Privacy Policy

Nucifera Global

Last Updated: December 1, 2025

Quick Summary

Nucifera Global (“we,” “our,” or “us”) collects and processes personal information to deliver our business transformation services.

We protect your data with industry-standard security measures and comply with Turkish (KVKK), European (GDPR), and US data protection regulations.

You have rights to access, correct, or delete your information at any time.

1. Who We Are

Nucifera Global is a business transformation consultancy headquartered in Turkey, operating globally with clients in the European Union, United States, and Turkey.

Contact Information:

Email: [email protected]
Website: https://nuciferaglobal.com
Data Protection Officer: [email protected]

2. Information We Collect

2.1 Information You Provide Directly

When you interact with our services, we collect the following information directly from you:

Contact Information

Name
Email address
Phone number
Company name
Job title

Communication Data

Messages sent through contact forms
Email correspondence
Meeting notes

Project Information

Business requirements
Project specifications
Consultation requests

Account Information (Future)

Username
Password
Profile information (when user accounts launch)

Billing Information (Future)

Payment details
Billing address
Transaction history for invoicing

2.2 Information Collected Automatically

When you visit our website, we automatically collect:

Usage Data

Pages visited
Time spent on site
Navigation patterns
Referring URLs

Device Information

Browser type
Operating system
IP address
Device identifiers

Cookies and Tracking

Analytics cookies
Functional cookies
Preference cookies

See our Cookie Policy for detailed information about cookies.

Email Tracking

Email open rates
Click-through rates for our communications

2.3 Information from Third Parties

We may receive information from:

Analytics Providers: Google Analytics for website usage insights
Communication Tools: Email service providers for delivery and engagement metrics
Public Sources: Business information from publicly available sources for B2B outreach

3. How We Use Your Information

We use collected information for the following purposes:

3.1 Service Delivery

Provide business transformation consulting services
Respond to inquiries and consultation requests
Manage client relationships and projects
Deliver contracted services (Source, Systems, Flow solutions)

3.2 Communication

Send service updates and project communications
Respond to questions and support requests
Send newsletters and marketing communications (with consent)
Provide relevant business insights and resources

3.3 Business Operations

Process payments and manage billing (future)
Maintain user accounts and authentication (future)
Analyze website performance and user behavior
Improve our services and user experience
Comply with legal and regulatory obligations

3.4 Marketing and Analytics

Understand how visitors use our website
Personalize content and service recommendations
Conduct market research and competitive analysis
Send promotional materials (with opt-out option)

We process personal data based on the following legal grounds:

Consent: When you provide explicit consent (e.g., newsletter signup, cookie acceptance)
Contract Performance: To deliver services you’ve requested or contracted
Legitimate Interest: For business operations, analytics, and service improvement
Legal Obligation: To comply with applicable laws and regulations

We do not sell your personal information.

We share data only in these circumstances:

5.1 Service Providers

We share information with trusted third-party providers who assist our operations:

Email Services: For sending communications and newsletters
Analytics Providers: Google Analytics for website performance analysis
Cloud Hosting: Secure data storage and website hosting providers
Payment Processors: (Future) For secure payment processing

All service providers are contractually obligated to protect your data and use it only for specified purposes.

5.2 Legal Requirements

We may disclose information when required by law:

In response to court orders, subpoenas, or legal processes
To protect our rights, property, or safety
To prevent fraud or security threats
To comply with regulatory investigations

5.3 Business Transfers

If Nucifera Global is involved in a merger, acquisition, or asset sale, your information may be transferred as part of that transaction.

We will notify you of any such change in ownership or control.

