Privacy Policy
borayevirgen.com, the personal website of Boray Evirgen
Last updated: October 12, 2026. This English text is a courtesy translation of the Turkish text. If the two differ, the Turkish text prevails.
Mobile app privacy policies
This page covers the borayevirgen.com website. Each mobile app has its own privacy policy, because each app handles information differently. The apps are listed in the "Mobile app policies" box on the left (at the top of the page on a phone). Click an app there to open its policy.
In short
- This is a personal portfolio website. You can read it without an account and without giving personal information.
- The site has no advertising, no third-party analytics tools and no tracking cookies. Cloudflare, which hosts the site, runs its own Web Analytics measurement, which Cloudflare describes as privacy-focused. Cookies are set by the site only for people who sign in to an admin panel.
- Fonts are served from this website, so your browser does not contact Google for fonts.
- The demo websites are samples. Their forms do not keep the name, phone number, email or note you type: the server replaces them with made-up details and saves only choices such as the date, room or service. Please still enter sample details.
- Emails you send are used only to answer you. You can ask for access, correction or deletion at any time.
1. Site owner and contact
borayevirgen.com is the personal website of Boray Evirgen, an individual software developer. Boray Evirgen decides why and how personal data on this website is processed, and is therefore the data controller under the Turkish Personal Data Protection Law No. 6698 (KVKK) and, where it applies, the EU General Data Protection Regulation (GDPR).
"BEvn Labs" is a brand name used for the mobile apps the site owner publishes. It is not presented as a registered company or as a separate legal entity.
For privacy questions or requests about this website:
Site owner: Boray Evirgen
Website: borayevirgen.com
Address for notifications: [[EKSİK: posta adresi: yasal-bilgiler.json dosyasına site sahibi yazacak]]. For formal KVKK applications, see the KVKK Notice.
2. Purpose of the website
The site is a personal portfolio. It introduces the site owner, lists software projects, links to apps and shows demo websites built for different industries, so that visitors and prospective clients can see what can be built. It also contains a small browser game, Uçan Kare.
You can read the site without registering and without leaving any personal information.
3. Demo projects and client projects
The demo websites (for example a restaurant, a hotel, a clothing shop, a car rental company or a dental clinic) are samples built for presentation. The businesses, products, prices, staff and opening hours in them are fictional or illustrative, even when a demo has working forms or an admin panel.
Some demos have booking, request or order forms that work, so that their features can be shown. They are designed not to keep personal details: see section 11 and the Demo Notice. Please enter sample details, not your real personal information, and never health or other sensitive details.
A demo may later be turned into a real website for a client. A real client website has its own data controller, its own contact details and its own privacy policy. This policy is not copied to client websites automatically and does not apply to them.
4. Personal data we process
- Technical request data. When a page loads, your browser sends an IP address, browser and device details, the requested address and the time. These requests are served through Cloudflare (section 9), which also provides aggregated visit statistics to the site owner (section 9).
- Messages you send. If you email the site owner: your name and email address as they appear in the message, and whatever you write.
- What you type in a demo form. The name, phone number, email address and note you type are sent to our server so that the form can be checked, but they are not stored: the server replaces them with made-up details (for example "Demo Müşterisi 123", 0500 000 00 00 and [email protected]). What is stored are the choices that make the demo work, such as the date, time, number of people, room, vehicle, service or treatment. The clothing demo's demo orders contain only product names, sizes, colours, quantities and a total calculated by the server. While a request passes through Cloudflare's network, Cloudflare can process it as technical request data (see above).
- Older demo entries. Entries created before this change was introduced were not removed automatically and could contain details that someone typed at that time. You can ask for them to be deleted (section 16).
- A pseudonymous abuse-prevention identifier. On demo forms, a shortened digest of your IP address, derived with a secret key held by the server, is kept to limit repeated submissions. The plain IP address is not stored. Because the digest can tell one connection from another, it is treated as personal data (pseudonymous), not as anonymous data. Section 12 says how long it is kept.
- Account data of admin panel users. Demo admin panels have sign-in accounts for the site owner and for people the owner has given access to (for example prospective clients): username, display name, role, a password hash and session information. Ordinary visitors do not need and do not get an account.
- Data kept in your own browser. See section 10.
We do not intentionally collect special categories of personal data (such as health data), and we do not knowingly collect data from children. The dental demo has no free-text message field and does not store the name, phone number or email you type, so a treatment choice is not linked to you. It is still a sample: please use made-up details there.
5. Why we use the data
- To deliver, secure and keep the website and its demos available, and to see in aggregate how the site is visited and performs.
- To show how the demo websites work, including their forms and admin panels.
- To read and answer the messages you send.
- To prevent spam and abuse of forms and sign-in pages.
- To meet legal obligations when they apply.
The data is not used for advertising, profiling, selling or automated decision-making.
6. How we collect it
- Automatically, through your browser's requests, when you visit a page (served via Cloudflare).
- Directly from you, when you send an email or use a demo form (the form entries are not kept, see section 4).
- From admin panel users, when an account is created for them.
