Aircux
GDPR

GDPR privacy notice & data subject rights.

Effective: 17 May 2026 · PROCUX Teknoloji A.Ş. · BAUNTEK Teknopark, Balıkesir, Türkiye

In effect · Regulation (EU) 2016/679 · PROCUX Teknoloji A.Ş.

1. Data Controller

This notice is issued by PROCUX Teknoloji A.Ş. ("PROCUX" / "Aircux") in accordance with Articles 13 and 14 of the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR"). The data controller is PROCUX Teknoloji A.Ş., registered at BAUNTEK Teknopark, Balıkesir, Türkiye. For data processed on behalf of our customers, Aircux acts as a data processor under Article 28 GDPR.

2. Categories of Personal Data

Identity (name, surname), Contact (email, phone, company), Role and growth profile (role, MQL band), Commercial (founding waitlist record, sales conversation notes), Technical (IP address, browser information, session data), and Customer account data (lead/account/interaction data processed through the Aircux platform on behalf of the customer-controller).

3. Purposes of Processing

Founding customer enrolment, sales conversation and contract management, provision of the service (operation of Pantheon roles), compliance with legal obligations, service quality measurement, billing and accounting, and customer communication and support.

4. Legal Bases (Art. 6 GDPR)

Art. 6(1)(b) — performance of a contract; Art. 6(1)(c) — compliance with a legal obligation; Art. 6(1)(f) — legitimate interests (service security, product improvement); and Art. 6(1)(a) — consent (where required, e.g. marketing communications). Where consent is the basis, it may be withdrawn at any time.

5. International Transfers & Hosting

Personal data is hosted within the EU on Hetzner Online GmbH (Germany) infrastructure. Cloudflare Inc. (US) acts solely as a DNS/CDN/WAF proxy; customer account data is not transferred to a third country in substance. Where any transfer outside the EEA occurs, it is governed by Standard Contractual Clauses (Art. 46 GDPR). Processing on behalf of customers is covered by a Data Processing Agreement (DPA) under Article 28 GDPR.

6. Retention Periods

Pre-sales lead data: 24 months. During the commercial relationship: active contract term + legally required retention. Marketing consent: until withdrawn. Technical logs: 90 days. On expiry of the applicable period, data is erased or anonymised.

7. Data Subject Rights (Art. 15–22 GDPR)

You have the right to: (a) access your personal data, (b) rectification of inaccurate data, (c) erasure ("right to be forgotten"), (d) restriction of processing, (e) data portability, (f) object to processing (including profiling), and (g) not be subject to a decision based solely on automated processing that produces legal or similarly significant effects. You also have the right to lodge a complaint with a supervisory authority.

8. Exercising Your Rights

To exercise your rights, contact us at demo@aircux.com with proof of identity, or write to the company address. We respond within one month, as required by Art. 12(3) GDPR. For customers, data subject requests received by Aircux as processor are forwarded to the relevant customer-controller.

9. Cookies

The Aircux user interface uses strictly necessary cookies for session management. Third-party tracking/analytics cookies are not used at this stage; if added, this notice will be updated and separate consent obtained.

This notice should be reviewed by counsel against your specific data processing environment. Turkish residents: see the KVKK notice. Questions: demo@aircux.com.

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