Growtyx

GROWTYX LEGAL

Privacy and Cookie Policy

Last Updated: September 13, 2026

This English version is provided for information purposes only. In the event of any conflict or inconsistency, the Turkish original governs and is the legally binding text.

At Growtyx ("Growtyx", "Platform", "Service", "we", "us" or "our"), we take the privacy and security of personal data seriously.

This Privacy and Cookie Policy ("Policy") explains what personal data is collected, for what purposes it is processed, with whom it may be shared, for how long it may be retained, and what rights data subjects have, when using the Growtyx website, application and SaaS services.

Growtyx is primarily a B2B SaaS platform aimed at businesses, professional users, and their authorized employees, representatives or consultants.

1. Our Role as Data Controller and Data Processor

For personal data processed in connection with the provision of Growtyx's own services, the management of user accounts, communication, billing, security and the fulfillment of legal obligations, Growtyx or [Full Name], the legal provider of the service, may act as the Data Controller under applicable law.

For personal data that the User transfers to the Growtyx Platform about their own customers, visitors, employees or other third parties, or that the User provides to Growtyx through authorized integrations, the User may act as the Data Controller and Growtyx as the Data Processor, under the agreement between the parties and applicable law.

In this context, the User represents and warrants that:

  • the personal data they transfer to the Platform was obtained lawfully;
  • they have fulfilled the necessary disclosure and other legal obligations;
  • they hold the necessary authority for the relevant data to be processed by Growtyx and used within the scope of the Service.

Growtyx, in its capacity as Data Processor, processes personal data in accordance with the User's instructions and for the purpose of providing the Service under the agreement between the parties.

2. Data We Collect and Process

Depending on the nature of the Service and how the User uses the Platform, Growtyx may process the following categories of data:

2.1. Account and Contact Data

The following, provided by the User, may be processed:

  • first and last name,
  • email address,
  • phone number,
  • company or brand information,
  • account and subscription information,
  • support and communication records.

2.2. Billing and Transaction Data

In connection with the subscription and service relationship, the following may be processed:

  • purchased plan,
  • subscription start and end information,
  • payment status,
  • invoice information,
  • transaction and accounting records.

Holding credit card details within Growtyx's own systems may not be necessary, depending on the technical structure of the payment service used. Where payment information is processed directly by the payment institution or the Merchant of Record, the relevant data is not stored on Growtyx's payment infrastructure.

2.3. Integration and Commercial Data

Depending on the third-party services the User connects to Growtyx and the permissions they grant, the following may be processed:

  • sales data,
  • order data,
  • product and category information,
  • traffic and conversion metrics,
  • Google Search Console data,
  • Google Analytics 4 data,
  • SEO and performance metrics,
  • advertising or marketing performance data,
  • other e-commerce and analytics data.

Growtyx aims to access only the data that is necessary for the Service and that the User has authorized.

2.4. Technical and Usage Data

The following technical and usage data may be collected automatically while the Platform is used:

  • IP address,
  • device type,
  • operating system,
  • browser type,
  • access time,
  • session information,
  • features used,
  • actions performed,
  • error and security logs,
  • log records,
  • approximate location information.

This data may be used to secure the Service, detect errors, monitor performance, prevent misuse, and improve the Service.

2.5. Integration Authorization Data

When an integration with a third-party service is established, OAuth authorization data, access tokens, API keys or similar technical authentication data may be used, depending on the technical structure of the integration.

Growtyx aims not to request or store user passwords for third-party services. That said, the specific technical authorization data processed may vary depending on the integration method used.

3. Purposes of Processing and Legal Bases

Personal data processed by Growtyx may be used, within the framework of applicable law, for the following purposes:

  • creating and managing the User's account,
  • providing the SaaS services,
  • carrying out subscription and payment processes,
  • providing customer support,
  • setting up and running integrations,
  • providing SEO, sales, performance and conversion analysis,
  • generating AI-powered analysis and recommendations,
  • securing the Platform,
  • detecting errors, misuse and security incidents,
  • technical development and performance improvements,
  • fulfilling legal and regulatory obligations,
  • resolving disputes and protecting legal rights,
  • sending necessary service notifications to the User.

Where applicable, the following legal bases under Article 5 of KVKK (Turkey's Law on the Protection of Personal Data) may be relied upon for processing personal data:

  • necessity for the establishment or performance of a contract,
  • fulfillment of a legal obligation,
  • the establishment, exercise or protection of a right,
  • the data controller's legitimate interest.

Where a specific processing activity legally requires explicit consent, the necessary consent is separately obtained.

4. Data Provided by the User and Authorization

The User is responsible for ensuring that the information, data, integrations, connections and access rights they provide to Growtyx are accurate, current and lawful.