6. Data Security

We implement industry-standard security measures to protect your information:

Encryption

Data transmitted via HTTPS/TLS encryption

Access Controls

Limited access to personal data on a need-to-know basis

Secure Storage

Data stored in secure, access-controlled environments

Regular Audits

Periodic security assessments and vulnerability testing

Important: No method of internet transmission or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

7. Data Retention

We retain personal information only as long as necessary:

Data Type	Retention Period
Active Client Data	Duration of business relationship plus 7 years for legal/tax purposes
Marketing Data	Until you unsubscribe or request deletion
Analytics Data	Aggregated data retained indefinitely; individual data anonymized after 26 months
Account Data (Future)	Until account deletion or inactivity period (as specified in terms)

8. Your Privacy Rights

8.1 Rights for All Users

You have the right to:

Access: Request a copy of your personal data we hold
Correction: Update or correct inaccurate information
Deletion: Request deletion of your personal data (subject to legal obligations)
Opt-Out: Unsubscribe from marketing communications at any time
Data Portability: Receive your data in a structured, machine-readable format

To exercise these rights, contact us at: [email protected]

If you are located in the European Union, you have additional rights:

Your GDPR Rights

Right to Object: Object to processing based on legitimate interests
Right to Restrict Processing: Request temporary restriction of processing
Right to Withdraw Consent: Withdraw consent for consent-based processing
Right to Lodge a Complaint: File a complaint with your local data protection authority

EU Data Protection Authority

Visit https://edpb.europa.eu to find your local authority.

Legal Basis for Transfer

We transfer EU personal data based on standard contractual clauses and adequacy decisions.

8.3 Additional Rights for Turkish Users (KVKK)

If you are located in Turkey, you have rights under the Personal Data Protection Law (KVKK No. 6698):

Your KVKK Rights

Right to Learn: Whether your personal data is being processed
Right to Information: Request information about processing activities
Right to Correction: Request correction of incomplete or inaccurate data
Right to Deletion: Request deletion or destruction of data under KVKK Article 7
Right to Object: Object to processing that produces legal consequences
Right to Notification: Request notification of corrections, deletions, or destructions to third parties

To exercise KVKK rights, contact our Data Controller at: [email protected]

Turkish Data Protection Authority (KVKK): https://www.kvkk.gov.tr

8.4 Additional Rights for US Users

California Residents (CCPA/CPRA)

You have the right to:

Know what personal information is collected
Delete personal information
Opt-out of sale of personal information (we do not sell data)
Non-discrimination for exercising privacy rights

Other US States

Users in Virginia, Colorado, Connecticut, and Utah have similar rights under their respective state laws.

To exercise US privacy rights, contact: [email protected]

9. International Data Transfers

Nucifera Global operates globally. Your information may be transferred to and processed in:

Turkey: Our primary operations headquarters
European Union: For EU client service delivery
United States: For cloud hosting and analytics services

We ensure appropriate safeguards for international transfers:

EU Standard Contractual Clauses for EU data transfers
KVKK-compliant transfer mechanisms for Turkish data
Data Processing Agreements with all international service providers

10. Cookies and Tracking Technologies

We use cookies and similar technologies for functionality and analytics.

For detailed information, please see our Cookie Policy.

Cookie Control: You can manage cookie preferences through your browser settings or our cookie consent banner.

11. Children’s Privacy

Our services are not directed to individuals under 18 years of age.

We do not knowingly collect personal information from children.

If you believe we have collected data from a child, contact us immediately at [email protected].

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements.

Material changes will be communicated via:

Prominent notice on our website
Email notification to registered users (future)
Updated “Last Updated” date at the top of this policy

We encourage you to review this policy regularly.

13. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or our data practices:

Email: [email protected] General Inquiries: [email protected] Website: https://nuciferaglobal.com

Response Time: We aim to respond to all privacy requests within 30 days.

14. Supervisory Authorities

If you believe your privacy rights have been violated, you may contact:

EU Users: Your local Data Protection Authority (https://edpb.europa.eu)
Turkish Users: Personal Data Protection Authority (https://www.kvkk.gov.tr)
US Users (California): California Attorney General (https://oag.ca.gov)

Effective Date: December 1, 2025

This Privacy Policy is written in English. Translations may be provided for convenience, but the English version governs in case of discrepancies.