Privacy Policy

U.S. WEBSITE PRIVACY POLICY

Vexara Teknoloji Limited Şirketi

Effective Date: August 17, 2026 | Last Updated: August 14, 2026 |

This Privacy Policy explains how Vexara Teknoloji Limited Şirketi ("Vexara," "we," "us," or "our") collects, uses, discloses, retains, and protects personal information through the U.S.-facing website, forms, accounts, and public-facing features that link to this Policy (collectively, the "Site"). It also explains choices and rights that may apply to you.

Key information. The following details apply to this Policy:

Operator: Vexara Teknoloji Limited Şirketi, a Turkish limited liability company

Primary audience: U.S. business contacts, prospects, customers, and authorized users

Sale for money: Vexara does not sell personal information for money

Advertising status: No sale/sharing or targeted advertising

Privacy requests: privacy@vexara.ltd

1. SCOPE AND PRIVACY ROLES

This Policy applies to personal information Vexara controls for its own website operations, business development, communications, and relationship management. It does not apply to a third-party site or service merely because the Site links to or integrates it; that third party's notice governs its independent processing.

When Vexara processes personal information solely on behalf of a business customer while delivering web development, hosting, website-care, SEO/GEO, analytics, email-marketing, or related paid services ("Customer Data"), the customer ordinarily determines the purposes and means of processing. The applicable Master Services Agreement, Order Form, and Data Processing Addendum govern that processing. Individuals should generally direct Customer Data requests to the relevant customer; Vexara will assist as required by the contract and applicable law.

The Site is intended for business use. Some U.S. privacy laws exempt some business-to-business contact information or apply only after statutory thresholds are met. We provide the rights described below where the relevant law applies to the person, data, and processing.

2. PERSONAL INFORMATION WE COLLECT

Information you provide

business identity and contact information, such as name, employer, title, business email, telephone number, mailing address, and professional profile;
inquiry, proposal, account, project, and relationship information, including requested services, website URLs, communications, meeting details, preferences, approvals, and files you choose to submit;
account and authentication information if an account or portal is offered, such as username, password hash, permissions, and authentication or recovery records;
transaction and billing information, such as billing contact, invoicing details, currency, transaction status, and limited payment details received from a payment provider; and
marketing preferences, event registrations, survey responses, feedback, and records of consent or opt-out choices.

If payment functionality is offered, a payment provider may collect full payment-card or bank information directly under its own privacy terms. Vexara should not receive full card data unless expressly stated at the collection point.

Information collected automatically

When you use the Site, we and providers acting for us may collect IP address; device, browser, and operating-system information; approximate location derived from IP; pages and links viewed; referring and exit pages; dates, times, duration, and interaction events; error and security logs; cookie or similar identifiers; and consent records. We use this information as described below and subject to available cookie choices.

Information from other sources

We may receive business contact and relationship information from your employer or colleagues, a customer or referral source, event or professional-network interactions, public company websites and registries, social or professional platforms, fraud-prevention or security providers, and service providers that help operate our sales and customer systems. We may combine this information with information we already hold, but use it only for lawful business purposes.

Information not requested through general forms

Do not submit Social Security numbers, government identifiers, full payment-card data, financial-account credentials, health information, biometric data, precise geolocation, children's data, or account passwords through a general Site form. Vexara does not intentionally collect such information through the public Site unless a specific feature clearly requests it and provides any required notice.

3. HOW WE USE PERSONAL INFORMATION

We use personal information as reasonably necessary to:

operate, maintain, secure, troubleshoot, measure, and improve the Site and user experience;
respond to inquiries, arrange meetings, prepare proposals, administer accounts, authenticate users, and manage prospective or existing business relationships;
provide requested materials and transactional, security, administrative, and service-related communications;
conduct analytics, understand demand, evaluate campaigns, and improve our services and business processes;
send business marketing where permitted by law, maintain suppression lists, and record communication preferences;
detect, investigate, and prevent fraud, abuse, security incidents, unlawful conduct, and violations of our Website Terms;
establish, exercise, or defend legal claims; enforce agreements; comply with tax, accounting, sanctions, court, regulatory, and other legal obligations; and
evaluate or complete a financing, reorganization, merger, sale, or other business transaction, subject to appropriate confidentiality and legal safeguards.

We do not use Site information to make decisions based solely on automated processing that produce legal or similarly significant effects about an individual. If that changes, we will provide any notice, choice, and rights required by applicable law before using the new process.

4. COOKIES AND ONLINE TRACKING

The Site may use cookies, pixels, tags, local storage, software development kits, and similar technologies. Depending on the Site configuration, these technologies may be used for the following purposes:

Strictly necessary. Security, network management, authentication, forms, load balancing, consent choices, and core Site functions.

Preferences. Remembering selections and interface settings.

Analytics. Understanding visits, navigation, performance, errors, and aggregate engagement.

Advertising. Measuring campaigns or delivering interest-based advertising across services, only if enabled.

You can manage non-essential technologies through (COOKIE SETTINGS LINK) and may also use browser controls. Blocking technologies may affect Site functionality. Third parties whose technologies are enabled may collect information over time and across websites or services under their own notices.

