Privacy Policy

1. Introduction & Data Controller

Aviation Asset Network Havacılık Mühendislik Yazılım Limited Şirketi (“Aviation Asset Network”, “we”, “us” or “the Company”) provides aviation-sector services including MRO and CAMO support, aircraft parts trading, and aviation software, with operations and business relationships across multiple jurisdictions including Türkiye, Romania, Latvia, Malta and Uzbekistan. We act as the data controller (and, in KVKK terms, the veri sorumlusu) for the personal data described in this policy.

2. Personal Data We Collect

We collect the following categories of personal data, depending on how you interact with us:

2.1 Data you provide directly (web form & e-mail)

• Identity and contact details: first name, last name, business e-mail address, telephone number.
• Company / role information: organisation name, position, and your stated business need.
• Message content: aircraft type, part number, quantity, delivery timeline, and any other details you include in enquiries or correspondence.

2.2 Data collected via LinkedIn

• Contact and professional profile information you submit through LinkedIn Lead Generation Forms (e.g. name, business e-mail, company, job title).
• Engagement and campaign interaction data associated with our LinkedIn advertising.

2.3 Data collected automatically (cookies & tracking)

• Technical data: IP address, device and browser type, operating system, referring URL.
• Usage data: pages viewed, time on page, and interactions, collected via cookies and similar technologies, including the LinkedIn Insight Tag (see sections 4 and 5).

2.4 Data arising from a business relationship

• Contact details of representatives of customers, suppliers and partners.
• Commercial and technical correspondence exchanged in the course of supply, MRO/CAMO and software services (see section 11).

3. Purposes & Legal Bases for Processing

We process personal data only where we have a valid legal basis. Under GDPR these are primarily contract performance (Art. 6(1)(b)), legitimate interests (Art. 6(1)(f)) and consent (Art. 6(1)(a)). Under KVKK the corresponding bases in Articles 5 and 6 apply (e.g. necessity for a contract, legitimate interest, legal obligation, and explicit consent).

4. Cookies & Tracking Technologies

Our website uses cookies and similar technologies. Strictly necessary cookies are required for the site to function. Analytics and marketing cookies — including the LinkedIn Insight Tag — are only set after you give consent through our cookie banner, where required.

You can accept, reject or change your preferences at any time via the cookie banner / cookie settings, and you can also control cookies through your browser settings.

Implementation note (for the site owner): a cookie consent banner must be added before non-essential tracking (analytics, LinkedIn Insight Tag) is activated, and the “cookie settings” control should link to it.

5. LinkedIn & Advertising

We use LinkedIn for marketing and lead generation. This involves:

• LinkedIn Lead Generation Forms: when you submit a LinkedIn lead form, LinkedIn shares the contact and professional profile information you provided with us so we can follow up about our services.
• LinkedIn Insight Tag / tracking pixel: we use the LinkedIn Insight Tag on our website to measure campaign performance, build audiences and deliver relevant advertising. This may set cookies and collect technical and usage data described in section 2.3.

LinkedIn acts as an independent controller for some of this processing. For details, see the LinkedIn Privacy Policy.

Opt-out: you can opt out of LinkedIn-based advertising in your LinkedIn ad settings, reject marketing cookies via our cookie banner, and unsubscribe from our marketing communications at any time using the link in our messages or by contacting us at info@aviationasset.net.

6. Sharing with Third Parties

We may share personal data with the following categories of recipients, under appropriate safeguards:

• Hosting and IT providers that operate our website and infrastructure.
• Analytics and advertising providers, including LinkedIn, as described in sections 4 and 5.
• Group companies and business partners across our jurisdictions where necessary to deliver services.
• Suppliers, MRO/CAMO partners and logistics providers involved in fulfilling a transaction.
• Professional advisers and authorities where required by law or to protect our rights.

We do not sell your personal data.

7. International Data Transfers

Because we operate across multiple jurisdictions (including Türkiye, Romania, Latvia, Malta and Uzbekistan) and use service providers such as LinkedIn, your personal data may be transferred to and processed in countries outside your own, including outside the European Economic Area and outside Türkiye.

Where we transfer data internationally, we rely on appropriate safeguards, such as European Commission adequacy decisions, Standard Contractual Clauses (GDPR), and, for transfers from Türkiye, the conditions set out in Article 9 of the KVKK (including explicit consent or other legal grounds and written undertakings where required).

8. Data Retention

We keep personal data only for as long as necessary for the purposes described in this policy, or as required by applicable law (including tax, commercial and aviation-regulatory retention periods). As general guidance:

• Enquiry / contact-form data: 24 months after the last contact, unless a business relationship begins.
• Customer / supplier records: for the duration of the relationship plus the statutory retention period of 10 years (under the Turkish Commercial Code).
• Marketing data: until you withdraw consent or object, and then deleted or anonymised.
• Cookie / analytics data: for the retention period of each cookie; session cookies are deleted at the end of each browser session where applicable.

When data is no longer needed, it is deleted, destroyed or anonymised in line with our retention and destruction policy.

9. Your Rights

9.1 Rights under KVKK (Article 11)

As a data subject, you have the right to:

• learn whether your personal data is processed;
• request information if your data has been processed;
• learn the purpose of processing and whether data is used accordingly;
• know the third parties to whom data is transferred, in Türkiye or abroad;
• request correction of incomplete or inaccurate data;
• request deletion or destruction of your data within the conditions of the KVKK;
• request notification of correction/deletion to third parties to whom data was transferred;
• object to outcomes resulting from automated analysis of your data;
• claim compensation for damage arising from unlawful processing.

9.2 Rights under GDPR

• access, rectification and erasure;
• restriction of processing and objection to processing;
• data portability;
• withdrawal of consent at any time (without affecting prior lawful processing);
• the right to lodge a complaint with a supervisory authority.

To exercise your rights, contact us using the details in section 12. We respond within the timeframes required by the applicable law (30 days under KVKK; without undue delay and within one month under GDPR).

10. Security Measures

We take appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure. These include access controls, encryption in transit (HTTPS), network and application security controls, staff confidentiality obligations, and supplier due diligence. No method of transmission or storage is completely secure, but we continually review and improve our safeguards.

11. Aviation-Sector Notes

As a B2B aviation business, our processing often takes place in the context of a business relationship rather than consumer interactions. In particular:

• We exchange technical and commercial documentation (e.g. part specifications, certificates, traceability and back-to-birth records, quotations and contracts) that may contain the contact details of individuals representing customers, suppliers and partners.
• We process supply-chain data necessary for sourcing, repair coordination, consignment and logistics across our partner network.
• Such processing is generally based on contract performance and/or legitimate interest, and is subject to the same safeguards described in this policy.

12. Contact & Complaints

For any privacy question, or to exercise your rights, please contact us:

You also have the right to complain to a supervisory authority:

• Türkiye: Personal Data Protection Authority (KVKK Kurumu) — kvkk.gov.tr.
• EU/EEA: the data protection authority of your country of residence, place of work or the place of the alleged infringement.

13. Updates to This Policy

We may update this Privacy Policy from time to time. The current version and its date are shown at the top of this page. Material changes will be communicated through appropriate channels.

Last updated: 30 June 2026  |  Version: 1.0

This document is a legal template and must be reviewed and approved by a qualified lawyer before publication. All highlighted placeholders must be completed with accurate company information.