Privacy Notice (GDPR)

Last updated: 31 July 2026

Türkçe (KVKK) sürümü: KVKK Aydınlatma Metni

This notice explains how 3T Havuzculuk ve Mekanik Ltd. Şti., trading as Cometepool, collects and uses personal data through this website and through the business enquiries we receive. It is written for visitors in the European Union and the European Economic Area and follows the General Data Protection Regulation (EU) 2016/679 ("GDPR").

Cometepool is a manufacturer selling to businesses. In practice we process very little personal data: business contact details that you deliberately give us, and basic technical data that any website receives. We do not sell personal data, we do not run advertising or retargeting campaigns from this site, and we make no automated decisions that produce legal effects for you.

A separate notice under Turkish law (Law No. 6698, "KVKK") is published at KVKK Aydınlatma Metni. The two documents describe the same processing activities under two legal frameworks.

1.Who is responsible for your data

The controller for the processing described here is:

2.What we collect and why

a) Catalogue requests

If you ask us for our product catalogue through the form on this website, we collect your name, your e-mail address and, if you choose to enter it, your company name. We use this to send you the catalogue and to follow up on your enquiry as a trade contact. The catalogue PDF itself is also downloadable, and giving us these details is your choice.

b) Direct contact

If you write to us by e-mail, call us, or start a WhatsApp conversation using the buttons on this site, we process whatever you choose to send: typically your name, company, contact details and the content of your message. We use it to answer you and, if it leads to business, to handle the order and our own commercial records.

c) Technical data received automatically

Like any website, ours is delivered by a hosting provider whose servers record standard request data: IP address, browser and operating system identifiers, the page requested, referring page and a timestamp. This is used to deliver the site, keep it available and defend against abuse.

d) Statistics

We use Google Analytics 4 to understand, in aggregate, which products and pages people look at. Section 7 explains exactly how this is configured and why no analytics cookies are placed on your device unless you agree.

e) Web fonts

This site loads its typefaces from the Google Fonts service. Your browser therefore requests those font files directly from Google's servers, and Google receives your IP address and basic request data as part of that. If you prefer this not to happen, blocking third-party requests to fonts.googleapis.com and fonts.gstatic.com in your browser will simply cause the site to fall back to a system typeface.

What we do not collect

• We do not ask for and do not want special categories of data (health, religion, political opinions, biometrics and similar).
• We do not run advertising or retargeting pixels on this site.
• We do not buy contact lists or enrich your data from third-party databases.
• We do not carry out profiling or automated decision-making within the meaning of Article 22 GDPR.

3.Legal basis for processing

We rely on the following grounds under Article 6(1) GDPR:

Where we rely on legitimate interest, we have weighed it against your interests and rights. The processing involves business contact details in a professional context, no special-category data and no profiling, and you can object at any time as described in section 6.

4.Third parties and transfers outside the EEA

We keep the number of parties involved deliberately small. The following organisations process personal data on our behalf or receive it as a consequence of how the site works:

We also disclose data to our accountants, auditors and, where necessary, legal advisers, who are bound by professional confidentiality.

Transfers outside the EEA

Cometepool is established in Türkiye. Türkiye is not covered by a European Commission adequacy decision. This means that when you send us an enquiry or request our catalogue, your data is transferred to and processed in a country outside the EEA.

For that transfer we rely on Article 49(1)(b) GDPR — the transfer is necessary to take steps at your request before entering into a contract — and, where that does not apply, on your explicit consent under Article 49(1)(a) GDPR. Some of the service providers listed above may likewise store or process data outside the EEA under their own transfer mechanisms; their published privacy terms describe those arrangements.

5.How long we keep your data

We keep personal data only as long as it is needed for the purpose it was collected for, and then for as long as the law requires us to keep the underlying commercial records.

• Enquiries that do not lead to business: kept while the enquiry is live and for a reasonable period afterwards, in case you come back to us.
• Customer and order records: kept for the statutory retention periods that apply to commercial and tax records under Turkish law.
• Server log data: kept for the period applied by our hosting provider.

When the purpose ends and no retention obligation applies, the data is deleted or anonymised.

6.Your rights

If you are in the EU or EEA, the GDPR gives you the following rights over your personal data:

• Access (Art. 15) — to be told whether we hold data about you and to receive a copy of it.
• Rectification (Art. 16) — to have inaccurate or incomplete data corrected.
• Erasure (Art. 17) — to have your data deleted where we no longer have a valid reason to keep it.
• Restriction (Art. 18) — to have processing paused while a dispute about accuracy or lawfulness is resolved.
• Portability (Art. 20) — to receive the data you gave us in a structured, machine-readable format, or to have it sent to another controller.
• Objection (Art. 21) — to object to processing based on our legitimate interest, and to object at any time and without giving a reason to any direct marketing.
• Withdrawal of consent (Art. 7(3)) — where processing is based on consent, to withdraw it at any time. This does not affect anything we did lawfully before you withdrew it.
• Complaint (Art. 77) — to complain to a data protection supervisory authority. See section 8.

To exercise any of these, write to info@cometepool.com. We will respond within one month of receiving your request, as required by Article 12(3) GDPR. If your request is complex we may extend this by up to two further months and will tell you if that happens. Exercising these rights is free of charge. We may ask you for information to confirm your identity, but only what is necessary to be sure we are not disclosing your data to someone else.

7.Cookies, local storage and Consent Mode

This site does not use advertising, retargeting or social media tracking cookies at all.

Google Consent Mode v2

Google Analytics is loaded with Google Consent Mode v2, and all four consent signals are set to denied by default before anything else runs:

• analytics_storage — denied
• ad_storage — denied
• ad_user_data — denied
• ad_personalization — denied

While these signals are denied, Google Analytics does not write analytics cookies or similar identifiers to your device, and measurement is limited to aggregated, cookieless signals. The advertising signals stay denied in all cases, because we do not advertise from this site. Note that loading the analytics and font resources still causes your browser to contact Google's servers, which means Google receives your IP address and standard request data, as explained in section 2.

Storage we do use

The site keeps a small amount of information in your own browser's local and session storage. It stays on your device, is not a tracking identifier and is not transmitted to us:

You can clear all of this at any time through your browser's settings for site data, and you can block cookies and storage for this site entirely without losing access to any content.

8.Contact and your right to complain

If you have a question or a concern about how we handle your data, please contact us first — most things are resolved quickly that way.

You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU or EEA country where you live, where you work, or where you believe the problem occurred. A list of national authorities and their contact details is published by the European Data Protection Board at edpb.europa.eu.

Under Turkish law, complaints may also be addressed to the Turkish Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu, KVKK) at kvkk.gov.tr.

9.Changes to this notice

We update this notice when our processing changes or when the law requires it. The date at the top always shows when the current version was published, and the current version is always available at this address.