Privacy Policy

This English version is provided for convenience. In case of any discrepancy, the Turkish version prevails.

Version 1.0 · Effective 15 October 2026

1. Who we are

This policy explains how the Hamurlabs group handles personal data on hamurlabs.com and in the HaROS platform. Version 1.0, effective 15.10.2026.

The group consists of two companies. Each acts for the relationships it holds:

CompanyDetailsActs for
Hamurlabs BVKapeldreef 60, 3001 Leuven, Belgium · Enterprise no. 1008.980.934Customers, contacts and visitors in the EU/EEA, the UK and other countries outside Türkiye; applicable law: GDPR and UK GDPR
Hamurlabs Elektronik Hizmetler Yazılım ve Ticaret A.Ş.Çifte Havuzlar Mah. Eski Londra Asfaltı Cad. Kuluçka Mrk. B2 Blok No: 151/1C İç Kapı No: 111 Esenler / İstanbul, Türkiye · Mersis 0456-0607-9150-0001 · KEP [email protected]Customers, contacts and visitors in Türkiye; applicable law: KVKK (Law No. 6698)

In this policy, "Hamurlabs", "we" and "us" mean the company responsible in the situation concerned.

Contact for all privacy matters: [email protected]. Requests for Hamurlabs A.Ş. can also be sent by KEP or by post to the Istanbul address above.

2. Scope and our roles

We process personal data in two different roles, and this policy covers both.

  • As controller, we decide why and how data is processed. This covers our website, demo requests, business contacts, customer account administration and job applications (section 3).
  • As processor, we process data on behalf of our customers, the merchants who use HaROS (OMS, WMS, PIM and fulfilment). This covers order, customer and shipping data that merchants bring into HaROS, including data received from the marketplaces and sales channels they connect (section 4). In this role the merchant is the controller and we act only on its instructions.

If you bought from a merchant that uses HaROS, that merchant's privacy policy governs your data. We support the merchant in handling your requests.

3. Data we process as controller

We collect only what each purpose needs. We do not sell personal data and do not use it for automated decisions with legal effect.

WhoDataPurposeLegal basis (GDPR / KVKK)
Website visitorsIP address, browser and device data, pages visited, security logsRunning and securing the website, preventing abuseLegitimate interest — Art. 6(1)(f) / m.5/2-f
Demo and contact requestsName, business email, phone (optional), company, role (optional), modules of interest, order volumes, message; demo account username and access logs if a demo account is createdAnswering the request, preparing and giving the demo, pre-contract communicationSteps before a contract — Art. 6(1)(b) / m.5/2-c; legitimate interest — Art. 6(1)(f) / m.5/2-f
Customer and supplier contactsName, business contact details, role, communications, contract and invoice recordsManaging the contract, support, billing, legal and tax obligationsContract — Art. 6(1)(b) / m.5/2-c; legal obligation — Art. 6(1)(c) / m.5/2-ç
HaROS user accountsName, business email, username, role, login and activity logsProviding access, security, supportContract — Art. 6(1)(b) / m.5/2-c; legitimate interest — Art. 6(1)(f) / m.5/2-f
Job applicantsCV data, contact details, interview notesRecruitmentSteps before a contract — Art. 6(1)(b) / m.5/2-c; consent for keeping your CV for future roles — Art. 6(1)(a) / m.5/1
Newsletter and marketingName, email, preferencesSending commercial electronic messagesConsent — Art. 6(1)(a) / m.5/1; you can withdraw at any time

Please do not send us special categories of data (for example health data) or personal data of other people in free-text fields.

4. Data we process for our customers (HaROS and integrations)

When a merchant connects a marketplace, web shop or sales channel to HaROS, we receive the data needed to fulfil its orders. We process it only to provide the service the merchant has instructed.

Data concerned: buyer name, delivery and billing address, phone number and email (where the channel provides them), order details, product and inventory data, shipment and return records.

Purposes: order synchronisation, inventory and catalogue updates, warehouse picking and packing, shipping label creation, returns, invoicing and the related support.

