Privacy Notice (KVKK)

1. Controller

Controller: DILMEX LIMITED (167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF, United Kingdom; email: destek@dilmex.net). Send your applications to destek@dilmex.net.

2. Personal data processed

• Identity and contact: name, e-mail address, date of birth.
• Customer transactions: orders, codes bought (stored encrypted), records of when codes were viewed, support requests, accepted contracts and region confirmations.
• Transaction security: IP address and the country derived from it, browser details, session records, a risk score for fraud prevention.
• Finance: payment amounts, the payment provider's transaction reference, the payer country and payer ID reported by PayPal (card numbers and PayPal login details are not processed and stay with PayPal).

3. Purposes and legal grounds

• Creating the account, taking orders, delivering and showing codes — establishment and performance of a contract (KVKK Art. 5/2-c).
• Documenting the 18+ requirement and contractual capacity (date of birth) — establishment of a contract (Art. 5/2-c).
• Accounting and consumer law obligations — legal obligation (Art. 5/2-ç).
• Preventing fraud and misuse, security and defending legal claims — legitimate interest and establishing a right (Art. 5/2-e, f). Orders with a high risk score are reviewed by a member of staff.

4. Recipients

• Payments: PayPal (PayPal (Europe) S.à r.l. et Cie, S.C.A. and affiliates).
• E-mail delivery: Mailgun (EU data centre).
• Hosting, storage and infrastructure: DigitalOcean, Vercel, Cloudflare (Cloudflare also for the bot check on forms).
• No personal data is transferred to code suppliers.
• Competent public authorities and courts: only where required by law and to the extent requested.

5. Transfers abroad

The controller is established in the United Kingdom; your data is processed in the United Kingdom and in the countries of the providers above (EU, USA). Transfers abroad rely, under KVKK Art. 9, on appropriate safeguards such as the standard contracts announced by the Board and, for occasional transfers, on necessity for the performance of the contract with you.

6. Collection method and retention

Data is collected electronically through the site and account forms and from the payment provider. It is kept while your account is open and afterwards for the statutory limitation and retention periods; when you delete your account your personal data is anonymised and the codes delivered to you are erased.

7. Your rights (KVKK Art. 11)

Under KVKK Art. 11 you may learn whether your data is processed and request information about it, learn the purpose of processing and whether it is used accordingly, know the third parties it is transferred to in Türkiye or abroad, ask for correction if it is incomplete or wrong, ask for erasure or destruction under KVKK Art. 7, ask that corrections and erasures be notified to recipients, object to an adverse outcome arising solely from automated analysis, and claim compensation for damage caused by unlawful processing.

Send applications in writing from the e-mail address registered on your account to destek@dilmex.net, in line with the Communiqué on the Procedures and Principles of Application to the Controller. Applications are answered free of charge within 30 days.

If your application is rejected, you find the answer insufficient or no answer is given in time, you may complain to the Personal Data Protection Board under KVKK Art. 14 within 30 days of learning the answer and in any case within 60 days of your application.