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Global Privacy Notice

This Privacy Notice explains how PHISHARK TEKNOLOJİ ANONİM ŞİRKETİ (“PhiShark”, “we”) processes personal data when using its website, platform, APIs, browser and email plug-ins and other PhiShark products and services.

1. Data controller and our role

Data controller in terms of personal data processing activities carried out by PhiShark for its own purposes:

PHISHARK TEKNOLOJİ ANONİM ŞİRKETİ Cevizli Mah. Zuhal Cad. Ritim Istanbul Sitesi A5 Blok No:46E İç Kapı No:179 Maltepe/İstanbul MERSIS: 0729137429700001

PhiShark may act as a data processor to the extent that it processes personal data of third parties on behalf of a customer or user and for the purposes specified by the user. In cases where PhiShark processes personal data for its own purposes, it acts as the data controller.

2. What data do we process?

Depending on the service you use, we may process the following personal data:

  • name, surname, e-mail, organization and account information;
  • subscription, billing and transaction information;
  • IP address, device, browser, API and security logs;
  • URL, domain name, e-mail metadata and, to the extent necessary, e-mail content, links, PDF, QR code, file and other security indicators sent for analysis;
  • security analyses, scores and results;
  • support requests and your communications with PhiShark;
  • cookies and user preferences.

Full payment card information may be processed by the payment service provider used under its terms and privacy policy.

3. Where do we get the data?

We may obtain personal data directly from you, from the company or organization to which your account is linked, from use of PhiShark services, from content submitted for analysis, from publicly available sources and from security or threat intelligence providers.

It is possible that e-mails, documents, URLs or other content sent for analysis may contain personal data of third parties.

4. Why and for what legal reasons do we process data?

Personal data mainly;

  • To provide PhiShark services and security analysis;
  • manage accounts and subscriptions;
  • detect phishing, abuse and security threats;
  • ensuring the security of our services and systems;
  • provide customer support;
  • fulfill payment, invoicing and legal obligations;
  • investigate abuse and security incidents; and
  • Establishing, exercising or protecting our legal rights

We process for.

Processing activities are based on legal reasons such as the establishment or performance of a contract, fulfillment of legal obligations, protection of legal rights, our legitimate interests or consent where necessary, depending on the applicable legislation.

In respect of the European Union, the European Economic Area (“EEA”) and the United Kingdom, if the GDPR or the UK GDPR applies, we may process personal data on the basis of fulfillment of a contract, fulfillment of our legal obligations, consent or our legitimate interests, in particular for the provision of services. Our legitimate interests; This includes ensuring the security of our services and systems, preventing phishing and abuse, protecting the reliability of the services and defending our legal rights. We only rely on this legal reason in cases where the rights and freedoms of the persons concerned do not outweigh our interests.

You can refer to the KVKK Information Text for the legal reasons for our personal data processing activities in Turkey and details within the scope of the Personal Data Protection Law No. 6698.

5. Contents processed by PhiShark products

Our browser and e-mail plug-ins, as well as our URL, PDF, QR, Mail Protection and similar security features, can process the necessary content and technical signals to perform the security analysis requested by the user.

Users and corporate customers are responsible for having the necessary legal basis or authority in respect of third party data they transfer to PhiShark and to remove or mask, to the extent possible, sensitive information that is not required for analysis.

6. AI-powered security analysis

PhiShark can utilize technical controls, threat intelligence sources and artificial intelligence-supported systems when performing security analyses.

The data required for analysis may be processed by cloud, security or AI service providers serving on behalf of PhiShark for the purpose of providing the service.

Security scores, classifications and descriptions created by PhiShark are used for decision support purposes. PhiShark services are not designed to make decisions about a person that have legal effects or similarly significantly affect that person, based solely on automated processing.

AI and cybersecurity analytics can produce false positives or false negatives. Important decisions should not be based solely on PhiShark output.

For detailed information, you can refer to the Information on AI and Cyber Security Outcomes.

7. With whom do we share data?

Personal data only to the extent necessary;

  • cloud and hosting providers;
  • AI and technical infrastructure providers;
  • cybersecurity and threat intelligence providers;
  • payment, billing, communications and support providers;
  • professional advisors; and
  • legally authorized public institutions, regulatory authorities and courts

We can share it with.

PhiShark does not sell personal data.

Up-to-date information about service providers that process data on behalf of PhiShark is located in the Sub-Processors and Service Providers Section.

8. International data transfers

Personal data may be transferred internationally because some of the service providers we use are located outside Türkiye or your country.

These transfers are carried out using transfer mechanisms and necessary safeguards in accordance with applicable data protection legislation. These may include, to the extent applicable, adequacy decisions, standard contractual clauses or other transfer mechanisms permitted by applicable data protection legislation.

Detailed information regarding international transfers from Türkiye is included in the KVKK Information Text.

9. Storage and security

We retain personal data only for as long as necessary for the purpose for which they were collected, legal obligations, security needs and possible legal claims.

When the processing conditions are no longer valid, we delete, destroy or anonymize personal data in accordance with applicable legislation.

For detailed periods, you can refer to the Data Retention and Deletion Policy.

We apply technical and administrative security measures commensurate with the risk to protect personal data against unauthorized access, loss, alteration or disclosure.

10. Your rights

Depending on your country and applicable legislation, you may have the right to access your personal data, request its correction or deletion, request restriction of processing, object to certain processing, request data portability where appropriate, and withdraw your consent in the case of consent-based processing.

The rights and application methods of relevant persons in Turkey under Article 11 of Law No. 6698 are explained in the KVKK Information Text.

If you are located in the EEA or the UK, you also have the right to lodge a complaint with the competent data protection authority regarding the processing of your personal data.

In cases where PhiShark processes data on behalf of a corporate or individual user, the relevant request may need to be directed to the customer who is the data controller.

11. Cookies

Mandatory cookies and similar technologies may be used on our website. Technologies that require consent are not activated without obtaining the necessary consent in accordance with applicable legislation.

For detailed information, you can see the Cookie and Local Storage Policy.

12. Changes and communication

We may update this Notice in response to changes in our products, data processing activities or legislation. Important changes are published on this page together with the current version and last update date and are notified separately when necessary.

For your questions or requests regarding privacy and personal data protection:

PHISHARK TEKNOLOJİ ANONİM ŞİRKETİ Cevizli Mah. Zuhal Cad. Ritim Istanbul Sitesi A5 Blok No:46E İç Kapı No:179 Maltepe/İstanbul Email: [email protected]