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Privacy Policy

Privacy Policy for Ayhan Sipahi Software Consultancy services - How we collect, use, and protect your data

Privacy Policy

Last updated: August 4, 2026

1. Introduction#

I, Ayhan Sipahi, am committed to protecting your privacy and personal data. This Privacy Policy explains how I collect, use, store, and protect your information when you use my software consultancy services.

2. Information We Collect#

Personal Information#

  • Account Information: Name, email address, company name, job title
  • Contact Information: Phone number, mailing address (when provided)
  • Billing Information: Payment details, billing address, tax information
  • Profile Information: Professional background, preferences, settings

Technical Information#

  • Usage Data: How you interact with our services, features used, time spent
  • Device Information: IP address, browser type, operating system, device identifiers
  • Log Data: Server logs, error reports, performance metrics
  • Cookies: Language and theme preferences only (no tracking cookies)

Content and Communications#

  • User Content: Files, code, documents you upload or create using our services
  • Communications: Messages, support tickets, feedback, consultation notes
  • Analytics Data: Aggregated, anonymized page metrics from Cloudflare Web Analytics (no individual behavior profiles)

3. How We Use Your Information#

We use your information for the following purposes:

Service Provision#

  • Providing and maintaining our SaaS platforms
  • Delivering software consultancy services
  • Processing payments and managing subscriptions
  • Providing customer support

Communication#

  • Sending service-related notifications
  • Responding to inquiries and support requests
  • Sharing important updates and security alerts
  • Marketing communications (with your consent)

Improvement and Analytics#

  • Analyzing usage patterns to improve our services
  • Developing new features and functionality
  • Monitoring system performance and security
  • Conducting research and analytics
  • Complying with legal obligations
  • Protecting against fraud and abuse
  • Enforcing our terms of service
  • Maintaining system security

We process your personal data based on:

  • Contract Performance: Fulfilling our service agreements with you
  • Legitimate Interest: Improving services, security, and business operations
  • Consent: Marketing communications and optional features
  • Legal Obligation: Compliance with applicable laws and regulations

5. Data Sharing and Disclosure#

We do not sell your personal information. We may share your data in these situations:

Service Providers#

  • Cloud hosting providers (Cloudflare, AWS)
  • Payment processors (Stripe, PayPal)
  • Analytics: Cloudflare Web Analytics (cookieless, anonymized, aggregated)
  • Customer support tools
  • Email and communication services
  • To comply with court orders or legal processes
  • To protect our rights and property
  • To prevent fraud or illegal activities
  • To protect user safety and security

Business Transfers#

In case of merger, acquisition, or sale of assets, your information may be transferred to the new entity with equivalent privacy protections.

6. Data Security#

We implement comprehensive security measures:

Technical Safeguards#

  • End-to-end encryption for sensitive data
  • Regular security audits and penetration testing
  • Multi-factor authentication requirements
  • Secure data transmission (TLS/SSL)
  • Regular software updates and patches

Administrative Safeguards#

  • Employee training on data protection
  • Access controls and principle of least privilege
  • Regular review of data processing activities
  • Incident response procedures
  • Data backup and recovery systems

Physical Safeguards#

  • Secure data centers with controlled access
  • Environmental protection systems
  • Surveillance and monitoring systems

7. Data Retention#

We retain your information for as long as necessary to:

  • Provide our services to you
  • Comply with legal obligations
  • Resolve disputes and enforce agreements
  • Maintain business records

Specific Retention Periods:

  • Account data: Retained while account is active, plus 3 years after closure
  • Billing information: 7 years for tax and accounting purposes
  • Usage logs: 2 years for security and analytics
  • Support communications: 5 years for quality assurance

8. Your Rights#

Depending on your location, you may have the following rights:

Access and Portability#

  • Request a copy of your personal data
  • Receive your data in a portable format
  • Access information about how we process your data

Correction and Updates#

  • Correct inaccurate personal information
  • Update your profile and preferences
  • Modify communication settings

Deletion and Restriction#

  • Request deletion of your personal data
  • Restrict processing of your information
  • Object to processing based on legitimate interests
  • Withdraw consent for marketing communications
  • Clear preference cookies via browser settings (we set no non-essential cookies)
  • Modify privacy preferences

To exercise your rights, contact us at privacy@sph.sh

9. International Data Transfers#

As a German company, we primarily operate within the EU/EEA. When we transfer data outside the EU/EEA:

  • We ensure adequate protection through standard contractual clauses
  • We comply with GDPR requirements for international transfers
  • We implement appropriate safeguards for cross-border transfers
  • We use adequacy decisions where available

10. Cookies and Tracking#

Essential Cookies#

  • Language preference (locale) and theme preference (theme-preference) on this website
  • Authentication and session management where our SaaS platforms require sign-in

Analytics (Cookieless)#

  • We use Cloudflare Web Analytics, which sets no cookies and uses no localStorage
  • No fingerprinting, no cross-site tracking, no individual profiles
  • Only aggregated metrics: page views, referrers, country, browser family, Core Web Vitals

Marketing Cookies#

  • We do not use marketing or advertising cookies

You can control cookies through your browser settings.

11. Children’s Privacy#

Our services are not intended for children under 16. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately.

12. Third-Party Services#

Our services may integrate with third-party platforms. This policy does not cover third-party privacy practices. Please review their privacy policies separately.

13. Changes to This Policy#

We may update this Privacy Policy to reflect:

  • Changes in our services or business practices
  • Legal or regulatory requirements
  • Industry standards and best practices

We will notify you of material changes through:

  • Email notifications
  • In-app notifications
  • Website announcements

14. Contact Information#

Data Protection Officer: privacy@sph.sh General Inquiries: legal@sph.sh Address: Berlin, Germany

For GDPR-related inquiries: gdpr@sph.sh

15. Regulatory Information#

Germany (GDPR/BDSG Compliance): As a German company based in Berlin, we fully comply with the General Data Protection Regulation (GDPR) and the German Federal Data Protection Act (Bundesdatenschutzgesetz - BDSG).

European Union (GDPR Compliance): We comply with the General Data Protection Regulation (GDPR). EU residents have specific rights under this regulation.