Kayra Partners Privacy Policy
Effective Date: September 25, 2025
Last Modified: September 25, 2025
1. Company Details & Contact Information
Kayra Partners LLC
Registered Office: 145 Tremont St. Suite 201-1014, Boston, Massachusetts 02111, US
Country of Incorporation: United States
Tel: +1-855-244-2972
General Enquiries: contact@kayrapartners.com
Data Protection Officer (DPO): Aytug Pala, dpo@kayrapartners.com
2. Introduction
This Privacy Policy describes how Kayra Partners ("we", "our", or "the Company") collects, uses, discloses, and protects the personal information of users ("you", "your", "Users") who visit our website [www.kayrapartners.com] ("Site") or otherwise interact with us. It applies globally, including in the United States, Turkey, the Middle East, and the European Union/United Kingdom. By accessing or using our Site or services, you acknowledge that you have read and understood this Policy.
3. What Information Do We Collect?
a. Personal Information
Information that identifies or can be used to identify you, including but not limited to:
• Name, email address, telephone number, business/job title, company information
• Device and technical info (IP address, geolocation, device identifiers)
• Account details, communications with us
• Any information you provide directly via our forms or communications
b. Special Categories of Personal Data
We do not knowingly collect or process sensitive personal data (e.g., health, religion, biometrics). If you voluntarily provide such information or if required by law, we will acquire your explicit consent.
c. Non-Personal Information
• Aggregated or de-identified technical data (browser type, OS, session statistics)
• User activity analytics (page visits, actions, referrer URLs)
4. Legal Bases for Data Processing
We process your personal information on the following lawful bases (as applicable):
• Performance of a contract
• Consent (including for cookies/marketing—can be withdrawn anytime)
• Compliance with legal or regulatory obligations
• Our legitimate business interests (unless overridden by your rights)
• Where required, vital interests or tasks in the public interest
Where processing relies on your consent, you may withdraw it at any time by contacting us.
5. How Is Information Collected?
• When you interact with our Site or services
• When you fill out forms or communicate with us
• From third-party services (e.g., analytics, advertising partners)
• Public sources, business partners, and affiliates
6. How Do We Use Your Information?
We use your information to:
• Provide, operate, and improve our Site and services
• Communicate with you (e.g., service announcements, support, updates)
• Send you marketing materials, if consented
• Personalize your experience on our Site
• Analyze Site usage and trends (statistics, analytics)
• Serve relevant advertisements (where legally permitted)
• Comply with legal, security, and regulatory requirements
• Prevent and detect fraud, and enforce our terms
We do not use your data for fully automated decision-making or profiling that has legal or significant effects, unless we have obtained your explicit consent or as permitted/required by law.
7. Cookies & Tracking Technologies
We and our partners use cookies and similar technologies for:
Facilitating navigation and enhancing your experience
• Facilitating navigation and enhancing your experience
• Ensure the proper functioning and security of our Site
• Preferences storage and session management
• Analyze and improve Site performance and usage
• Serve personalized advertisements
• Enable social media features
Types of Cookies We Use
• Strictly Necessary Cookies: Essential for Site operation (cannot be disabled)
• Performance & Analytics Cookies: Collect data on Site usage (e.g., Google Analytics)
• Functionality Cookies: Personalize your user experience
• Advertising & Targeting Cookies: Deliver relevant ads and measure their effectiveness
• Social Media Cookies: Facilitate social sharing/logins
Full details of each cookie, including provider, purpose, and duration, are available in the Cookie Table at the end of this statement, and through our Cookie Settings manager on the website.
Third-Party Cookies
Our Site may include content or features from third parties that set their own cookies (e.g., for analytics, advertising, social sharing). We have limited control over these third-party cookies—please refer to their respective privacy and cookie policies for more information.
Cookie Consent and Management
On your first visit (and periodically thereafter), a cookie banner enables you to accept, decline, or customize non-essential cookies. You can update your preferences via Cookie Settings at any time. Disabling cookies may affect some Site features. You may also manage cookies via your browser settings and through third-party opt-out options (e.g., NAI, DAA). For more information, visit https://optout.networkadvertising.org/#!/ and https://optout.aboutads.info/#!/.
