Privacy Notice on Processing of Personal Data
Information provided pursuant to our duty to inform under our role as a data controller for the personal data we process about you.
Data Controller
Your personal data is processed by 3C1B Telekomünikasyon ve İnternet Hizmetleri Sanayi ve Ticaret A.Ş. ("3C1B" or the "Company") in its capacity as data controller, for the purposes and legal bases set out below. Operating as an Internet Service Provider (ISP), Fixed Telephony Service (FTS) and Infrastructure Operator (IO) licensed by BTK, our Company is ISO/IEC 27001:2022 ISMS certified.
Scope
This privacy notice is addressed to natural persons who visit our website, use our services, contact our call centre, become subscribers, submit applications, or otherwise communicate with us. It also covers representatives, contact persons of our corporate customers and natural persons named in billing addresses.
Categories, Purposes, Retention Periods and Legal Bases
The following table summarises the categories of personal data processed, the processing purposes, retention periods and underlying legal bases pursuant to KVKK art. 10/1-c and 10/1-ç:
| Data Category | Processing Purpose | Retention Period | Legal Basis |
|---|---|---|---|
| Identity data (first name, last name, national ID no) | Subscriber identification, mandatory KYC under BTK regulation | Subscription period + 10 years | BTK Notification and Service Continuity Regulation · KVKK art. 5/2-ç (legal obligation) |
| Contact data (phone, email, address) | Service delivery, billing communication, customer support, notifications | Subscription period | KVKK art. 5/2-c (performance of a contract) |
| Customer transaction data (requests, complaints, contracts) | Customer service, record archive, dispute resolution | 10 years (Turkish Commercial Code art. 82) | Commercial Code · KVKK art. 5/2-ç (legal obligation) |
| Traffic data (CDR, NetFlow, session logs) | Retention under Law no. 5651, BTK SAD reporting, lawful authority requests | 1-2 years (Law no. 5651) | Law no. 5651 art. 5 · KVKK art. 5/2-ç |
| Invoice and payment data | Accounting, tax legislation, collection follow-up | 10 years (Tax Procedure Code + Commercial Code) | Tax Procedure Code + Commercial Code · KVKK art. 5/2-ç |
| Location data (installation address, fibre route) | Service technical checks, fault intervention, installation | Service term | KVKK art. 5/2-c (performance of contract) |
| Marketing preferences (consent status) | Advertising, campaign notifications, customer engagement | Until explicit consent is withdrawn | KVKK art. 5/1 (explicit consent) · Law no. 6563 art. 6 (commercial electronic messages) |
Methods of Collection
Your personal data is collected from electronic and physical channels including forms on our website, the customer portal, email, the call centre, corporate sales contracts, BTK shared sub-systems (BBK address lookup, KPS identity verification), authorised dealers and physical applications.
Transfer of Personal Data
Pursuant to KVKK art. 8 your personal data may be transferred to the following third parties:
- BTK (Information and Communication Technologies Authority) — subscriber movement reports, SAD reports, traffic data (legal obligation)
- Lawful authorities (prosecution, courts, law enforcement) — pursuant to lawful requests and orders
- Wholesale infrastructure, transit and access service providers — technical information necessary for service delivery (performance of a contract)
- Service providers — independent audit firms, accountancy/financial advisory and billing-collection suppliers (under KVKK art. 8/2-a, subject to confidentiality and data processing terms)
Data Subject Rights (KVKK Art. 11)
Pursuant to article 11 of Law no. 6698, you have the following rights regarding your personal data:
- To learn whether your personal data is being processed
- To request information if processed
- To learn the processing purpose and whether the data is used in accordance with that purpose
- To know the third parties to whom data has been transferred domestically or abroad
- To request correction if processed incompletely or inaccurately
- To request deletion or destruction subject to KVKK art. 7
- To request that any correction or deletion be notified to third parties to whom the data has been transferred
- To object to outcomes arising from automated decision-making analysis
- To request compensation for damage caused by unlawful processing
To exercise these rights you can use one of our written or electronic application channels. Fill the KVKK Application Form →
Cookies
Our website uses necessary, statistics and marketing cookies. Cookies outside the necessary category are only loaded with your explicit consent. Cookie Policy details →
Updates to this Notice
This privacy notice may be revised in line with regulatory developments and changes to the scope of our services. Material changes are announced via our website and, where necessary, fresh consent is requested.