This notice explains, under article 10 of Turkish Personal Data Protection Law No. 6698 (“KVKK”), how your personal data is processed on adonis.net.tr and in the Adonis Telecom services.
1. Data controller
ADONİS NETWORK YAZILIM SANAYİ VE TİCARET ANONİM ŞİRKETİ, head office: Taya Hatun Mah. Tığcılar Sk. Tığcılar Hanı No:9 İç Kapı No:3, 34120 Fatih/İstanbul, branch: Asmalı Mescit, İstiklal Cd. No:108 D:3, 34430 Beyoğlu/İstanbul, Türkiye, MERSİS 0008174271800001, email support@adonis.net.tr, KEP adonisnetworkyazilim@hs01.kep.tr. Adonis Telecom is a business division of this company.
2. Data we process
- Identity: name.
- Contact: email address; a WhatsApp number if you choose to give one.
- Customer transactions: orders, plans bought, e-SIM records (ICCID), data usage and validity information, support requests and correspondence, preferred language and currency.
- Transaction security: session data, IP address, sign-in code requests and sign-in records.
- Finance: payment reference, amount and status. We never see or store your card details; payment is processed by Garanti BBVA.
- Invoice details (only if you ask for an invoice in your or your company’s name): Turkish ID or tax number, tax office, company name, address.
- Linked sign-in: if you choose to sign in with Google, Facebook, LinkedIn or Adonis Workspace, the user ID and email address that provider sends us.
We do not process special categories of data (health, biometrics, etc.). We do not take location data from your device; what we know about where an e-SIM is used is limited to the usage information our infrastructure provider sends us.
3. Purposes and legal grounds
- Taking your order and payment, creating and delivering the e-SIM, sending usage and expiry notices (data running low, plan ending), and providing support — performance of a contract (KVKK art. 5(2)(c)).
- Invoicing, accounting, tax, consumer law and ETBİS obligations, and responding to competent authorities — legal obligation (art. 5(2)(ç)).
- Account security, fraud prevention, improving the service and asking how your plan is working — legitimate interest (art. 5(2)(f)).
- Establishing, exercising or defending legal claims (art. 5(2)(e)).
4. Commercial electronic messages
We do not send you promotional or marketing messages unless you separately give your explicit consent. Order, delivery, usage and expiry notices are informational messages needed to provide the service. If you consent, your consent is recorded in the Message Management System (İYS) and you can withdraw it at any time, free of charge, through the link in each message or at support@adonis.net.tr.
5. Who we share data with
Only for the purposes above and only as far as necessary:
- e-SIM infrastructure provider — to create the e-SIM and receive usage data; name, email, optional WhatsApp number and order details.
- Payment institution (Adonis Pay infrastructure and Garanti BBVA) — to take payments and make refunds.
- e-Invoice / e-Archive integrator (DSM E-Dönüşüm ve Bilişim Hizmetleri A.Ş. — Trendyol e-Faturam) and the Revenue Administration (GİB) — to issue and report the e-Arşiv or e-Fatura invoice that Turkish law requires for every sale; your name, email, order amount and (if you asked for them) your invoice details.
- Hosting and email infrastructure (IONOS) — to run the website and deliver email.
- Sign-in providers (Google, Meta, LinkedIn) — only if you choose to sign in that way, to verify your identity.
- Adonis shared account system — your user code and email, so you are recognised with one account across Adonis platforms.
- Legal and financial advisers, auditors — for legal obligations and defending claims.
- Competent public authorities — on request and as far as the law permits.
6. Transfers abroad
Because an e-SIM works through local operators in the country you visit, and our infrastructure provider and some service providers are located abroad, some of your data is transferred outside Türkiye. These transfers are made under KVKK art. 9: to countries with an adequacy decision or, where there is none, with appropriate safeguards such as the standard contracts published by the Board (notified to the Board within five business days of signature).
The website’s fonts are loaded from Google Fonts; your IP address is sent to Google when they load.
If you accept the cookie notice, data about how you use the site (pages visited, device and browser, approximate location) is transferred to Google through Google Analytics, including outside Türkiye (e.g. the US). This transfer rests on your explicit consent, which you can withdraw at any time with the “Cookie settings” link at the bottom of the site. See the Cookie Policy for details.
7. How data is collected
Electronically, by automated or partly automated means: through the website, the order and sign-in forms, your account page, support requests and email, and through system notifications from our infrastructure and payment providers. See the Cookie Policy for cookies.
8. How long we keep data
- Order, invoice and payment records: 10 years (Turkish Commercial Code art. 82, Tax Procedure Law art. 253).
- Distance contract and pre-information records: 3 years (Distance Contracts Regulation).
- Account data: while your account remains open. If you ask us to delete your account, your data is deleted except records we are legally required to keep.
- Support correspondence: 3 years after the request is closed.
- Security and sign-in records: 2 years.
- Sign-in codes: 10 minutes (single use).
At the end of the period, data is deleted, destroyed or anonymised under the Regulation on the Deletion, Destruction or Anonymisation of Personal Data.
9. Your rights
Under KVKK art. 11 you have the right to learn whether your data is processed and to request information about it; to learn the purpose of processing and whether it is used accordingly; to know the third parties in Türkiye or abroad to whom it is transferred; to have incomplete or inaccurate data corrected; to have it deleted or destroyed under the conditions of art. 7; to have those actions notified to the third parties it was transferred to; to object to a result against you that arises solely from automated analysis; and to claim compensation for damage caused by unlawful processing.
10. How to apply
Under the Communiqué on the Procedures and Principles of Applications to the Data Controller, send your application in Turkish, including your full name, Turkish ID number (for foreign nationals: nationality and passport or ID number), postal address, email and phone if any, and your request:
- as a signed letter to the address above,
- by KEP, secure electronic signature or mobile signature to adonisnetworkyazilim@hs01.kep.tr, or
- by email to support@adonis.net.tr from the email address registered with us.
We answer free of charge within 30 days at the latest; if the request involves an additional cost, the Board’s fee schedule may apply. If your application is refused, you find the answer insufficient, or we do not answer in time, you can complain to the Personal Data Protection Board within 30 days of learning the answer and in any case within 60 days of your application.
11. Minors
Our services are intended for people aged 18 or over. Orders for anyone under 18 must be placed by a parent or guardian.
12. Changes
We may update this notice when the law or our processing changes. The current version is always published on this page, with the last update date at the bottom.