Privacy Notice
How personal data of selsil.com visitors and form users is processed, on which legal bases, for how long, and your rights under the GDPR.
Last updated: · Version 2
This Privacy Notice explains how personal data of visitors to selsil.com and of people who use the forms on this website is processed, in accordance with Articles 13 and 14 of the EU General Data Protection Regulation (GDPR) and the applicable rules on cookies (Article 5(3) of Directive 2002/58/EC and its national implementations).
1. Controller
The controller is Sel Dış Ticaret ve Kimya Sanayi A.Ş. ("Selsil", "we"), a company established in Türkiye.
- Address: Maslak Mahallesi Sanatkarlar Sokak (Eclipse) No:2E İç Kapı No:6, 34475 Sarıyer / İstanbul, Türkiye
- Trade registry (MERSİS) number: 0759002248300011
- Privacy contact: kvkk@selsil.com.tr
- Phone: +90 212 438 75 38
We are established in Türkiye. Personal data you provide on this website is collected directly by us and processed in Türkiye and by the service providers listed in section 5.
2. Which personal data we process
Depending on how you use the website, we may process:
- Technical and security data: IP address, browser and device information (user agent), requested address, time of request, server logs.
- Measurement and marketing data: pages you visit and products you view, clicks on phone links, the click identifier of the ad that brought you to us (Google gclid, Meta fbclid, ChatGPT Ads oppref, TikTok ttclid), cookie and pixel identifiers, a random identifier specific to your page session, and hashed versions of these identifiers.
- Consent records: your cookie choices, the date of your choice, the policy version, the site language and a randomly generated anonymous consent ID. Your IP address is not stored in the consent record.
- Identification and contact data: first name, last name, e-mail address and phone number you enter in the contact, job application or newsletter forms.
- Request and application data: your message; education, experience and similar information in a job application.
We do not intend to collect special categories of personal data. Please do not include such data in form messages.
3. Purposes and legal bases
3.1. Providing and securing the website
We process technical and security data to deliver the website, protect it against attacks and fix errors. Legal basis: our legitimate interest in operating a secure website (Art. 6(1)(f) GDPR) and compliance with legal obligations (Art. 6(1)(c) GDPR).
3.2. Strictly necessary cookies
We use strictly necessary cookies to deliver the website securely and to remember your cookie choice. They are exempt from consent under Art. 5(3) of the ePrivacy Directive. Legal basis for the related processing: our legitimate interest (Art. 6(1)(f) GDPR).
3.3. Analytics cookies (Google Analytics 4)
With your consent only, we use analytics cookies to understand statistically how pages are used and to improve the website. Legal basis: consent (Art. 6(1)(a) GDPR). If you do not consent, Google receives limited signals without any cookie being set on your device and without an identifier that identifies you (page address, time, browser type, consent status) for aggregate measurement and modelling (Google Consent Mode). Legal basis for these signals: our legitimate interest in measuring the reach of our website (Art. 6(1)(f) GDPR).
3.4. Marketing and advertising cookies and pixels
With your consent only, cookies and pixels (Meta Pixel, ChatGPT Ads Measurement Pixel, TikTok Pixel, Google tag) run in your browser to measure the results of our Google Ads, Meta (Facebook and Instagram), ChatGPT Ads and TikTok campaigns, to recognise visitors who come from an ad and to show relevant ads. Legal basis: consent (Art. 6(1)(a) GDPR). Without consent these cookies are not set, the pixels are not loaded and no server event is sent to TikTok Events API.
3.5. Server-side advertising measurement
To measure the results of our advertising spend, certain interactions on our website are sent directly from our server to Meta Platforms (Conversions API) and to OpenAI (ChatGPT Ads Conversions API). This transmission does not use cookies and takes place independently of your cookie choice, which is why it is described separately here.
- Events sent: page view, product view, click on a phone link and form submission.
- Data sent with each event: event type and time, page address, product code and name, IP address, browser information (user agent), a hashed (SHA-256) version of a random identifier specific to your page session and, if present, the ad click identifier contained in the page address (fbclid or oppref).
- Additionally, for form submissions: e-mail address, phone number, first name and last name are sent only in irreversibly hashed form (SHA-256). The plain values never leave our server.
