Privacy Policy

Last updated: April 4, 2026

At Initial Code Software Solution Yazılım Hizmetleri ve Ticaret A.Ş. (“Initial Code,” “we,” “us,” or “our”), we respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and protect personal data when you visit www.initialcode.io (the “Site”), contact us, or otherwise interact with us.

This Privacy Policy should be read together with our Cookie Policy and any other notices we provide at the time we collect your data.

1. Who We Are

If you have any questions about this Privacy Policy or our data practices, you can contact us using the details above.

2. What Personal Data We Collect

Depending on how you interact with the Site, we may collect the following categories of personal data:

Information you provide directly

• Full name
• Email address
• Phone number
• Subject line
• Message content
• Any other information you choose to share with us

Information collected automatically

• IP address
• Browser type and version
• Device type and operating system
• Referring pages
• Pages visited and time spent on the Site
• Date and time of access
• Basic log and diagnostic data
• Cookie and similar technology data

3. How We Collect Your Data

We collect personal data:

• when you fill out and submit the contact form on our Site;
• when you contact us by email or other communication channels;
• automatically through server logs, cookies, and similar technologies;
• from third-party service providers that support our website, hosting, analytics, security, or communications.

4. Why We Use Your Personal Data

We may process your personal data for the following purposes:

• to respond to your inquiries and contact requests;
• to communicate with you about our services, projects, or business opportunities;
• to operate, maintain, secure, and improve our Site;
• to monitor Site performance, diagnose technical issues, and prevent misuse;
• to comply with legal, regulatory, tax, accounting, or reporting obligations;
• to establish, exercise, or defend legal claims;
• where permitted, to send business communications relevant to our services.

5. Legal Bases for Processing

Depending on the applicable law, we rely on one or more of the following legal bases:

• your consent, where required;
• performance of pre-contractual steps or a contract, for example when you ask us about services;
• our legitimate interests, such as managing inquiries, improving the Site, and maintaining security;
• compliance with legal obligations;
• protection of rights, including the establishment or defense of legal claims.

Where consent is required for non-essential cookies or similar technologies, we will request it before placing them on your device.

6. Cookies and Similar Technologies

Our Site may use cookies and similar technologies to:

• ensure the Site functions properly;
• remember user preferences;
• analyze traffic and performance;
• enhance security;
• measure the effectiveness of our website and communications.

Some cookies are strictly necessary for the operation of the Site. Others, such as analytics or marketing cookies, may require your consent depending on applicable law.

You can manage cookies through:

• our cookie banner or consent tool, where available;
• your browser settings;
• any controls described in our Cookie Policy.

For more detailed information, please see our Cookie Policy at: /cookie-policy

7. Sharing of Personal Data

We do not sell your personal data.

We may share personal data with:

• website hosting providers;
• cloud infrastructure providers;
• analytics providers;
• email and communication providers;
• IT, maintenance, and security service providers;
• legal, accounting, and professional advisors;
• public authorities, regulators, or law enforcement where required by law;
• potential investors, acquirers, or counterparties in a merger, acquisition, restructuring, or asset transfer, subject to confidentiality obligations.

We require service providers acting on our behalf to process personal data only under appropriate confidentiality and security obligations.

8. International Data Transfers

Your personal data may be stored or processed in countries other than your own, including countries where our service providers operate.

Where required by applicable law, we will take appropriate safeguards for international transfers, such as:

• contractual safeguards;
• transfer mechanisms recognized by applicable law;
• technical and organizational security measures.

9. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, including to:

• respond to your request;
• maintain business and legal records;
• comply with legal obligations;
• resolve disputes;
• enforce agreements.

As a general approach:

• contact form submissions may be retained for up to 24 months unless a longer period is required;
• technical logs may be retained for up to 180 days unless needed for security or legal reasons;
• records related to contracts, invoices, or legal obligations may be retained for the period required by applicable law.

Once no longer needed, personal data is deleted, anonymized, or securely destroyed.

10. Your Rights

Depending on the law that applies to you, you may have the right to:

• learn whether your personal data is being processed;
• request information about the processing;
• request access to your personal data;
• request correction of inaccurate or incomplete data;
• request deletion or destruction of your data;
• request restriction of processing;
• object to certain processing activities;
• withdraw consent at any time, where processing is based on consent;
• request portability of your data, where applicable;
• object to decisions based solely on automated processing, where applicable;
• request compensation where you suffer damage due to unlawful processing, where permitted by law.

To exercise your rights, please contact us at info@initialcode.io.

We may need to verify your identity before responding to your request.

11. Third-Party Links

Our Site may contain links to third-party websites or platforms, including social media services. We are not responsible for the privacy practices of third-party sites. We encourage you to review their privacy notices before providing personal data.

12. Data Security

We implement reasonable technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, or misuse. However, no method of transmission over the internet or method of storage is completely secure, and we cannot guarantee absolute security.

13. Children’s Privacy

Our Site is not directed to children, and we do not knowingly collect personal data from children unless permitted by law and supported by an appropriate legal basis. If you believe a child has provided personal data to us, please contact us so we can take appropriate action.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or business operations. When we do, we will revise the “Last updated” date at the top of this page. Material changes may also be communicated through the Site where appropriate.

15. Contact Us