Except where resulting from Growtyx's own fault, Growtyx is not responsible for outcomes arising from incomplete, incorrect, outdated or unauthorized information, data or access provided by the User.

When an integration with a third-party service is established, data may be received by Growtyx from that service, or certain data may be transferred from Growtyx to that service, depending on the technical structure of the integration and the permissions granted by the User.

5. Data Minimization and Usage Limits

Growtyx processes personal data for specified, explicit and legitimate purposes, and to the extent required by those purposes.

Growtyx does not sell personal data without a legal basis, nor does it use personal data as part of an independent data brokering activity.

Sharing User data with third-party service providers is limited to necessary purposes such as providing the Service, ensuring its security, operating the technical infrastructure, carrying out payment and communication processes, running AI-powered features, or fulfilling legal obligations.

Where personal data is anonymized or sufficiently aggregated such that it can no longer be associated with an identified or identifiable natural person, this data may be used to analyze service performance, conduct statistical studies, develop products and features, and make security/performance improvements.

6. Third-Party Service Providers

Growtyx may make use of third-party service providers in various categories in order to provide the Service.

These may include:

  • cloud infrastructure and hosting,
  • database,
  • CDN and application infrastructure,
  • payment and Merchant of Record,
  • email, SMS and communication services,
  • security and monitoring,
  • analytics,
  • customer support services,
  • integration services,
  • AI and machine learning infrastructure.

Third-party service providers acting on Growtyx's behalf have their access to personal data limited to what the service they provide requires.

Where applicable, agreements governing confidentiality, data security and data processing obligations are entered into with these service providers.

An up-to-date list of sub-processors may be published separately.

7. International Data Transfers

Some of the infrastructure, hosting, payment, communication, analytics or AI services Growtyx uses may be located abroad, or data may be processed on systems located abroad.

In such cases, the transfer of personal data abroad is carried out within the framework of Article 9 of KVKK and other applicable legislation.

Depending on the nature of the transfer, an adequacy decision, appropriate safeguards, standard contractual clauses, or other transfer mechanisms provided for under applicable law may be relied upon.

Where a standard contract is used for the international transfer of data, the necessary procedures — including notifying the relevant Turkish Data Protection Authority as required by law — are carried out separately.

International data transfers are not intended to rely solely on a general and unlimited "explicit consent" mechanism.

8. Data Retention and Deletion

Growtyx retains personal data for as long as necessary for the purpose of processing and to the extent required by applicable legal obligations.

Retention periods may vary depending on the category of data, the purpose of processing, the service relationship with the User, legal obligations, and technical requirements.

Technical Logs

We aim not to retain the following, generated during the technical operation of the Crawler and the Platform, for longer than necessary:

  • crawl records,
  • HTTP status codes,
  • error logs,
  • technical performance logs,
  • similar temporary logs.

Where a specific retention period is defined for a particular type of log, that period may be described in the relevant system or service documentation.

Account and Transaction Records

Account, subscription, billing and transaction records may be retained for as long as necessary to carry out the service relationship and to fulfill related legal obligations.

Where certain records need to be kept longer for reasons such as tax, accounting, commercial recordkeeping, or dispute resolution, those records may be retained until the end of the applicable legal period.

Account Closure

When the User closes their account or the service relationship ends, data is deleted, anonymized or removed from access to the extent possible.

That said:

  • records that must be legally retained,
  • records necessary to resolve an ongoing dispute,
  • records necessary for security and fraud prevention purposes,
  • data held in technical backups as part of normal deletion cycles

may be retained for their applicable retention periods.

9. Data Security

Growtyx aims to implement technical and administrative measures appropriate to the nature and risk level of the Service, in order to prevent the unlawful processing of personal data, unauthorized access, and data loss.

These measures may include access authorization, encryption, secure authentication, access controls, logging, security monitoring, infrastructure security, and other necessary technical/administrative controls.

The technical security mechanisms Growtyx uses may change and be improved over time.

For this reason, no binding commitment is made here that any specific software, library or security technology will continue to be used indefinitely.

10. Data Breaches

If personal data is unlawfully obtained by others, or a personal data security breach occurs, Growtyx fulfills the notification obligations under applicable law in cases where it acts in its own capacity as Data Controller.

Under KVKK, the Turkish Data Protection Authority's practice — requiring notification to the Board without delay and within 72 hours at the latest from when the data controller becomes aware of the breach — is taken into account. Notifications to affected data subjects are also made based on the nature of the incident and applicable law.

In cases where Growtyx acts in its capacity as Data Processor, the relevant data breach is reported to the User, as Data Controller, within the procedure and timeframes set out in the agreement between the parties, and the necessary cooperation is provided.

11. Google User Data and API Limited Use Policy

Growtyx uses data accessed through Google APIs — including Google Search Console and Google Analytics 4 (GA4) — solely to provide the relevant integration, organic search analysis, performance reporting, conversion analysis, and to provide or improve the related features offered in the User interface.