- If you have not consented to marketing cookies, no cookie is read from your device and events sent to OpenAI carry OpenAI's "opt_out" flag, which excludes them from personalisation. If you have consented, the identifiers in the advertising cookies (_fbp, _fbc, __oppref, __obref) and the anonymous ID of your consent record are added.
- Purpose: measuring advertising conversions and reporting which results our ads produce.
- Legal basis: our legitimate interest in measuring the effectiveness of our advertising (Art. 6(1)(f) GDPR). Hashing, not reading device data without consent and the personalisation opt-out flag are the safeguards we apply in balancing this interest against your rights.
- Right to object: you can object to this processing at any time on grounds relating to your particular situation (Art. 21 GDPR) by writing to kvkk@selsil.com.tr. The advertising settings in your Meta and OpenAI accounts are also available to you.
3.6. Contact, job application and newsletter forms
- Contact form: answering your enquiry and sending offers or product information you request. Legal basis: steps taken at your request prior to entering into a contract (Art. 6(1)(b) GDPR) and our legitimate interest in responding to enquiries (Art. 6(1)(f) GDPR).
- Job application form: assessing your application and contacting you. Legal basis: steps prior to entering into an employment contract (Art. 6(1)(b) GDPR).
- Newsletter: sent only with your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time via the unsubscribe link in each e-mail.
- Measurement of form submissions as advertising conversions is described in section 3.5.
- We may use a security check on forms to prevent spam and abuse. Legal basis: our legitimate interest (Art. 6(1)(f) GDPR).
Providing data in the forms is neither a statutory nor a contractual requirement, but without the required fields we cannot answer your request.
4. Automated decision-making
We do not use automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you (Art. 22 GDPR).
5. Recipients
We share personal data only to the extent necessary for the purposes above:
- Hosting and infrastructure providers acting as processors: Google Cloud / Firebase (website hosting, storage of form submissions) and our e-mail service provider (delivery of form notifications).
- Analytics and advertising providers: Google LLC / Google Ireland Limited (Google Analytics, Google Ads), Meta Platforms, Inc. / Meta Platforms Ireland Limited (Meta Pixel, Conversions API) and OpenAI OpCo, LLC (ChatGPT Ads Measurement Pixel, Conversions API) and TikTok Technology Limited / TikTok Information Technologies UK Limited (TikTok Pixel, Events API; only with marketing consent). For the collection and transmission of data via the Meta Pixel and the Conversions API, we and Meta Platforms Ireland Limited are joint controllers; Meta is responsible for the subsequent processing. These providers process data under their own terms and privacy policies.
- Competent public authorities and courts, where required by law.
International transfers: the providers above process data in the United States, among other countries. Where the recipient is certified under the EU-U.S. Data Privacy Framework, transfers are based on the European Commission's adequacy decision of 10 July 2023; otherwise they are based on the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR). Data you provide to us is processed in Türkiye, where we are established.
6. Retention periods
- Cookies: for the duration stated for each cookie in the Cookie Policy.
- Your cookie choice: 12 months, after which you are asked again.
- Consent records: 3 years from your decision, to demonstrate consent.
- Contact form submissions: 24 months.
- Job applications: 12 months from the application; if you are hired, in line with employment record rules.
- Newsletter consent: until withdrawn; the record of withdrawal is kept as required by law.
- Measurement events that could not be delivered: at most 7 days (for re-sending), then deleted.
- Server and security logs: for the periods required by law.
- Data transmitted to analytics and advertising providers: according to the retention policy of each provider.
7. Your rights
Under the GDPR you have the right to access your personal data (Art. 15), to rectification (Art. 16), to erasure (Art. 17), to restriction of processing (Art. 18), to data portability (Art. 20) and to object to processing based on legitimate interests (Art. 21). Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing before withdrawal; for cookies, use the "Cookie Settings" link at the bottom of every page.
To exercise your rights, write to kvkk@selsil.com.tr. We will answer within one month (Art. 12(3) GDPR). You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or the place of the alleged infringement (Art. 77 GDPR).
8. Related documents and changes
For the full list of cookies see the Cookie Policy; for the scope of your cookie consent see the Consent Statement. We update this notice when our processing or the law changes; the current version and its date are published on this page. If cookie-related processing changes significantly, you will be asked for your choice again.
