Privacy notice (KVKK)

This notice applies to dogancoban.com, operated by Doğan Çoban. Providing information is not a request for consent. Jump to: Contact and request forms · Test records · Chat · Analytics.

1. Data controller

Doğan Çoban
Manavkuyu Mah. 275 Sk. No: 4 D: 22, Bayraklı / İzmir, Türkiye
Email: kvkk@dogancoban.com

2. What data I process

• Contact and request data: Identity, business contact details and request content you provide through forms, email, phone or WhatsApp. Form fields, recipients and processing grounds are explained under Contact and request forms.
• Meeting and proposal data: Notes I take during the introductory conversation; the summary and proposal I send you.
• Free test data: When you request a report: company, industry, role, headcount, full name, work email, optional phone, answers, result and contact request. Details are in section 9.
• Contract and invoicing data: If you buy a service, the information needed for the order, the invoice and the service (trade name, tax office and tax number, address, authorized contact person).
• Training and project data: If you buy a service:
  • Participant list: Full name and job title (for the participation certificate)
  • Answers to the forms before a training: Role, AI use, views and questions; name optional
  • Evaluation forms after a training
  • AI Opportunity Map interview and observation notes: Roles are recorded instead of names
• Site usage data:
  • Technical logs the hosting service keeps for the site's operation and security: IP address, browser information, time of request.
  • Cookieless, aggregated visit statistics: which pages were viewed, where visitors came from, device type, country.
  • Anonymous counting: pages opened, test and contact form steps, clicks on contact links, the name of the referring site and device type. No name, email, IP address or device identifier is recorded.

I don't ask for special categories of personal data (such as health, religious or biometric data); please don't share them.

3. Purposes

• To respond to your request, and to schedule and hold the introductory conversation
• To prepare and send the summary and proposal
• To record the answers and result for the report you request; if you requested contact, to email you once about the result
• To set up and perform the service contract: training, consulting, applications and follow-up
• To assess participation and learning in standard training; to plan custom training through paid preparation interviews and issue participation certificates
• To meet invoicing, tax and accounting obligations
• To keep the site running securely and properly, and to understand how the site is used through aggregated statistics
• To exercise and protect rights in the event of a dispute

I don't send you promotional emails without your permission.

4. Legal grounds

I process your personal data on the following grounds under Article 5(2) of KVKK:

• Establishing or performing a contract (subparagraph c): To the extent directly related and necessary for personal data of a natural person who is a party to the contract; Responding to your request, preparing the summary and proposal, and concluding and performing the contract.
• Legal obligation (subparagraph ç): Invoicing, tax and accounting records.
• Establishing, exercising or protecting a right (subparagraph e): In the event of a dispute.
• Legitimate interest (subparagraph f): Site security and technical logs, aggregated visit statistics, keeping business correspondence in order, and participant forms before and after a training. I do this in a way that does not harm your fundamental rights and freedoms.

I quote your comments from an evaluation form only with your explicit consent (KVKK Article 5(1)). You can withdraw this consent at any time.

Contact and request forms

Data controller: Doğan Çoban. I collect your name, company, email/phone, selected topic, message, preferred date/time if provided and the page from which you opened the form electronically through the contact page or chat request form. Google Apps Script saves the request to Google Sheets; Zoho Mail sends me an email notification. Information entered in these forms is not sent to the AI.

If you submit the chat request form, up to the last 6 chat messages are included, each limited to 300 characters. I use this information to understand and respond to your request and arrange the conversation you requested. Submitting a form does not give marketing permission.

Legal grounds: Article 5(2)(c) of KVKK for data directly related and necessary to a contract with a natural person; Article 5(2)(f) for other requests and business contacts of company representatives, based on the legitimate interest in responding to requests and managing business correspondence without harming fundamental rights and freedoms. Doğan Çoban accesses the data to respond. Recipients and transfer status are in sections 6–7, retention in section 8, and rights and request channels in sections 11–12.

