Privacy Policy
Last updated: 5 September 2026
This notice explains what we collect, why, and what you can do about it. It covers the Turkish Personal Data Protection Law (KVKK No. 6698) and, for visitors in the EU, the GDPR.
1. Data controller
| Seller | Mehmet Deniz Duymaz |
|---|---|
| Trading as | Smurf Digital |
| Address | Viranşehir Mah. 34324 Sk. Gültuğ A Blok No: 22/A İç Kapı No: 13, Mezitli / Mersin, Türkiye |
| Tax office | İstiklal |
| Tax number | 3210408922 |
| Phone | +90 532 499 71 95 |
| [email protected] | |
| Website | https://smurfdigital.com |
2. What we collect
- Your e-mail address — to send your keys, download links and receipts. This is the only personal detail we need to complete a sale.
- Order records — what you bought, when, how much, and the delivery message.
- Billing details — only if you enter them for an invoice.
- Technical data — IP address and browser type, kept briefly in server logs to block abuse and to rate-limit key guessing.
3. What we do not collect
- Card details never reach us. They are entered on the payment provider's own page. We receive only a success or failure result.
- We do not record which files a download key was used on. The system stores the remaining credit count and the date of last use, nothing more.
- No advertising trackers, no profiling, no data sold to anyone.
4. Why we may process it (legal basis)
- Performance of a contract — delivering what you bought and supporting it.
- Legal obligation — keeping commercial and tax records for the statutory period.
- Legitimate interest — preventing fraud and abuse of the service.
5. Who else sees it
- Our payment provider, to take the payment.
- Our e-mail provider, to deliver your keys.
- Our hosting and network provider, to run the site.
Each receives only what it needs for that task. We do not share your data with anyone else.
6. How long we keep it
- Order and invoice records: 10 years, as required by Turkish tax and commercial law.
- Server logs: 90 days.
- Support messages: 2 years.
7. Your rights
Under KVKK Art. 11 and the GDPR you may ask us to tell you what we hold, correct it, delete it, or restrict how we use it, and you may object to processing. Write to [email protected] and we answer within 30 days.
Deleting your order record does not undo a purchase, and we must keep invoice data for the statutory period even if you ask for deletion.
8. Security
The site runs over HTTPS. Files sold through the archive are stored outside the public web root and are reachable only through a link issued to your own order. Keys are rate-limited against guessing.
9. Complaints
If you are not satisfied with our answer, you may complain to the Turkish Personal Data Protection Authority (KVKK) or, in the EU, to your national supervisory authority.
10. Contact
Terms of Service · Refund and Cancellation Policy · Privacy Policy · Cookie Policy · Delivery Policy · Distance Sales Agreement · Preliminary Information Form