Privacy Policy

Last updated: 14 July 2026

CPM — Cube Procurement Management ("CPM", "we", "us", or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains what information we collect through our website cpm-procurement.com (the "Website"), how we use it, with whom we share it, and the rights you have over it.

We process personal data in accordance with the applicable data protection legislation, including the Turkish Law on the Protection of Personal Data No. 6698 ("KVKK") and, where applicable, the EU General Data Protection Regulation ("GDPR").

1. Data Controller

The data controller responsible for your personal data is:

• Company: CPM — Cube Procurement Management
• Location: Istanbul, Türkiye
• Email: info@cpm-procurement.com

2. Personal Data We Collect

Depending on how you interact with us, we may collect the following categories of personal data:

2.1 Information you provide to us

• Contact details — such as your name, email address, phone number, job title, and company name when you contact us by email or through the Website.
• Business and supplier information — such as company name, registration number, address, contact details, and details of products or services offered, when you submit a supplier or partnership enquiry.
• Correspondence — the content of messages you send us.

2.2 Information collected automatically

• Usage data — pages visited, time spent on pages, links clicked, and approximate location (country/city level), collected through analytics cookies. See our Cookie Policy for details.
• Technical data — IP address, browser type and version, device type, operating system, and referring URLs, collected through standard server logs.

We do not knowingly collect special categories of personal data (such as health data or data revealing racial or ethnic origin) through the Website, and we ask that you do not send us such data.

3. How and Why We Use Your Data

We use your personal data for the following purposes:

• To respond to your enquiries and communicate with you;
• To evaluate potential suppliers, partners, and business relationships;
• To provide, maintain, and improve the Website and our services;
• To analyse Website traffic and usage so we can improve content and user experience;
• To ensure the security of the Website and prevent misuse;
• To comply with legal obligations and to establish, exercise, or defend legal claims.

4. Legal Bases for Processing

We rely on the following legal bases under the KVKK and, where applicable, Article 6 of the GDPR:

• Legitimate interests — operating and securing our Website, developing our business, and responding to enquiries;
• Performance of a contract — taking steps at your request prior to entering into, or to perform, a contract with you or your company;
• Legal obligation — where processing is necessary to comply with laws applicable to us;
• Consent — for non-essential cookies and analytics, where required by applicable law. You may withdraw your consent at any time.

5. Cookies and Analytics

The Website uses cookies and similar technologies, including Google Analytics 4, to understand how visitors use the site. For detailed information about the cookies we use, their purposes, and how you can manage them, please see our Cookie Policy.

6. Who We Share Your Data With

We do not sell your personal data. We may share personal data with:

• Service providers — such as website hosting, IT, email, and analytics providers (including Google LLC for Google Analytics), who process data on our behalf under appropriate safeguards;
• Professional advisers — such as lawyers, auditors, and insurers, where necessary;
• Public authorities — where disclosure is required by law, regulation, or legal process;
• Business partners — only where necessary for a project or engagement you are involved in, and limited to what is required.

7. International Transfers

Some of our service providers (for example, Google Analytics) may process data on servers located outside Türkiye and/or the European Economic Area. Where personal data is transferred internationally, we take steps to ensure an adequate level of protection in line with the KVKK and, where applicable, the GDPR — such as transferring to countries with adequacy decisions or using appropriate contractual safeguards.

8. Data Retention

We retain personal data only for as long as necessary for the purposes described in this Policy, or as required by applicable law (for example, statutory retention periods for commercial records). When data is no longer needed, we delete, destroy, or anonymise it in accordance with applicable legislation.

9. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration, or disclosure. However, no method of transmission over the Internet is completely secure, and we cannot guarantee absolute security.

10. Your Rights

Under Article 11 of the KVKK and, where applicable, the GDPR, you have the right to:

• Learn whether your personal data is being processed and request information about such processing;
• Learn the purpose of processing and whether your data is used in line with that purpose;
• Know the third parties to whom your data is transferred, in Türkiye or abroad;
• Request rectification of incomplete or inaccurate data;
• Request erasure or destruction of your data where the conditions under applicable law are met;
• Object to processing based on legitimate interests, and object to results produced exclusively by automated systems;
• Request restriction of processing and data portability, where applicable under the GDPR;
• Withdraw your consent at any time, where processing is based on consent;
• Claim compensation for damages arising from unlawful processing.

To exercise any of these rights, please contact us at info@cpm-procurement.com. We will respond to your request as soon as possible and in any case within the time limits set by applicable law. You also have the right to lodge a complaint with the Turkish Personal Data Protection Authority (KVKK Kurumu) or, where the GDPR applies, with your local supervisory authority.

11. Children's Privacy

The Website is intended for a professional, business audience and is not directed at children under 16. We do not knowingly collect personal data from children.

12. Third-Party Links

The Website may contain links to third-party websites (for example, LinkedIn). We are not responsible for the privacy practices or content of those websites, and we encourage you to review their privacy policies.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised "Last updated" date. We encourage you to review this page periodically.

14. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at info@cpm-procurement.com.