Our commitments:

  • We use this data only on the merchant's instructions and in line with the data processing agreement and the terms of the connected channel. We never use it for our own marketing, profiling or sale.
  • Data is stored in cloud infrastructure in the EU (Belgium), encrypted in transit (TLS 1.2+) and at rest (AES-256). Each merchant's data is logically separated.
  • Access is limited to named personnel who need it, with multi-factor authentication, and is logged and reviewed.
  • Requests to access, correct, delete or restrict data are actioned without undue delay when received from the merchant or the channel.
  • After a merchant's contract ends, its data is deleted within 60 days, unless the law requires longer retention of specific records. Backup copies are overwritten in the normal backup cycle. We provide written confirmation of deletion on request.
  • We notify the merchant, and the channel where its terms require it, of a personal data breach without undue delay.

If you are a buyer and want to exercise your rights, please contact the merchant first. If you contact us, we will forward your request to the merchant and help them answer it.

5. Who receives data and international transfers

We share personal data only with the service providers below, within the Hamurlabs group, and with public authorities where the law requires it.

RecipientRoleLocation
Cloud hosting providerHosting of HaROS and the website, backupsEU (Belgium)
Corporate email and document providerCorporate email and documentsProvider's data centres, including outside the EU
Content delivery and security providerContent delivery and website securityGlobal network
Hamurlabs BV / Hamurlabs A.Ş.Development, support and operations within the groupBelgium / Türkiye
Merchant-selected carriers and channelsDelivery and order updates, only on the merchant's instructionsAs chosen by the merchant

Transfers outside the EU/EEA: where data reaches a country without an EU adequacy decision, including access by group staff in Türkiye, we use the European Commission's Standard Contractual Clauses and additional safeguards.

Transfers outside Türkiye (KVKK): data of Hamurlabs A.Ş. is transferred abroad, including to the EU hosting region, under KVKK Art. 9 safeguards: standard contracts with the providers concerned, notified to the Personal Data Protection Authority.

6. Retention, security and cookies

We keep data only as long as the purpose or the law requires, then delete, destroy or anonymise it.

DataRetention
Demo and contact requests that do not lead to a contract12 months from the request
Customer data in HaROS (processor role)While the contract is active, then deleted within 60 days
Contracts and customer/supplier correspondence10 years after the contract ends
Invoices and accounting records10 years (Turkish and Belgian law)
Security, access and system logs2 years, longer only if needed as evidence for an incident
Job applications not leading to hiring1 year after the decision
Marketing dataUntil you withdraw consent; reviewed yearly

Security: we apply encryption in transit and at rest, least-privilege access with multi-factor authentication, centrally managed and encrypted company laptops, logging and monitoring, and a documented incident response process. Our information security management system is aligned with ISO/IEC 27001.

Cookies: our website uses cookies that are strictly necessary for its operation and security. If we use analytics or marketing cookies, we ask for your consent first, and you can change your choice at any time.

7. Your rights

You can ask us to:

  • confirm whether we process your data and give you a copy;
  • correct inaccurate or incomplete data;
  • delete your data, or restrict its processing;
  • give you the data you provided in a portable format;
  • stop processing based on our legitimate interest;
  • stop sending marketing messages, and withdraw any consent you gave;
  • tell third parties who received your data about a correction or deletion (KVKK);
  • compensate damage caused by unlawful processing (KVKK).

Send requests to [email protected]. Requests for Hamurlabs A.Ş. can also be sent by KEP or in writing to the Istanbul address. We answer within one month (GDPR) or 30 days (KVKK). We may ask you to confirm your identity.

Complaints: you can complain to the Belgian Data Protection Authority ([email protected]), the supervisory authority in your EU country, the UK Information Commissioner's Office, or, for Hamurlabs A.Ş., the Turkish Personal Data Protection Board (KVK Kurulu). We would welcome the chance to resolve your concern first.

Children: our services are for businesses and are not directed at children. We do not knowingly collect children's data.

Changes: when we update this policy, we publish the new version on this page with a new version number and date.