1. Scope and identity of the organisation
This Privacy Policy explains how NEWLY İLETİŞİM VE BİLGİ TEKNOLOJİLERİ ANONİM ŞİRKETİ ("NEWLY", "we", "us" or "our") handles personal data when you use NEWLY SOFT websites, applications, cloud services, support channels, business services and other digital products that link to this notice.
Some products may provide a service-specific privacy notice. If a service-specific notice conflicts with this general notice, the service-specific notice controls for that service to the extent permitted by law.
2. Personal data we may collect
Depending on the product, you may also choose to provide location, media, files, device or application data. We only request these data where they are relevant to the feature or service you use.
Sources
We may obtain personal data directly from you, automatically from your device when you use our services, from your organisation where you use a business account, from service providers acting on our behalf, or from lawful public/business sources.
3. Why we use personal data
We process personal data for purposes such as providing and securing services, creating and administering accounts, responding to support requests, fulfilling contracts, improving reliability and usability, preventing fraud or abuse, complying with legal obligations, managing business relationships and — where permitted — sending relevant communications.
| Purpose | Typical legal basis where applicable |
|---|---|
| Provide requested products, services and support | Contract performance; steps requested before entering a contract |
| Security, fraud prevention, diagnostics and service integrity | Legitimate interests; legal obligations; protection of rights |
| Accounting, tax, compliance and lawful requests | Legal obligation |
| Product improvement and non-essential analytics | Legitimate interests where permitted; consent where required |
| Marketing, advertising or optional tracking | Consent or another lawful basis permitted by applicable law |
Where we rely on legitimate interests, we consider the impact on individuals and apply safeguards appropriate to the processing. Where consent is the legal basis, you may withdraw it at any time without affecting processing already lawfully carried out.
5. International transfers
Our services may involve processing in more than one country. Where a cross-border transfer occurs and a legal transfer mechanism is required, NEWLY will select and document an appropriate mechanism for the circumstances. Depending on the law that applies, this may include an adequacy decision, contractual safeguards such as the EU Standard Contractual Clauses, applicable UK transfer mechanisms, the standard-contract mechanisms available under Article 9 of Türkiye's KVKK, or another lawful transfer basis.
6. Retention
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected, including service delivery, account administration, security, dispute handling, legal claims and statutory accounting or record-keeping obligations. Retention periods vary by data type and service.
When data is no longer required, we delete, destroy or anonymise it in accordance with applicable requirements and operational backup cycles.
7. Your privacy rights
Depending on applicable law, you may have rights to be informed; access personal data; correct inaccurate data; request deletion; restrict or object to processing; receive portable data; withdraw consent; and obtain safeguards information for certain international transfers. Under the GDPR/UK GDPR, additional protections may apply to certain solely automated decisions. Under Türkiye's KVKK, rights are available under Article 11. California residents may have rights such as know, delete, correct, opt out of sale/sharing, limit certain uses of sensitive personal information and equal treatment where the CCPA applies.
To submit a request, email cs@newlysoft.com.tr. We may need to verify your identity and the request may be subject to lawful exceptions. Response periods depend on the law that applies to your request.
If you are making a formal statutory application specifically under Türkiye's KVKK, the application may need to follow the language, identity and submission-method requirements prescribed by Turkish law. You may contact us first for routing information; the statutory procedure remains controlling.
8. Security and privacy by design
We use technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. Measures are selected according to risk and may include access controls, authentication, encryption in transit, logging, backup controls, vulnerability management, vendor controls and confidentiality obligations.
No internet or storage system is completely secure. We therefore continuously review safeguards and incident-response processes rather than representing that risk can be eliminated entirely.
9. Children
Our general corporate services are not directed to children. If a specific product is designed for minors, we will provide age-appropriate information and obtain parental or guardian authorisation where required by applicable law. If you believe a child has provided personal data to a service not intended for children, contact us.
10. Contact, complaints and updates
NEWLY İLETİŞİM VE BİLGİ TEKNOLOJİLERİ ANONİM ŞİRKETİ
Nilüfer Caddesi No: 38E 1–5, 16285 Görükle, Nilüfer, Bursa, Türkiye
Phone: +90 850 302 49 04
Email: cs@newlysoft.com.tr
You may also have the right to complain to a competent supervisory authority, such as Türkiye's Personal Data Protection Authority (KVKK), an EU/EEA data-protection authority, the UK Information Commissioner's Office, or another regulator with jurisdiction over the processing.
We may update this notice to reflect changes in services, technology or law. The date at the top of this page shows the most recent revision.