Digital Collar IT Systems

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PRIVACY POLICY AND CLARIFICATION TEXT

Last Updated: November 25, 2025

Digital Collar IT Systems LTD (“Company”, “We”, “Us”) places the highest importance on your privacy and the security of your data.

This Privacy Policy explains how your personal data is collected, used, and protected when you visit the digitalcollar.io website, contact us, or use our services.

Legal Basis and Compliance: This policy has been prepared in accordance with the UK General Data Protection Regulation (UK GDPR) and EU GDPR standards. Additionally, for citizens of the Republic of Turkey, this text constitutes a “Clarification Text” (Aydınlatma Metni) within the scope of Article 10 of the Law on the Protection of Personal Data No. 6698 (KVKK).

1. Data Controller

The legal entity responsible for the processing of your personal data:

  • Company Name: Digital Collar IT Systems LTD
  • Address: 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
  • Authorized Director: Derya Yeğin Çimen
  • Contact Email: support@digitalcollar.io
  • ICO Registration Number: ZC047343

2. Data We Collect

We request only the minimum level of data necessary for service provision, legal obligations, and site security.

Automated Decision Making: We do not use automated decision-making or profiling mechanisms defined under UK GDPR Article 22 that would produce legal or similarly significant effects on you.

A. Information You Provide Directly:

  • Identity and Contact: Name, Surname, Email address.
  • Corporate Information: Company title and invoice details (In case of service purchase).
  • Communication Content: Content of messages transmitted via forms on our website or the Fluent Support system.

B. Automatically Collected Technical Data: For site security and analysis (Google Site Kit, Wordfence, etc.), IP address, browser type, and on-site navigation movements may be processed automatically.

Sensitive Data: Our Company does not collect or process “Special Category Data” such as health, biometric data, race, religion, or political opinions.

3. Data Processing Purposes and Legal Bases

We process your data within the framework of the following purposes and legal bases:

  1. Service Provision: To prepare proposals and execute the contract.
    • Legal Bases: Contractual Necessity / KVKK Art. 5/2-c.
  2. Legal Obligations: To issue invoices and keep tax records.
    • Legal Bases: Legal Obligation / KVKK Art. 5/2-ç.
  3. Site Security: To prevent cyber attacks and perform backups.
    • Legal Bases: Legitimate Interest / KVKK Art. 5/2-f.
  4. Communication and Marketing: To send newsletters if you provide consent.
    • Legal Bases: Consent / KVKK Art. 5/1.


Data Breach Notification: In the event of a breach (cyber attack, etc.) posing a high risk to your data, notification will be made to the relevant authority (ICO) and to you within 72 hours.

4. Data Sharing and International Transfer

We do not sell your data. However, due to the technical infrastructure of the service, your data may be shared with the following providers:

  • Hosting: Hostinger (Servers: UK).
  • Backup and Transfer (Important): Site backups are stored on Google Drive. Your data may technically be transferred outside the United Kingdom (to the USA).
  • Transfer Assurance: This transfer is made to organizations accepted as safe under the ‘UK Extension to the EU-US Data Privacy Framework’ (Data Bridge) recognized by the UK Government.

5. Data Retention Periods

  • Potential Customer Data: Stored for 5 years or until you request deletion.

  • Financial/Customer Data: Must be stored for the legal obligation period required by UK and Turkish tax laws (usually 6-10 years) and cannot be deleted before this period expires.

6. Cookies

Cookies are used on our site to improve your experience. You can manage your cookie preferences via the “Cookie Policy” panel (Complianz) on our website.

7. Your Rights

Under GDPR and KVKK (Article 11), you have the rights to access, correct, delete (right to be forgotten), object to processing, and port your data.

  • Right to Lodge a Complaint with the Supervisory Authority: If you are not satisfied with our data processing activities, you have the right to lodge a complaint with the UK data protection authority, the Information Commissioner’s Office (ICO). (ICO Contact: https://ico.org.uk/make-a-complaint/)

8. Children’s Privacy

Our services are directed only towards adults and commercial businesses. We do not knowingly collect data from individuals under the age of 18.

9. Contact

You can contact us for your requests:

  • Email: support@digitalcollar.io
  • Address: Digital Collar IT Systems LTD, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, UK.