Data Accessed

When a Google account is connected, only the data authorized by the User and necessary for Growtyx to provide the relevant feature is accessed.

This may include, for example:

  • Search Console click and impression metrics,
  • search queries,
  • site performance data,
  • GA4 traffic and conversion metrics,
  • related measurements relevant to product or performance analysis.

Use

Data obtained from Google APIs may be used to provide the User with reports, charts, analysis and related performance features on the Growtyx Platform.

Sharing and Transfer

We do not share, transfer, or disclose any Google user data (whether raw, derived, or anonymized) to any third parties, data brokers, or advertising platforms under any circumstances. Data is only used to provide the app's core features.

AI Models

Data obtained from Google APIs is not used to train an independent AI or machine learning model in any way not permitted by Google's applicable API user data policies.

Where Google data is used in Growtyx's AI features, that use is limited in a manner compliant with the Google API Services User Data Policy and applicable Limited Use requirements. Google's policies limit the use of data obtained to the appropriate features provided to the relevant user, and prohibit data transfer except in certain specified exceptions.

Authorization and Deletion

If the Google integration is removed, Growtyx's access to the relevant Google account is terminated.

We retain Google user data only for as long as your account is active to provide the requested services. When you disconnect your Google integration or delete your Growtyx account, all associated Google user data is permanently and irrevocably deleted from our servers within 30 days.

Data held in technical backups may be retained for a longer period as part of the applicable backup and retention cycles.

Limited Use

The use and transfer of raw or derived user data that Growtyx receives from Google APIs is subject to policies applicable to Growtyx as set by Google, including the Google API Services User Data Policy.

Limited Use Statement:
Growtyx's use and transfer to any other app of information received from Google APIs (Workspace or other APIs) will adhere to the Google User Data Policy, including the Limited Use requirements.

12. Cookies and Tracking Technologies

Growtyx may use cookies and similar technologies to ensure the website and Platform function securely and correctly.

Essential Cookies

Cookies necessary for session management, authentication, security, and the core functioning of the Platform may be used.

To the extent these cookies are necessary for the Service to function, they may not be capable of being disabled by the user.

Analytics and Performance Cookies

Growtyx may use analytics technologies to understand how the website and Platform are used, measure performance, and improve the user experience.

Where the use of analytics cookies requires explicit consent under applicable law, the necessary consent mechanisms are implemented.

Users can also control or block cookies through their browser settings. However, disabling certain cookies may cause certain features of the Platform to stop working.

13. Authorized Access

Access to personal data within Growtyx, or at third-party service providers acting on Growtyx's behalf, is limited to what is necessary to provide or secure the Service, and is granted in line with authorization principles.

For data requiring special protection, such as Google API user data, the relevant service provider's and platform's own data usage policies are additionally complied with.

14. Legal Authorities and Mandatory Disclosures

Personal data may be shared with the relevant authority or parties, only to the extent necessary, where a legally valid reason exists, such as:

  • a request from a legally authorized public institution or organization,
  • a court or administrative authority decision,
  • fulfilling a legal obligation,
  • the establishment, exercise or protection of a right,
  • preventing security incidents, fraud or misuse.

15. User Rights – KVKK Article 11

Under Article 11 of Turkey's Law No. 6698 on the Protection of Personal Data, to the extent applicable, you have the right to:

  • learn whether your personal data is being processed,
  • request information about it if it has been processed,
  • learn the purpose of processing and whether it is used in accordance with that purpose,
  • know the third parties to whom your personal data is transferred, domestically or abroad,
  • request correction of incomplete or inaccurate data,
  • request the deletion or destruction of personal data where the legal conditions are met,
  • request that correction, deletion or destruction be notified to third parties to whom the data has been transferred,
  • object to a result that is to your detriment arising solely from analysis performed by automated systems,
  • request compensation for damages, in accordance with legal requirements.

You may submit your requests under KVKK through the contact channel below:

Email: hello@growtyx.com
Data Controller: [Full Name]
Address: [Notice / contact address]

Requests are evaluated within the procedure and timeframes set out in KVKK and its related secondary legislation.

16. Changes to This Policy

Growtyx may update this Privacy and Cookie Policy due to changes in its services, data processing activities, the technologies used, or applicable law.

If changes are made that materially affect the purposes of processing personal data or the rights and obligations of users, additional notice may be given via the Platform or by email, where appropriate.

The current version of the Policy is published on the Growtyx website or Platform.

17. Contact

If you have questions about this Policy, your personal data, or your rights under KVKK, you can contact us through the following channel:

Growtyx
Email: hello@growtyx.com
Data Controller: [Full Name]
Address: [Address]