Optional analytics

Google Analytics 4 runs only with your separate analytics consent (KVKK Article 5(1)) to help understand site use. It measures the page address (without query or fragment), visit duration, device/browser information and contact-link type. I do not send names, email addresses, form answers or chat content. Google processes measurement data abroad; the transfer review below also applies to this service. Cookie consent does not resolve that separate review. Withdraw consent using “Analytics preferences” in the footer. Cookie and duration details.

5. How data is collected

I collect your data in these ways:

• Through the emails and WhatsApp messages you send and the phone calls we have
• During the introductory conversation and the work
• Through forms before and after a training (online or on paper)
• Through the report form of the free tests, the contact form and the request form in the chat window on the site
• Automatically, through the site's hosting and analytics tools

6. Transfers

I don't sell your data or share it with anyone for marketing. To the extent the service requires, it may be transferred to these recipients:

If you choose to message me on WhatsApp, your message passes through WhatsApp (Meta) infrastructure. That service's own privacy terms apply.

7. Transfers abroad

Google, Zoho and Cloudflare process data outside Türkiye; access from abroad also counts as a transfer. Regular transfers require an adequacy decision or an appropriate safeguard under Article 9 of KVKK. An EU data center alone is insufficient.

Transfer safeguards for these accounts have not yet been verified. Reading this notice, starting chat or accepting cookies does not resolve this gap; incidental transfer exceptions are not used as a general basis for regular services.

8. Retention

• General rule: I keep your data for as long as the purpose it was processed for requires, and for the periods set by the relevant legislation.
• Correspondence that doesn't lead to a contract: Deleted no later than 2 years after the last message.
• Participant forms: For current services, purposes and retention of preparation, learning measurement and evaluation records are explained in the service-specific notice before collection. The old 60/90-day periods do not automatically apply to new forms. A comment you allowed me to quote is used until you withdraw that permission.
• Participant list: Kept for no more than 2 years as a record of participation; statutory retention of invoice records is assessed separately.
• Consulting working notes: Purposes, access and retention are specified for the selected engagement before collection; invoice retention does not apply to all working notes.
• Invoicing and accounting records: Kept for the periods set by tax legislation.
• When the period ends: Data is erased, destroyed or anonymized when processing conditions cease. The business periods above do not permit retention after necessity ends; destruction operations are recorded.

9. Free tests

The workload calculator is an exception: It asks for no company/contact details and submits no task names or answers. Person-hours are calculated in your browser; general anonymous page analytics are separate.

In the free tests on the site, your answers and your result are calculated in your browser; you don't have to give any information to see the short result. When you submit the optional report recording form, I collect your company name, industry, name, work email and, if you wish, your phone number. These are recorded together with your answers and result.

• Purpose: To keep the answers and result for the report you requested. The report is calculated automatically; it is not a company-specific consulting analysis. You can print it or save it as a PDF from your browser. If you ticked the contact box, to write to you once by email to discuss your result.
• Legal grounds: Legitimate interest for keeping the requested report record and the one-off contact you request without harming your fundamental rights and freedoms (KVKK Art. 5(2)(f)). Announcements and promotional emails are sent only with separate explicit consent and registration in İYS (the national commercial message system).
• Not recorded: IP address, cookies, location and browser information are not kept in the test record.
• Transfers: Google Apps Script saves records in Google Sheets; Zoho Mail sends me a notification. Google and Zoho process data outside Türkiye. Transfer requirements and verification status are explained in section 7.
• Retention: If no business relationship follows, the record is deleted 12 months after the last contact. This is a maximum business period, not a statutory obligation. Identifiable data is not retained solely for aggregate statistics; when the processing need ends earlier, data is erased or truly anonymized.
• Your rights: You can use the rights below for your test records, too.

10. Chat assistant (only if you use it)

This section applies only if you use the chat assistant on this site. No chat question is sent to Gemini and the chat protection service is not started until you select “Start chat” and submit a question. Site hosting, cookies and visit measurement are separate, as described in the relevant sections. The request form can be used without starting an AI conversation.

