Last updated: 13 June 2025
1. Who We Are
This website is operated by GROWMIRE TEKNOLOJİ ANONİM ŞİRKETİ ("GROWMIRE", "we," "us," or "our"), a company registered in Türkiye. All privacy-related inquiries may be directed to info@growmire.com.
2. Scope
This Privacy Policy applies to personal data processed through growmire.com and any sub-domains that link to this notice. It does not cover offline processing or third-party sites to which we may link.
3. Key Definitions
- "Personal data" means any information that identifies or can reasonably identify an individual.
- "Processing" means any operation performed on personal data, such as collection, storage, use, disclosure, or deletion.
- "Controller" means the entity that determines the purposes and means of processing personal data.
4. Personal Data We Collect
| Category | Specific Elements | Method of Collection |
|---|---|---|
| Usage & Security | IP address, browser type & version, operating system, device identifiers, referring URLs, pages viewed, access timestamps | Automatic via server logs & first-party cookies |
| reCAPTCHA Interaction | IP address, user-agent, mouse movements, keystrokes, click events | Automatic via embedded Google reCAPTCHA script |
| Contact Form | Full Name, Company Name, Email, Phone, Subject, Message content | Directly from you via form submission |
5. Purposes & Legal Bases
We process personal data only when we have a valid legal basis under the EU GDPR:
| Purpose | Description | Legal Basis |
|---|---|---|
| Site Security | Detect, prevent, and respond to malicious activity or fraud. | Legitimate interest (Art. 6 §1 (f)) |
| Performance Analytics | Understand website traffic patterns to enhance user experience. | Consent for non-essential cookies; otherwise legitimate interest |
| Client Enquiries | Respond to questions or service requests sent via the contact form. | Contractual necessity (Art. 6 §1 (b)) or legitimate interest |
| Compliance | Meet legal obligations, e.g., accounting, tax, regulatory audits. | Legal obligation (Art. 6 §1 (c)) |
6. Cookies, Analytics & reCAPTCHA
We rely on first-party and third-party cookies as explained in our Cookie Policy. Key points:
- Google Analytics (GA 4) – Collects aggregated usage statistics; IP addresses are truncated inside the EU.
- Google reCAPTCHA (v3) – Protects our forms from spam by analyzing interaction patterns.
- All non-essential cookies are set only after you give explicit consent via our cookie banner.
7. Data Sharing & International Transfers
- No personal data are sold or rented.
- Third-party processors: Google LLC (Analytics & reCAPTCHA). Transfers to the United States are covered byStandard Contractual Clauses.
- Professional advisers (lawyers, auditors) may access data under NDA when strictly required.
- Law enforcement agencies may receive data if we are legally compelled (see Section 12).
8. Security Measures
- Data in transit: TLS 1.2+ encryption
- Data at rest: AES-256 server-side encryption
- Logical access controls and role-based permissions
- Quarterly vulnerability scans & annual penetration testing
- ISO 27001-aligned internal policies and staff training
9. Retention & Deletion
- IP logs: 26 months (Google Analytics default)
- reCAPTCHA logs: 6 months
- Contact-form data: 24 months after final interaction or longer if a contractual relationship forms
- We periodically review data to ensure minimal retention. Data slated for deletion are securely erased or irreversibly anonymised.
10. Children’s Privacy
Our services are not directed to children under 16. We do not knowingly process children’s personal data. Parents who believe their child has provided us data may contact us for prompt deletion.
11. Your Rights
Under the GDPR you can:
- Request access to your personal data
- Request correction or deletion
- Object to or restrict processing
- Request data portability
- Withdraw consent at any time, without affecting prior lawful processing
To exercise any right, email info@growmire.com. We will respond within one month.
12. Law Enforcement & Legal Requests
We may disclose personal data when required to comply with subpoenas, court orders, or other legal obligations, provided such disclosure is limited to what is legally necessary.
13. Changes to This Policy
Material updates will be announced via a banner or pop-up on our website and reflected in the "Last updated" date above.
14. Contact
Email info@growmire.com for any privacy-related question.