Privacy Policy
TASLAK - hukuki inceleme gerekir (DRAFT - legal review required). Do not publish this text before a lawyer reviews it. Notes in square brackets are points to verify. [Because RTİB is based in Moscow, the lawyer must also check whether Russian Federal Law No. 152-FZ on Personal Data applies, in addition to the KVKK and the GDPR.]
Last updated: 26.09.2026
This policy explains how we process your personal data when you visit www.rtib.org and use the forms on the site. The information notice for event and organisation participants is on the Personal Data (KVKK) page.
1. Data controller
RTİB - Rus Türk İş İnsanları Birliği (Russian-Turkish Businessmen's Association)
Address: Bolshoy Ovchinnikovsky per., 16, 115184 Moscow, Russian Federation
E-mail: info@rtib.org
2. Personal data we process
When you visit the site. The site is hosted on Cloudflare Pages. To deliver and protect the site, Cloudflare processes your IP address, the requested page, the time and your browser information (User-Agent). RTİB uses no analytics, tracking or advertising tools on this site and builds no visitor profiles.
When you use the forms. The contact form and the KVKK information request form collect: full name, e-mail address, your message, the company name (optional, contact form only) and the page language. Before a form is sent, a Cloudflare Turnstile check runs. Turnstile processes your IP address and short-lived browser signals to tell people from automated submissions.
In your browser. To remember that you closed the cookie notice, the site writes the item cookie_consent to the local storage (localStorage) of your browser. This item holds no personal data. See the Cookie Policy for details.
3. Purposes and legal bases
| Purpose | Data | KVKK legal basis | GDPR legal basis |
|---|---|---|---|
| Delivering and securing the site | IP address, request data | Art. 5(2)(f) legitimate interest | Art. 6(1)(f) legitimate interest |
| Protecting the forms against bots (Turnstile) | IP address, browser signals | Art. 5(2)(f) legitimate interest | Art. 6(1)(f) legitimate interest |
| Answering questions sent with the contact form | full name, e-mail, company, message | Art. 5(2)(f) legitimate interest [to verify] | Art. 6(1)(f) legitimate interest; Art. 6(1)(b) for requests before a membership application [to verify] |
| Answering KVKK information requests | full name, e-mail, message | Art. 5(2)(ç) legal obligation (KVKK Art. 13) | Art. 6(1)(c) legal obligation |
4. Recipients of personal data
We do not sell your personal data and do not share it for advertising. We transfer the data only to these service providers (processors):
| Recipient | Country | Role | Data |
|---|---|---|---|
| Cloudflare, Inc. (Cloudflare Pages and Turnstile) | USA | Hosting, security and bot check (processor) | IP address, request data, browser signals |
| Plus Five Five, Inc. (Resend) | USA | Delivery of form messages to RTİB by e-mail (processor) | full name, e-mail, company, message, page language |
| [E-mail provider of the info@rtib.org mailbox - to add] | [country - to add] | Storage of received messages | form messages |
5. International transfers
Cloudflare and Resend process data in the USA. For this reason your form data and connection data are transferred abroad.
- KVKK Art. 9: The Turkish Personal Data Protection Board has no adequacy decision for the USA. The transfer is based on the standard contract that the Board published under KVKK Art. 9(4). The signed standard contract is notified to the Authority within 5 business days. [Verify that the standard contracts with the providers are signed and notified.]
- GDPR Chapter V: Cloudflare, Inc. and Resend (Plus Five Five, Inc.) are certified under the EU-U.S. Data Privacy Framework (GDPR Art. 45, adequacy decision of the European Commission of 10.07.2023). In addition, the data processing agreements of the providers include the Standard Contractual Clauses (GDPR Art. 46(2)(c)). [Verify the current certification status on dataprivacyframework.gov.]
6. Retention periods
- Form messages: kept in the RTİB mailbox for [period to set], then deleted.
- Resend delivery logs: per the Resend retention period [to verify].
- Cloudflare connection logs: per the Cloudflare retention period [to verify].
cookie_consent: stays in your browser until you delete your browser data.
7. Your rights
Under KVKK Art. 11 you have the right to learn whether your personal data is processed, to request information, to learn the purpose of processing, to know the third parties that receive it, to request correction, deletion or destruction, to request that third parties are told of these actions, to object to a result of automated analysis and to claim compensation for damage.
If the GDPR applies to you, you also have the rights of access, rectification, erasure, restriction of processing, data portability and objection (GDPR Art. 15-22), and the right to lodge a complaint with a supervisory authority.
Send your request with the information request form on the Personal Data (KVKK) page, by e-mail to info@rtib.org or in writing to the address above. We answer free of charge within 30 days at the latest. In Turkey you can complain to the Personal Data Protection Board.
8. Changes
We can update this policy. The current text is always on this page. If we add a tracking or analytics tool to the site, we will update this page and the Cookie Policy before that.