— PRIVACY POLICY

Privacy Policy

Effective date: July 10, 2026

This Privacy Policy explains how Dubicon (“Dubicon,” “we,” “us”) collects, uses, and protects information when you visit dubicon.net (the “Site”) or engage our services. Dubicon is operated by [Yagiz Duhan Suluoglu / Dubicon], based in Istanbul, Türkiye. If you have any questions, contact us at yagiz@dubicon.net.

1. Information We Collect

Information you provide directly. When you email us, request an audit, create an account on the Site, or become a client, we may collect your name, business name, email address, phone number, billing details, and the contents of your communications with us.

Information provided during an engagement. To perform an audit or ongoing work, clients may grant us access to business accounts and materials such as websites, analytics, advertising accounts, social media profiles, booking systems, and customer relationship tools. We access this information only to perform the agreed services.

Information collected automatically. Like most websites, the Site may collect technical data such as IP address, browser type, device information, pages visited, and referring URLs through cookies and similar technologies. 

2. How We Use Information

We use the information we collect to:

  • Respond to inquiries and communicate with you;
  • Deliver the services you purchase, including audits, strategy work, retainers, and consulting;
  • Issue invoices, process payments, and maintain business records;
  • Operate, secure, and improve the Site;
  • Send service-related updates about your engagement;
  • Comply with legal obligations.

We do not sell your personal information, and we do not use client data for advertising to third parties.

3. Legal Bases for Processing

Where applicable data protection law (including the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and, where relevant, the EU General Data Protection Regulation (“GDPR”)) requires a legal basis, we process personal data on the basis of: performance of a contract with you; our legitimate interests in operating and promoting our business; your consent, where required; and compliance with legal obligations.

4. Client Customer Data

In the course of an engagement, we may incidentally view personal data belonging to a client’s own customers (for example, within a client’s analytics, CRM, or booking system). We treat such data as confidential, access it only as necessary to perform the services, do not extract or retain it beyond what the engagement requires, and process it in accordance with the client’s instructions and applicable law.

5. How We Share Information

We may share information with:

  • Service providers and subcontractors who assist in delivering our services (for example, specialist contractors, hosting providers, and email providers), under confidentiality obligations and only to the extent needed to perform the work;
  • Payment providers, to process transactions;
  • Legal and regulatory authorities, where required by law or to protect our legal rights;
  • A successor entity, in the event of a merger, acquisition, or sale of business assets.

6. International Data Transfers

Dubicon is based in Türkiye and primarily serves clients in the United States. Information you provide will be processed in Türkiye and may be processed in other countries where our service providers operate. Data protection laws in these countries may differ from those in your country. Where required, we take steps to ensure appropriate safeguards for such transfers.

7. Data Retention

We retain personal information for as long as needed to provide the services, comply with legal and tax obligations, resolve disputes, and enforce agreements. Access credentials shared for an engagement are deleted or revoked when the engagement ends, and we recommend that clients revoke access on their side as well.

8. Your Rights

Depending on where you live, you may have rights under applicable law — including the KVKK, the GDPR, or US state privacy laws such as the California Consumer Privacy Act (CCPA) — to request access to, correction of, or deletion of your personal information; to object to or restrict certain processing; to data portability; and to withdraw consent where processing is based on consent. To exercise any of these rights, email yagiz@dubicon.net. We will respond within the timeframe required by applicable law. You also have the right to lodge a complaint with a supervisory authority, including the Turkish Personal Data Protection Authority (KVKK Kurumu).

9. Cookies

The Site uses cookies and similar technologies necessary for its operation, and may use additional cookies for functionality and analytics. You can control or delete cookies through your browser settings; disabling cookies may affect how the Site functions.

10. Marketing Communications

If we contact you by email for business purposes, every such email includes a simple way to opt out. If you ask us not to contact you again, we honor that request and add you to our suppression list.

11. Security

We use reasonable technical and organizational measures to protect the information we hold. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

12. Children’s Privacy

Our Site and services are intended for businesses and are not directed to anyone under 18. We do not knowingly collect personal information from minors.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The current version will always be posted on this page with its effective date. Material changes will be communicated to active clients by email.

14. Contact

Dubicon
Yagiz Duhan Suluoglu 
Cumhuriyet Mh, Istanbul, Türkiye
Email: yagiz@dubicon.net

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