Do Not Track and opt-out signals. Because there is no uniform industry standard for browser "Do Not Track" signals, the Site does not respond to them unless required by law. Where required, we process a recognized universal opt-out preference signal, such as Global Privacy Control, as a request to opt out of sale, sharing, or targeted advertising for the browser or device sending the signal. If we can reasonably associate the signal with an authenticated account, we will apply it to that account as required.

5. HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information to the following categories of recipients for the purposes described in this Policy:

hosting, cloud, website, security, analytics, communications, scheduling, customer-relationship, marketing, payment, and professional-service providers that process information for us under appropriate contractual or legal restrictions;
your employer, organization, account owner, or other authorized users where needed to administer a business relationship or shared account;
professional advisers, auditors, insurers, banks, and financing sources subject to confidentiality or professional obligations;
courts, regulators, law enforcement, tax authorities, or other persons when we reasonably believe disclosure is required by law or necessary to protect rights, safety, systems, or the public;
a prospective or completed acquirer, investor, lender, or transaction counterparty in connection with a corporate transaction, subject to appropriate safeguards; and
another recipient at your direction or with your consent.

This Policy identifies recipients by category. Service-specific subprocessors used for Customer Data are addressed in the applicable customer contract and subprocessor schedule.

6. SALE, SHARING, AND TARGETED ADVERTISING

Vexara does not sell personal information for monetary consideration. If optional advertising or cross-site measurement technologies are enabled, their collection of identifiers and Internet or other electronic-network activity may be treated by some U.S. state laws as a "sale," "sharing," or processing for targeted advertising even though no money changes hands.

Current 12-month status: (OPTION A: Vexara did not sell or share personal information and did not process it for targeted advertising.) (OPTION B: Vexara may have shared identifiers and Internet or other electronic-network activity with advertising or analytics partners through optional technologies for cross-context behavioral or targeted advertising.)

Where an opt-out right applies, use (COOKIE SETTINGS LINK), submit a request through (PRIVACY REQUEST URL), or use a recognized opt-out preference signal. We do not knowingly sell or share the personal information of persons under 16. We do not offer a financial-incentive or price-difference program in exchange for personal information.

7. EMAIL AND OTHER COMMUNICATIONS

You may opt out of promotional email by using the unsubscribe link in the message or contacting (MARKETING EMAIL). We may retain limited information on a suppression list to honor the opt-out. An opt-out does not stop non-promotional communications reasonably necessary for an inquiry, account, security issue, transaction, or customer relationship. Consent for automated telephone calls or text messages, if ever requested, will be collected separately where required and is not a condition of purchasing services unless the law permits otherwise.

8. INTERNATIONAL PROCESSING

Vexara is established in Türkiye. Personal information may therefore be accessed, transferred, stored, or otherwise processed in Türkiye, the United States, and other countries where Vexara's actual service providers operate. Those countries may have privacy laws different from the law where you live. Where a transfer mechanism or contractual safeguard is legally required, we will implement an appropriate mechanism. Processing of EEA, UK, or Swiss personal data may also be governed by a separate regional notice or data-processing and transfer terms.

9. RETENTION

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including to manage a prospect or customer relationship; provide Site, account, and security functions; honor communication choices; comply with legal, tax, accounting, and recordkeeping duties; resolve disputes; and enforce agreements. We consider the amount, nature, sensitivity, purpose, legal requirements, and risk of harm when setting retention periods.

In general, Site logs are kept for the period reasonably needed for operations and security; inquiry and business-contact records for the active relationship and a reasonable follow-up period; contract, invoice, and transaction records for legally required periods; and marketing data until opt-out or earlier deletion where required. Suppression records may be retained longer to ensure that an opt-out remains effective. Residual copies may persist temporarily in routine backups and are isolated or overwritten through ordinary cycles.

10. SECURITY

We use commercially reasonable administrative, technical, and organizational safeguards designed for the nature and risk of the personal information we process. Measures may include access controls, least-privilege permissions, multi-factor authentication for critical systems where available, encrypted transmission where supported, device protections, security updates, provider review, backups where appropriate, and incident-response procedures. No Internet transmission or storage method is completely secure, and we cannot guarantee absolute security.

If you believe your interaction with the Site or an account is no longer secure, notify us promptly at (SECURITY CONTACT EMAIL). Do not include sensitive data in an ordinary email.

11. U.S. STATE PRIVACY RIGHTS

Depending on your state, our role, the nature of the data, and applicable statutory thresholds or exemptions, you may have the right to:

confirm whether we process your personal information and obtain access to it;
correct inaccuracies; delete personal information; or obtain a portable copy, subject to legal exceptions;
opt out of sale, sharing, targeted advertising, or certain profiling that produces legal or similarly significant effects;
limit certain uses or disclosures of sensitive personal information, or withdraw consent where the law provides that right;
appeal a refusal to act on a request; and
receive equal service and not be unlawfully discriminated or retaliated against for exercising a privacy right.

