At ŞAK Almanya, we take the protection of the personal data of our visitors, students, and anyone who contacts us seriously.
This Privacy Policy explains which personal data may be processed when you visit sakalmanya.com.tr or contact us via WhatsApp or email, the purposes for which that data may be used, and the rights you have regarding your personal data.
This notice has been prepared with regard to the transparency principles of the EU General Data Protection Regulation (GDPR) and, where applicable, Turkish Law No. 6698 on the Protection of Personal Data (KVKK).
1. Data Controller
The person responsible for processing personal data in connection with this website:
Ş. Anday Kahveci (ŞAK Almanya)
Website: https://sakalmanya.com.tr
Email: iletisim@andaykahveci.com
ŞAK Almanya is currently in a non-commercial preparation and pilot phase. The full legal business name and registered address will be added to this section once the required approval and registration steps in Germany are completed.
2. What Data May We Process?
Depending on your interaction with ŞAK Almanya, the following categories of personal data may be processed.
Contact information
When you contact us via WhatsApp or email:
- full name
- phone number or email address
- any information you choose to share in your message (e.g. your current German level, the service you're interested in, your target university/Hochschule/city, or questions about the visa process)
The website does not have a form that sends your personal data to us directly: messages sent via WhatsApp are delivered through WhatsApp's (Meta's) own infrastructure, and emails go directly, through your own email provider, to iletisim@andaykahveci.com.
Please do not send health information, identity document images, or other sensitive personal data via WhatsApp or email unless it is genuinely necessary for the consulting request.
Technical and usage information
The following technically necessary information may be processed to host and secure the website: IP address, device and browser type, time of visit, pages requested, and referral source. Where you consent, campaign parameters such as utm_source, utm_medium, and utm_campaign may also be processed; see Section 6.
3. Why Do We Process Personal Data?
Personal data may be processed for the following purposes:
- responding to contact requests received via WhatsApp or email
- evaluating requests for German private tutoring, or for German university, Hochschule, Master's, Ausbildung, or student visa consulting
- understanding your current German level and goals
- securing the website and identifying technical issues
- measuring website performance and advertising effectiveness, where you have given consent
- fulfilling legal obligations
- protecting our rights and the rights of our users
Personal data is not used in a manner incompatible with the purposes for which it was collected.
4. Legal Bases for Processing
Depending on the specific processing activity, personal data may be processed on one or more of the following legal bases:
- carrying out pre-contractual steps at the user's request
- the formation or performance of a contract
- compliance with legal obligations
- the legitimate interests of ŞAK Almanya or relevant third parties
- explicit consent of the data subject, where required (e.g. Analytics and marketing cookies)
Where explicit consent is required, it is obtained separately from this notice and given freely. Acknowledging that you have read this notice is not, by itself, the same as giving consent.
5. Contact Channels
When you write to us on WhatsApp, your message is delivered through WhatsApp Ireland Limited / Meta Platforms infrastructure and is subject to WhatsApp's own privacy policy.
When you send an email, your message reaches iletisim@andaykahveci.com directly through your own email provider.
The website does not have any form that transmits your personal data to a server or database; the site does not have a backend or a user account system.
6. Cookies, Analytics, and Similar Technologies
Beyond the storage that is technically necessary for the site to function, this site uses Google Analytics (gtag.js) and Google Ads conversion measurement. These tools are only activated once you consent to "Analytics" and/or "Marketing" in the cookie-preferences panel at the bottom of the site.
Your preference is stored locally in your browser (under the key "sak-consent-v1") and can be changed at any time via the "Cookie preferences" link in the footer.
If you consent to Analytics or Marketing, campaign parameters such as utm_source, utm_medium, utm_campaign, utm_content, utm_term, gclid, gbraid, and wbraid, along with your first and last landing page, may be stored locally in your browser (under the key "sak-attribution-v1").
The site also uses Vercel Analytics and Vercel Speed Insights, which are designed to measure site performance and do not use cookies by default.
For links from sakalmanya.com.tr to deutschlaender.com.tr, a Google Analytics linker is used so that measurement stays consistent across both sites; this is only active where Analytics consent has been given.
If a new Analytics or marketing tool is added, this policy will be updated.
7. Third-Party Service Providers
The site uses Vercel for hosting and delivery. Where you have consented, Google Analytics and Google Ads (Google LLC) are used. Communication via WhatsApp uses WhatsApp Ireland Limited / Meta Platforms infrastructure.
The site does not have a backend database, user account system, or payment system, and there is no other known third-party data processor beyond those listed above. This section will be updated if and when a new third-party service provider is introduced.
8. International Transfer of Data
The servers or company headquarters of the Vercel, Google, and WhatsApp/Meta infrastructure we use may be located in different countries, particularly within the European Economic Area and the United States, so personal data may be processed outside Türkiye. Where such a transfer takes place, care is taken to use the appropriate legal safeguards required by applicable data protection law.
9. Data Retention
Personal data is retained for as long as necessary for the purpose it was collected for, and to the extent required by applicable legal obligations. When determining retention periods, factors such as whether the contact or consulting process is ongoing, the nature of the service relationship, statutory retention obligations, dispute and claim periods, and data security requirements may be taken into account.
10. Data Security
Appropriate technical and organisational measures are taken to protect personal data against unauthorised access, loss, misuse, or unauthorised alteration. That said, no data transmission over the internet or method of electronic storage can be guaranteed to be absolutely secure.
11. Your Rights
Depending on applicable data protection law, you may have the following rights regarding your personal data:
- to learn what personal data about you is processed
- to request access to your personal data
- to request correction of inaccurate or incomplete data
- to request deletion of your data once the conditions are met
- to request restriction of processing
- to object to processing in certain circumstances
- to request data portability where applicable
- to withdraw your consent where processing is based on consent
- to lodge a complaint with the competent data protection authority
Withdrawing consent does not retroactively affect the lawfulness of processing carried out before the withdrawal.
12. Rights Under the Turkish KVKK
Where Turkish Law No. 6698 on the Protection of Personal Data applies, data subjects may exercise the rights set out in Article 11 of the KVKK, which generally include the right to:
- learn whether personal data is being processed
- request information about it if it is
- learn the purpose of processing and whether it is used in accordance with that purpose
- learn the third parties to whom data is transferred
- request correction of incomplete or inaccurate data
- request deletion or destruction of data once the conditions are met
- request that any correction or deletion be notified to the parties the data was transferred to
- object to a result reached solely through automated processing, under the conditions set out in the law
- claim compensation for damage arising from unlawful processing
13. Data of Minors and Underage Students
Some of the students who use ŞAK Almanya's services may be under the age of 18. Particular care is taken to minimise the personal data processed in connection with underage students.
Where involving a parent or legal guardian is legally required or necessary given the nature of the service, the relevant contact and consent processes are carried out accordingly.
14. Third-Party Links
Our website may contain links to universities, to deutschlaender.com.tr, to our social media profiles (Instagram, YouTube, LinkedIn, GitHub), and to other third-party websites. The content and privacy practices of those sites are not under ŞAK Almanya's control. When you visit a third-party site, we recommend reviewing that site's own privacy policy.
15. Changes to This Privacy Policy
This Privacy Policy may be updated from time to time to reflect technical developments on the website, changes to our services, or legal requirements. The current version is published on this page, and the last-updated date is shown at the top of the page.
16. Contact
For questions about your personal data or this Privacy Policy:
ŞAK Almanya
Email: iletisim@andaykahveci.com
Web: https://sakalmanya.com.tr
If you wish to make a formal data protection request under applicable law, you may need to provide sufficient information for your request to be understood and processed.