Section A: Privacy Policy
General Information
This notice has been prepared to inform you about the personal data processed through the ecomwhole.com website, in accordance with Article 10 of Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) and Article 13 of the EU General Data Protection Regulation (“GDPR”).
The data controller is Sontem Grup Danışmanlık İç ve Dış Ticaret Limited Şirketi (“we”, “the Company”), operating under the EcomWhole brand. The Company is a limited liability company established in Türkiye; EcomWhole is the registered trade name it uses for its global e-commerce activities. Our contact details are set out in the “Contact” section at the end of this page.
This notice is for information purposes; visiting the website does not mean that you consent to any data processing. The only processing based on your explicit consent is the transfer abroad that you approve separately on the application form.
Data We Collect
When you complete the application form, we collect the following data that you provide to us directly and electronically:
- First and last name
- Corporate email address
- Brand name and product category
- Target market information
- The description you provide about your brand
- Your consent to the transfer abroad, the date and time the form was submitted, and the IP address and browser information recorded at submission
When you visit the website, our hosting provider's servers automatically keep technical logs, such as IP address, date and time of the visit, the page requested and browser information, to operate and secure the website. We do not use these logs to identify you or to build profiles.
Purposes and Legal Bases
We process your personal data only for the following purposes and on the legal bases indicated:
- Evaluating your application and responding to you: processing is directly related to the conclusion of a contract (KVKK Art. 5(2)(c); GDPR Art. 6(1)(b))
- Communicating with you about the services you have requested: conclusion of a contract and our legitimate interest (KVKK Art. 5(2)(c) and (f); GDPR Art. 6(1)(b) and (f))
- Secure and uninterrupted operation of the website (server logs): our legitimate interest (KVKK Art. 5(2)(f); GDPR Art. 6(1)(f))
- Fulfilling our legal obligations and responding to legal claims: legal obligation and the establishment, exercise or defence of rights (KVKK Art. 5(2)(ç) and (e); GDPR Art. 6(1)(c) and (f))
We do not sell or rent your data, and we do not share it with third parties for marketing purposes. We will not use the contact details you submit via the form to send you commercial electronic messages for marketing purposes without your separate consent.
Data Sharing and Transfers Abroad
Your personal data may be shared with the following recipients, only to the extent necessary for the purposes above:
- Netlify, Inc. (United States), which hosts our website and forwards form submissions to us, and the sub-processors it uses to provide this service (e.g. filtering services that screen out unwanted submissions)
- The email service providers we use to reply to your application
- Public authorities and courts legally entitled to receive data, only where there is a legal obligation or request
Transfer abroad: As our hosting and form infrastructure provider is based in the United States, the data you submit via the form and the server logs are transferred to servers abroad, in particular in the United States. The transfer of form data is based on the explicit consent you give separately on the form (KVKK Art. 9; GDPR Art. 49(1)(a)). There is no adequacy decision for the United States under the KVKK; this means that your data may not enjoy the same level of protection as in Türkiye or the European Union. You may withdraw your consent at any time; if you prefer not to consent, you can send your application directly to info@ecomwhole.com.
All parties with access to such data are bound by confidentiality obligations.
Cookies and Analytics
This website does not use cookies, does not contain any analytics, advertising or visitor-tracking tools, and does not store information in your browser. All website files, including fonts, are loaded from our own domain; during your visit your browser does not connect to any service other than the server hosting the website.
If this changes, this section will be updated in advance and your consent will be obtained where required by law.
Retention Period
We retain the data you submit via the application form for as long as necessary to evaluate your application and inform you of the outcome. If your application does not lead to a collaboration, the data is deleted or anonymised at the end of that period; if a collaboration is established, it is retained for the duration of the contractual relationship and our statutory retention obligations.
Server logs are kept in our hosting provider's systems for the provider's security-related retention period; we do not store these logs separately.
Data Subject Rights
Under Article 11 of the KVKK, you have the right:
- to learn whether your personal data is processed and, if so, to request information about it
- to learn the purpose of the processing and whether the data is used in line with that purpose
- to know the third parties in Türkiye or abroad to whom your data is transferred
- to request the correction of incomplete or inaccurate data
- to request the erasure or destruction of your data under the conditions set out in Article 7 of the KVKK
- to request that any correction, erasure or destruction be notified to the third parties to whom the data has been transferred
- to object to any outcome to your detriment arising from analysis of your data exclusively by automated systems
- to claim compensation for damage suffered as a result of unlawful processing
If you are visiting from the European Union, you also have the rights of access, rectification, erasure, restriction of processing, data portability and objection under the GDPR. Your right to lodge a complaint with the data protection supervisory authority in your country of residence or where the alleged infringement took place remains unaffected.
You may withdraw the explicit consent you have given for the transfer abroad at any time. Withdrawal does not affect the lawfulness of processing carried out before it.
To exercise your rights, you may send a written request to our company address below, or email info@ecomwhole.com from the email address you previously provided to us and which is registered in our records. Your request will be concluded free of charge as soon as possible, and within thirty days at the latest, depending on its nature. If your request is rejected, if you find our response insufficient, or if we do not respond in time, you may lodge a complaint with the Turkish Personal Data Protection Board.
Section B: Terms of Use
Terms of Use
By accessing and using this website, you are deemed to have accepted the following terms. If you do not accept these terms, please do not use the site.
EcomWhole operates on a selective partnership model. Applications submitted through the website are subject to an evaluation process, and submitting an application does not constitute any service agreement or commitment to collaborate. We do not extend proposals to all brands.
Intellectual Property
All content on this website — texts, images, logos, design and layout — is owned by Sontem Grup Danışmanlık İç ve Dış Ticaret Limited Şirketi (under the EcomWhole brand) or the relevant rights holders, and is protected by copyright and other intellectual property rights.
The content on the site may not be copied, reproduced or used for commercial purposes without prior written consent.
The names and logos of marketplaces, logistics companies, brands we work with and institutions shown on the website are trademarks or trade names of their respective owners and remain their property.
Limitation of Liability
The information on the website is provided for general informational purposes only. While reasonable efforts are made to keep the content current and accurate, no warranty is given as to the completeness of the information or its fitness for any particular purpose.
Figures such as orders, products and customer satisfaction shown on the website are based on our own records and reflect past performance; they do not constitute a commitment or guarantee of future results. Content marked as “sample data” is illustrative.
To the extent permitted by applicable law, Sontem Grup Danışmanlık İç ve Dış Ticaret Limited Şirketi shall not be held liable for any indirect damages arising from the use of the site.
Governing Law
This policy and the terms of use are governed by the laws of the Republic of Türkiye. Any disputes that may arise shall be subject to the jurisdiction of the Istanbul Courts and Execution Offices. This does not limit any rights you have under mandatory provisions of applicable law or data protection legislation, including your right to lodge a complaint with a competent supervisory authority.
Sontem Grup Danışmanlık İç ve Dış Ticaret Limited Şirketi reserves the right to update the terms on this page from time to time. The current version is always published on this page; for material changes, the date at the top of this page is updated.
Contact
For questions about this notice or data-related requests, you can reach us through the following channels:
- Company: Sontem Grup Danışmanlık İç ve Dış Ticaret Limited Şirketi
- Address: Sultan Selim Mahallesi, Büyükdere Caddesi, Büyükdere İş Merkezi No:4 K:3 D:5‑4, 34415 Kağıthane/İstanbul
- Email: info@ecomwhole.com