How to submit a request. Use (PRIVACY REQUEST URL), email (PRIVACY EMAIL) with the subject "Privacy Request," or call (TOLL-FREE NUMBER IF REQUIRED). Identify your state and the right you wish to exercise. We will use information reasonably necessary to verify your identity and authority, which may include matching details already held or confirming control of an email address. Do not send government identifiers. If we cannot verify a request, we may ask for additional information or limit our response.

Authorized agents. Where permitted, an authorized agent may submit a request. We may require proof of the agent's authorization and may ask you to verify your identity or confirm the request directly, except where a valid power of attorney or applicable law provides otherwise.

Appeals. If we deny a request and your law provides an appeal right, reply to our decision or email (PRIVACY EMAIL) with the subject "Privacy Appeal" within the period stated in our response. We will explain the appeal result and, where required, how to contact the appropriate regulator.

12. CALIFORNIA DISCLOSURES

This section supplements the rest of the Policy for California residents. The categories below describe personal information Vexara may have collected in the preceding 12 months through the Site or its own business relationships. We collect and use only the categories relevant to the interaction.

Identifiers and contact data. Examples include Name, business email, phone, IP address, account ID, cookie ID. Sources: You; employer or colleagues; referrals; public business sources; Site and providers. Purposes and recipient categories: Site/account operation; inquiries; security; business relationships; marketing. Disclosed to operational providers, advisers, authorized organization users, and transaction/legal recipients.

Customer-record and commercial data. Examples include Address, billing and transaction records, requested or purchased services. Sources: You; employer; customer systems; payment or relationship providers. Purposes and recipient categories: Proposals, transactions, billing, support, records, and analytics. Disclosed to payment, accounting, CRM, professional, legal, and transaction recipients as relevant.

Internet or electronic activity. Examples include Pages, clicks, referrer, device/browser, logs, interaction and consent data. Sources: Site, device, cookies, security, hosting, and analytics tools. Purposes and recipient categories: Site delivery, security, diagnostics, analytics, preferences, and, if enabled, advertising. Disclosed to hosting, security, analytics, and optional advertising providers.

Approximate geolocation. Examples include General location inferred from IP. Sources: IP address and network or security tools. Purposes and recipient categories: Localization, security, fraud prevention, and aggregate analytics. Disclosed to operational and security providers.

Professional information. Examples include Employer, title, role, expertise, business profile, authority. Sources: You; employer/colleagues; referrals; professional platforms; public business sources. Purposes and recipient categories: B2B communications, relationship management, proposals, and marketing. Disclosed to CRM, communications, advisers, and transaction recipients as relevant.

Communications and inferences. Examples include Messages, meeting notes, preferences, service interests, feedback. Sources: You; interactions with Vexara; relationship and communication tools. Purposes and recipient categories: Responding, service and relationship management, personalization, analytics, and records. Disclosed to operational providers and authorized personnel/advisers.

Sensitive personal information. Public Site use is not intended to collect sensitive personal information other than account credentials or security information if an account is offered. Vexara does not use sensitive personal information to infer characteristics about individuals. Do not submit sensitive information through general forms.

Business-purpose disclosures. During the preceding 12 months, Vexara may have disclosed each relevant category in the table to the recipient categories shown for the business purposes described. Vexara does not sell personal information for money. Section 6 states whether identifiers and Internet activity were sold or shared under California's broader definitions through optional technologies.

California residents may exercise applicable rights to know/access, correct, delete, obtain information about categories and recipients, opt out of sale or sharing, limit certain sensitive-information uses, and receive non-discriminatory treatment through Section 11. Vexara will provide any request metrics or additional disclosure required if and when the law applies.

California online-tracking notice. The categories collected online and the categories of third parties are described in Sections 2, 4, 5, and this section. Our response to Do Not Track and recognized opt-out preference signals is described in Section 4. The process for requests is in Section 11. We notify users of policy changes as described in Section 15, and the Effective Date appears above.

13. CHILDREN

The Site is a general-audience business site and is not directed to children under 13. We do not knowingly collect personal information online from children under 13. If you believe a child has provided personal information through the Site, contact (PRIVACY EMAIL) so we can investigate and take appropriate action. We do not knowingly sell or share personal information of persons under 16.

14. THIRD-PARTY LINKS AND SOCIAL FEATURES

The Site may link to or embed third-party sites, social platforms, scheduling services, maps, videos, payment tools, or other features. Those third parties may independently collect information and apply their own privacy notices. Review their practices before using the feature. Vexara is not responsible for a third party's independent privacy or security practices.

15. CHANGES TO THIS POLICY

We may update this Policy prospectively to reflect changes in the Site, our practices, or legal requirements. We will post the revised version, update the date above, and provide additional notice or obtain consent if required by law. A material change will not be used to make a materially different use of previously collected personal information without any notice or choice required by applicable law.

16. CONTACT US

Questions, complaints, and privacy requests may be directed to:

Legal entity: Vexara Teknoloji Limited Şirketi

Registered address: Cevizli Mah. Zühal Cad. A Ticari Blok Apt. No:46/50

Registration: MERSİS / Trade Registry No.: 1144688

Privacy contact: privacy@vexara.ltd