8. Third-Party Disclosures & International Data Transfers
Your data may be shared with:
• Our subsidiaries, affiliates, trusted service providers and partners (hosting, analytics, marketing, etc.)
• Transaction-related parties (as part of merger, sale, or acquisition events)
• Governmental or regulatory bodies, as required by law
Some recipients may be located outside your home country (including the EEA, UK, Turkey, Middle East, US).
Data Transfer Mechanisms:
We employ appropriate safeguards such as:
• Standard Contractual Clauses approved by EU/UK authorities
• Compliance with adequacy decisions (where applicable)
• Data processing agreements (DPAs)
• Turkish KVKK and other local law cross-border transfer permissions
To request details of third-party processors or to obtain a copy of data transfer agreements, contact dpo@kayrapartners.com.
9. How Do We Protect Your Information?
We use industry-standard physical, technical, and organizational safeguards, including:
• Data encryption in transit and at rest
• Access controls and authentication
• Secure data storage and monitoring
• Regular security assessments and staff training
While we strive to protect your personal information, no system is 100% secure. In the event of a data breach, we will notify affected users and regulators in accordance with applicable laws.
10. Data Retention
• Personal information is retained only as long as reasonably necessary for the purposes stated in this Policy or as required by law.
• Retention periods are determined based on statutory requirements (e.g., accounting, regulatory), business needs, and dispute resolution requirements.
• Outdated or unnecessary information is securely deleted or anonymized.
11. Your Rights
Depending on your jurisdiction, you may have the right to:
• Access, correct, or delete your personal information
• Obtain a copy of your data (data portability)
• Object or restrict the processing of your data
• Withdraw consent at any time (where processing is based on consent)
• Opt-out of marketing
• Lodge a complaint with a supervisory authority/regulator
California Residents: You may request information regarding disclosure of your data to third parties, opt out of the sale/sharing of your data, and exercise your privacy rights under CCPA/CPRA.
Turkey: You may exercise rights under the Turkish Data Protection Law No. 6698 (KVKK). For cross-border data transfers, explicit consent may be required under local law.
To exercise your rights, please email dpo@kayrapartners.com or use the contact information above. We may verify your identity before actioning your request.
12. Children’s Privacy
Our Site and services are not directed to children under the age of 16 (or relevant minimum under local law, e.g., 13 in the US). If we become aware that a minor has provided us personal information without appropriate parental consent, we will promptly delete it. Parents/guardians may contact us at contact@kayrapartners.com to request removal.
13. Do Not Track and Global Privacy Controls
We do not respond to Do Not Track browser signals. However, you may adjust cookie and ad preferences via our cookie settings and opt out mechanisms where applicable.
14. Data Breach Notification
In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify you and the relevant data protection authority as required by law.
15. Corporate Transactions
In the event of a merger, acquisition, or sale of assets, your personal information may be transferred as part of the transaction. The successor will be bound by this Policy.
16. Updates to This Policy
We may update this Privacy Policy from time to time. Material changes will be notified to you by email or prominent notice on the Site, and the revised version will be effective as of the "Last Modified" date above. Your continued use of our Site / Services / Offerings constitutes acceptance of any changes.
17. Cookie Table
Below are examples of cookies we use—an up-to-date list is always available via our [Cookie Settings] tool.
• Cookie name: _ga, _gid | Provider: Google Analytics | Purpose: Analytics/usage statistics | Retention: 2 yrs/_ga; 24h/_gid
• Cookie name: cookieconsent_status Provider: Internal Purpose: Remember user preferences | Retention: 1 year
• Cookie name: NID, ANID Provider: Google Ads Purpose: Advertising/targeting | Retention: 6-13 months
• Cookie name: fbm_, xs, datr Provider: Facebook/Meta Purpose: Social/ad integration Retention: up to 2 yrs
For full details, visit [Cookie Settings] or contact dpo@kayrapartners.com.
18. How to Contact Us
For questions, concerns, or to exercise your rights, contact us at: contact@kayrapartners.com
Data Protection Officer: dpo@kayrapartners.com
