1. Who we are
Turchina Group is a bilingual advisory firm based in undefined, undefined. For data-protection purposes, we are the data controller of the personal data described below. You can reach us at contact@turchinagroup.com for any privacy-related question.
2. What data we collect
We collect three categories of personal data. First, data you provide directly: your name, email, phone number, country, company, and the content of any message you send us through the contact form, WhatsApp, WeChat, or email. Second, data we collect through engagement: when you become a client, we collect the information needed for our services (for example, passport copies, proof of address, source-of-funds documentation, family details for citizenship applications). Third, technical data: IP address, browser type, language, device, pages visited, and approximate location, collected through cookies and analytics tools.
3. Why we use your data
We use your data to respond to your enquiry, deliver the services you have engaged us for, comply with our legal obligations (including anti-money-laundering checks under Turkish MASAK rules), prevent fraud, and improve our website. We do not use your data for advertising and we do not sell your data to third parties.
4. Legal basis
We process your data on one of the following legal bases: your consent (for marketing and analytics cookies); performance of a contract with you (for engagement work); compliance with a legal obligation (for AML and tax reporting); or our legitimate interest in running and improving our business (for website analytics).
5. Who we share data with
We share data only with parties strictly necessary to deliver our services. These include: our network of independent Turkish lawyers, accountants, valuers, and bankers when working on your engagement; Turkish government authorities when required by law (for example, the Migration Directorate for residence permits); third-party service providers (hosting, email, analytics) under contract; and our auditors and regulators. We never share data with developers, brokers, or any party that would create a commission conflict.
6. International transfers
Because we serve Chinese clients with Turkish needs, your data may be transferred between Turkey and China and (where the service requires) to the European Union or other jurisdictions. Such transfers are protected by contract and limited to what is necessary for the engagement. Where we transfer data outside the data subject's home jurisdiction, we apply the relevant safeguards required under KVKK, GDPR, or PIPL.
7. Cookies
Our website uses essential cookies (required for the site to work), preference cookies (to remember your language selection), and analytics cookies (Google Analytics 4, configured with IP anonymisation and without advertising features). You can refuse non-essential cookies via your browser settings. Refusing analytics cookies has no impact on the services we provide.
8. How long we keep your data
Engagement data: kept for the duration of the engagement plus 10 years for compliance and tax-record purposes. Anti-money-laundering records: kept for the period required by Turkish law (currently a minimum of 8 years). Marketing-only enquiries: kept for 2 years from the last contact unless you ask us to delete earlier. Website analytics: kept in aggregated form for up to 26 months.
9. Your rights
Depending on the legal regime that applies to you, you have the right to: access the data we hold about you; correct inaccurate data; request deletion (subject to our legal retention obligations); restrict processing; object to processing based on our legitimate interest; data portability; and withdraw consent for cookies and marketing at any time. To exercise any of these rights, write to us at the email below. We respond within 30 days.
10. Security
We protect personal data through technical and organisational measures including access control, encryption in transit (HTTPS), encryption at rest where appropriate, regular review of access permissions, and confidentiality undertakings with all staff and external partners. No system is completely secure; if a personal-data breach occurs that is likely to affect your rights, we will notify you and the relevant authority within the timeframes required by law.
11. Changes to this policy
We may update this Privacy Policy from time to time to reflect changes in our practice or in applicable law. Material changes will be highlighted on this page; the updated date will be revised accordingly.
12. Contact us
For any privacy-related question, request, or complaint, please contact us at contact@turchinagroup.com. You also have the right to lodge a complaint with the Turkish Personal Data Protection Authority (KVKK) or your local data-protection authority.
This policy applies alongside any engagement letter you sign with us. If there is any conflict, the signed engagement letter prevails.