duties. We may share relevant information with providers of website hosting and operation, email delivery, business communications, analytics, advertising, live chat, IT support and data storage. Depending on the service, a provider may act as our processor or may process certain information under its own legal responsibilities.

We may also disclose information within our corporate group where necessary for administration, sales, support, compliance or customer service, and to professional advisers, public authorities, courts or other recipients where required by law or necessary to establish, exercise or defend legal rights. Access is limited to what is necessary for the relevant purpose.

15. International Transfers

Because we use service providers and group companies located outside Turkey, personal data may be processed in Germany, elsewhere in the European Economic Area, the United States or other countries in which an authorised provider or its sub-processors operate. The countries involved depend on the service used and the provider’s current infrastructure.

Transfers from Turkey are carried out in accordance with Article 9 KVKK using the applicable legal transfer condition and safeguards. Depending on the transfer, these may include an adequacy decision, binding corporate rules, a standard contract published by the Turkish Personal Data Protection Authority, an approved written undertaking, or a statutory exception available for an incidental transfer. Where the GDPR applies to a subsequent transfer, an applicable GDPR transfer mechanism and any required supplementary safeguards are used.

We require service providers to protect personal data through appropriate contractual, technical and organisational measures and limit transfers to what is necessary for the stated purposes.

16. Retention

Unless a specific period is stated in this Policy, we retain personal data only for as long as necessary for the purpose for which it was collected. We then delete, destroy or anonymise it unless continued retention is required by commercial, tax, accounting, product-safety, warranty or other legal obligations, or is necessary to establish, exercise or defend legal claims. Consent, subscription, İYS registration and marketing-objection records may be retained as necessary to demonstrate compliance and ensure that opt-out requests continue to be respected.

17. Your Rights under KVKK

Under Article 11 KVKK, you may apply to us to:

• learn whether your personal data is processed and request information about the processing
• learn the purpose of processing and whether the data is used consistently with that purpose
• learn the third parties in Turkey or abroad to whom personal data has been transferred
• request correction of incomplete or inaccurate personal data and notification of the correction to relevant recipients
• request deletion or destruction where the legal conditions are met and notification to relevant recipients
• object to an outcome against you arising exclusively from analysis by automated systems
• claim compensation where you suffer damage because personal data was processed unlawfully

To exercise these rights, contact info@dragsys.com. Your application should identify you, specify the right requested and include information reasonably necessary to locate the relevant records and verify identity. Applications are handled in accordance with KVKK and applicable procedures.

18. Additional Rights Where the GDPR Applies

Where the GDPR applies, and subject to its conditions and exceptions, you may also have rights of access, rectification, erasure, restriction, data portability, objection to processing based on legitimate interests, withdrawal of consent for the future, and protection concerning decisions based solely on automated processing. You may contact us or our EU Representative to exercise these rights.

You may withdraw marketing consent or object to direct marketing at any time. After a valid withdrawal or objection, we will no longer process your personal data for that marketing purpose, while retaining information necessary to document and respect your choice where permitted or required by law.

19. Complaints

Under KVKK, you may first apply to the data controller and, where the statutory conditions are met, submit a complaint to the Turkish Personal Data Protection Board. Where the GDPR applies, you may lodge a complaint with the competent supervisory authority in the European Union, particularly in the Member State of your habitual residence, place of work or the alleged infringement.

Turkish authority: Personal Data Protection Authority
German supervisory authority for the EU Representative’s establishment: The Hessian Commissioner for Data Protection and Freedom of Information

20. Data Security

We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure and unauthorised access. Measures are reviewed and adjusted where appropriate, taking account of the nature of the processing, available technology and relevant risks.

21. Changes to this Privacy Policy

We may update this Privacy Policy when our website, services, providers or legal requirements change. The current version and update date will be published on this page. We recommend reviewing the Policy periodically.