Cookie Policy

Last updated: February 5, 2025

1. Who We Are

This website is operated by:

Founderville Dijital Yazılım Limited Şirketi
Istanbul, Turkey
Email: support@getcombina.com
Website: combina.app

Data Controller: Founderville Dijital Yazılım Limited Şirketi
Data Protection Contact: support@getcombina.com

2. What Are Cookies

Cookies are small text files stored on your device when you visit a website. They help websites remember your preferences and understand how you use the site.

This Cookie Policy explains what cookies we use on combina.app (our marketing website) and how you can control them.

Note: This policy covers only our website. For information about data collection in the Combina mobile app, please see our App Privacy Policy.

3. Cookies We Use

We use only two services on our website:

3.1 Essential Cookies (Framer)

Our website is built on Framer, which uses cookies necessary for the site to function properly.

Purpose:

  • Session management and site functionality

  • Security and fraud prevention

  • Basic performance optimization

Legal Basis: Necessary for contract performance (providing the website you requested)

These cookies cannot be disabled as they are required for the website to work.

3.2 Analytics Cookies (Google Analytics)

We use Google Analytics to understand how visitors interact with our website.

Cookies Set:

Cookie NameDurationPurpose_ga2 yearsDistinguishes unique visitors_gid24 hoursDistinguishes unique visitors within 24 hours_gat1 minuteThrottles request rate to prevent server overload

Data Collected:

  • Pages you visit on combina.app

  • Time spent on each page

  • How you arrived at our site (referral source)

  • Browser type and device information

  • General geographic location (city/country level only)

  • Screen resolution and viewport size

Data NOT Collected:

  • Your name or email address

  • Payment information

  • Any data from the Combina mobile app

  • Precise geolocation or GPS coordinates

  • Personal identification information

Legal Basis: Your explicit consent via our cookie banner (GDPR Article 6(1)(a))

You can opt out of these cookies using the methods described in Section 6.

4. Why We Use Cookies

4.1 Website Analytics

We use Google Analytics to:

  • Understand which pages are most visited

  • Identify navigation problems or broken links

  • Measure the effectiveness of our marketing efforts

  • Improve website content and user experience

  • Track overall website performance

4.2 No Advertising or Tracking

We do NOT use cookies for:

  • Advertising or marketing

  • Cross-site tracking

  • Building user profiles for sale

  • Third-party data sharing beyond essential service providers

5. Legal Basis for Processing

5.1 GDPR (EU Visitors)

Under the General Data Protection Regulation, we process cookie data based on:

  • Essential Cookies: Legitimate interest (GDPR Article 6(1)(f)) - necessary for website functionality

  • Analytics Cookies: Explicit consent (GDPR Article 6(1)(a)) - you choose via our cookie banner

You can withdraw consent at any time by clearing cookies or using opt-out methods below.

5.2 KVKK (Turkish Law No. 6698)

As a Turkish company, we comply with Turkey's Personal Data Protection Law (KVKK). We process cookie data based on:

  • Explicit consent for analytics cookies (KVKK Article 5)

  • Necessity for contract performance for essential cookies

6. Managing Your Cookie Preferences

6.1 Our Cookie Banner

When you first visit combina.app, you'll see a cookie consent banner. You can:

  • Accept - Allow all cookies (essential + analytics)

  • Decline - Only essential cookies will be used

Your choice is stored for 12 months. You can change your preference by clearing cookies and revisiting the site.

6.2 Browser Settings

You can control or delete cookies through your browser settings:

Warning: Disabling essential cookies may prevent the website from functioning properly.

6.3 Google Analytics Opt-Out

To completely block Google Analytics across all websites:

Install the Google Analytics Opt-out Browser Add-on

This add-on prevents Google Analytics from collecting data about your website visits.

7. International Data Transfers

7.1 Where Your Data Goes

Google Analytics may transfer cookie data to servers located in the United States and other countries.

7.2 Legal Protections

These international transfers are protected by:

  • Standard Contractual Clauses (SCCs) - Approved by the European Commission for GDPR compliance

  • EU-U.S. Data Privacy Framework - Google LLC is certified under this framework

  • Adequacy Decisions - Where applicable for specific countries

7.3 Third-Party Privacy Policies

8. Data Retention

Data TypeRetention PeriodPurposeGoogle Analytics data26 monthsStandard analytics retentionFramer session cookiesUntil browser closesEssential site functionalityCookie consent choice12 monthsRemember your preference

After these periods, data is automatically deleted from our systems.