• What is sent: Your question and relevant public service information are sent to Google's Gemini service so that an answer can be generated. To prevent abuse, Google's protection service (Firebase App Check and reCAPTCHA Enterprise) processes browser and device signals.
• Google's use: The assistant uses Google's free service. Google may use the content sent and the answers to improve its own services, and its staff may read them. So don't type your name, contact details or confidential company information into the assistant.
• Before the first question: The assistant shows a processing explanation and a link to this section. It is for users aged 18 or over, accessing from Türkiye. Do not enter personal or confidential information. The start button enables the assistant; it is not explicit consent to the notice or permission for transfers abroad.
• Request form: The meeting request, feedback and question form in the chat window is not sent to the AI. It reaches me like the contact form; Your contact details and up to the last 6 chat messages are saved in Google Sheets and reach me through a Zoho Mail notification. See Contact and request forms.
• Retention: I do not store full conversations as a separate record; refreshing the page clears the browser conversation. If you submit the request form, the last chat lines included in it reach me and are stored in the request record. Records kept by Google are subject to Google's terms.
• Legal ground and transfer: Legitimate interest for necessary and proportionate processing to answer your question and secure the service (KVKK Art. 5(2)(f)); this alone does not cover Google’s own uses or transfers abroad. Google may process data outside Türkiye; transfer requirements and verification status are explained in section 7.

11. Your rights

You may exercise all rights under Article 11 of KVKK:

• Learn whether data is processed; request information about processing, its purpose and proper use; learn recipients in Türkiye or abroad.
• Request correction of incomplete or inaccurate data, deletion or destruction under Article 7, and notification of those actions to recipients.
• Object to adverse results based solely on automated analysis.
• Claim compensation for damage caused by unlawful processing.

12. Applications

You can send your requests in writing, together with information that verifies your identity, in two ways:

• By a signed written application to the address above
• From an email address you previously provided to me and that is registered in my system, to kvkk@dogancoban.com; you may also apply using a secure electronic or mobile signature

Your application includes your name, signature if written, Turkish identity number for Turkish citizens or nationality and passport/identity number for foreign nationals, service address, contact email/phone/fax if available, and your request. Identity checks are limited to necessary information; a copy of your ID card is not a standard requirement.

I conclude your application as soon as possible and within 30 days, free of charge, and notify you in writing or electronically. If the process requires an additional cost, the Board’s tariff may apply. If the request is rejected, the response insufficient or no response provided in time, after first applying to the controller you may complain to the Board within 30 days of learning the response and in any event within 60 days of the application.

13. Application customers and data processed on their behalf

I process contract and contact data of a natural person purchasing an application service where necessary to establish or perform the contract (Art. 5(2)(c)). Business contact data of a company representative is processed for managing the business relationship on legitimate interest grounds without harming their fundamental rights and freedoms (Art. 5(2)(f)). Invoices and mandatory records are processed for legal obligations (Art. 5(2)(ç)); dispute records for establishing, exercising or protecting rights (Art. 5(2)(e)). Data is collected electronically or in writing through contracts, correspondence and support requests. Recipients and transfer conditions are explained in sections 6–7.

For application data concerning a customer company’s chat visitors, employees or customers, the customer determines the purposes and I act as a processor under its written instructions. Chat questions and necessary technical logs; documents, user accounts and access roles in an internal assistant; and source/destination fields in an automation are limited to what the selected service requires. Data types, purposes, access, providers, processing countries, retention and deletion are specified in a data processing agreement. The customer informs its data subjects and establishes the necessary processing and transfer conditions.

I do not use customer data for my own advertising or model training. Necessary processing and transfer conditions and security measures are verified before an application starts processing personal data. For data processed on a customer’s behalf, apply to that customer company; I forward requests received to the authorized controller and assist with its response. For processing where I am the controller, the rights and channels in sections 11–12 apply.

Data is retained only as long as its purpose requires. When processing conditions cease, it must be erased, destroyed or anonymized; only limited records legally required are retained for the applicable period. KVKK does not specify a single fixed retention period for all application data.

14. Changes

I update this notice when necessary; the current version is on this page. I provide information before starting any new processing purpose. Deletion is carried out through documented manual checks, not automatic deletion; provider security and backup logs follow their own terms.