9. Your Privacy Rights

9.1 Rights Under GDPR (EU/EEA Residents)

If you're located in the European Union or European Economic Area, you have the right to:

  • Access - Request a copy of cookie data we've collected about you

  • Rectification - Correct inaccurate information (limited for cookie data)

  • Erasure - Delete your cookie data by clearing cookies in your browser

  • Restriction - Limit cookie processing by disabling analytics cookies

  • Object - Oppose analytics tracking via opt-out methods

  • Data Portability - Receive your data in machine-readable format (contact us)

  • Withdraw Consent - Change cookie preferences at any time

  • Lodge a Complaint - File a complaint with your Data Protection Authority

To exercise rights: Email support@getcombina.com

9.2 Rights Under KVKK (Turkish Residents)

Under Turkish Personal Data Protection Law (KVKK Law No. 6698), you have the right to:

  • Learn whether your personal data is processed

  • Request information if your data has been processed

  • Learn the purpose of data processing and whether it's used appropriately

  • Know third parties in Turkey or abroad to whom data is transferred

  • Request correction of incomplete or inaccurate data

  • Request deletion or destruction of data under KVKK Article 7 conditions

  • Request notification to third parties about corrections or deletions

  • Object to negative consequences arising from automated data analysis

  • Claim compensation for damages due to unlawful processing

To exercise KVKK rights:

Submit a written request to:

Response Time: We will respond within 30 days as required by KVKK Article 13.

Right to Appeal: If you're unsatisfied with our response, you can appeal to the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu) within 30 days.

9.3 Rights Under CCPA (California Residents)

If you're a California resident, you have the right to:

  • Know - What personal information is collected via cookies

  • Delete - Request deletion of cookie data (clear cookies in browser)

  • Opt-Out of Sale - We do NOT sell cookie data or any personal information

  • Non-Discrimination - We will not discriminate against you for exercising rights

To exercise rights: Email support@getcombina.com

10. Data Security

We implement industry-standard security measures to protect cookie data:

Technical Safeguards:

  • All data transmission encrypted via HTTPS/SSL

  • Secure access controls for analytics dashboards

  • Regular security audits and monitoring

  • Secure cloud infrastructure (Google Cloud, Framer)

Organizational Measures:

  • Limited employee access to analytics data

  • Regular privacy and security training

  • Incident response procedures

  • Compliance with Google's security standards

While we implement strong security measures, no internet transmission is 100% secure. We cannot guarantee absolute security of cookie data.

11. Children's Privacy

Our website is not directed at children under 13 (or 16 in the EU/EEA). We do not knowingly collect cookie data from minors.

If you believe we have inadvertently collected data from a child, please contact us immediately at support@getcombina.com, and we will promptly delete such information.

12. Third-Party Links

Our website may contain links to external sites (e.g., App Store, social media platforms). We are not responsible for the privacy practices or cookie policies of third-party websites.

Please review their policies before providing any personal information.

13. Do Not Track (DNT) Signals

Some browsers offer "Do Not Track" (DNT) signals. Currently, there is no industry standard for responding to DNT signals.

Our website does not currently respond to DNT browser settings. You can opt out of analytics cookies using the methods described in Section 6.

14. Changes to This Cookie Policy

We may update this Cookie Policy to reflect:

  • Changes in our cookie usage

  • New features or services on our website

  • Legal or regulatory requirements

  • Industry best practices

Notice of Changes:

  • Material changes will be posted on this page with an updated "Last updated" date

  • Significant changes may be communicated via email or in-app notification

  • Continued use of the website after changes constitutes acceptance

We encourage you to review this Cookie Policy periodically.

15. Contact & Complaints

General Inquiries

Questions about cookies or this policy?

Email: support@getcombina.com
Company: Founderville Dijital Yazılım Limited Şirketi
Location: Istanbul, Turkey

Response Time: We aim to respond within 14 days.

GDPR Complaints (EU/EEA)

If you're located in the EU/EEA and wish to lodge a complaint:

Contact your national Data Protection Authority:

KVKK Complaints (Turkey)

If you're located in Turkey and wish to lodge a complaint:

Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu)

  • Website: kvkk.gov.tr

  • Address: Nasuh Akar Mah. Ziyabey Cad. 1407. Sokak No: 4, 06520 Balgat-Çankaya/Ankara, Turkey

16. Relationship to Other Policies

This Cookie Policy is part of our broader privacy framework:

Please review all policies to understand how we protect your privacy.

Summary

What cookies we use: Google Analytics (analytics), Framer (essential functionality)

Why we use them: Understand website usage, improve user experience, ensure site functionality

Your control: Accept or decline via banner, browser settings, or Google Analytics opt-out

Your rights: Access, deletion, opt-out under GDPR, KVKK, and CCPA

Contact: support@getcombina.com

We do NOT: Sell your data, use advertising cookies, track you across websites

Last Updated: February 5, 2025
Version: 1.0

By using getcombina.com, you acknowledge that you have read and understood this Cookie Policy.

© 2025 Founderville Dijital Yazılım Limited Şirketi. All rights reserved


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