7. Legal bases
The table shows the legal basis for each activity. Where the GDPR applies (see section 15), the matching basis is in the last column.
| Activity | KVKK Art. 5/2 | GDPR Art. 6(1), where it applies |
|---|---|---|
| Delivering and securing the website (technical request data, Cloudflare) | (f) legitimate interest | (f) legitimate interests |
| Aggregated visit and performance statistics (Cloudflare Web Analytics) | (f) legitimate interest | (f) legitimate interests |
| Answering a business or service request you email us | (c) directly related to the conclusion of a contract | (b) steps at your request before a contract |
| Answering any other email | (f) legitimate interest | (f) legitimate interests |
| Checking a demo form request (the details you type are not stored) | (f) legitimate interest. A demo form does not create a contract. | (f) legitimate interests |
| Pseudonymous digest for limiting spam on forms | (f) legitimate interest | (f) legitimate interests |
| Admin panel accounts | (f) legitimate interest | (f) legitimate interests |
| Lawful request from an authority | (ç) legal obligation | (c) legal obligation |
Legitimate interest. The interest is running, securing and presenting a personal portfolio website and its demos, and limiting abuse. The processing is limited to what that needs: demo forms keep no name, phone, email or note, nothing is used for advertising or profiling, and what is kept is shown only to the site owner and to people the owner gives demo access. A demo can show how a form works with made-up details, so real personal details are not necessary for it, and we do not claim they are. On that balance, your fundamental rights and freedoms are not expected to be harmed. If you disagree, tell us and we will review it.
We do not rely on consent for running the site or for demo forms. If we ever need your consent for something, we will ask for it separately, never through a pre-ticked box or by making you accept general terms, and you can withdraw it.
8. Service providers and transfers
- Cloudflare, Inc. hosts the website (Cloudflare Pages), delivers it through its network, provides security and protection against attacks, measures visits with its Web Analytics, and stores the demos' and panels' data in its D1 database.
- Google. The contact email address is a Gmail address, so emails are handled by Google as the email provider. The website itself no longer loads anything from Google: fonts are served from this site.
- People given access to a demo admin panel (for example prospective clients) can see the entries made in that demo, to evaluate it. They are not service providers; the site owner decides who gets access.
- LinkedIn and other platforms are only linked. A link sends you to that platform only if you click it, and its own policy then applies.
Sharing. We do not sell personal data. Personal data may be processed by our service providers, made accessible to authorized demo administration users, or disclosed to competent authorities where required by law, only for the purposes described in this policy.
Transfers abroad. Cloudflare and Google operate servers in several countries, so using them can mean your personal data is processed outside Türkiye and outside the European Economic Area. Which of the mechanisms in Article 9 of KVKK (adequacy decision, appropriate safeguards such as the Board's standard contracts, or the limited incidental cases) covers each transfer has not been confirmed by the site owner and is under legal review. We therefore do not state that a particular mechanism is in place. The KVKK Notice explains this in section 6.
9. Hosting, security and analytics by Cloudflare
The website runs on Cloudflare Pages and every request goes through Cloudflare's network. Cloudflare terminates the secure (HTTPS) connection, filters malicious traffic and may process technical request data such as your IP address, request headers and timing for these purposes. Cloudflare handles that data under its own privacy policy and data processing terms.
Cloudflare Web Analytics. When we checked the live site in a real browser on 12 October 2026, the pages loaded Cloudflare's measurement script from static.cloudflareinsights.com and sent a measurement to /cdn-cgi/rum. This script is added by Cloudflare's hosting service, not by our own page code. According to Cloudflare's documentation, the script collects the minimum information, mainly page timing metrics, and Cloudflare does not track individual end users across its customers' websites; the site owner sees aggregated statistics. Cloudflare's launch material said this service uses no cookies or local storage for analytics, but an independent review at the time reported a cookie being set when the script loaded. We did not find a cookie in our browser check, but cookies marked HttpOnly cannot be listed there, so we do not claim that none can be set. We do not use Google Analytics or any other analytics service. If Cloudflare's measurement is switched off, this paragraph will be updated.
11. Contact and demo forms
Contact. The site has no contact form. Contact links are email links that open your own email program. Nothing is sent until you send the email yourself.
Demo forms. The booking, appointment and request forms work so that their features can be shown, but they do not keep personal details. The name, phone number, email address and note you type are checked by the server and then replaced with made-up details; the demo's admin panel shows a sample record with those made-up details and the choices you made (date, time, room, vehicle, service or treatment). Looking up a booking uses the booking code only. Nothing is forwarded elsewhere. The demos do not send emails, text messages or WhatsApp messages and nobody calls you, even if a demo's screen says a request was received. Demo forms are rate limited and the number of stored entries is capped.
Clothing demo. A demo order stores the products, sizes, colours and quantities and a total that the server calculates from its own product list. No name, address, phone or payment detail is asked.
Each demo form shows a short notice with a link to the Demo Notice, which lists, demo by demo, what is stored.
12. Retention periods
- Request logs and visit statistics at Cloudflare: kept according to Cloudflare's own policy, which the site owner does not control.
- Demo form records (made-up details and choices): kept until the site owner deletes them in the demo's admin panel or resets the demo. There is no automatic expiry, because they hold no personal details you typed. Entries created before this change was introduced may contain details someone typed then; you can ask for them to be deleted at any time.
- Database recovery copies: Cloudflare D1 can keep point-in-time recovery data for a limited period (7 days on the Free plan, 30 days on the Paid plan), so a deleted entry may remain recoverable in that copy until the period ends.
- Abuse-prevention identifier: rows older than 24 hours are deleted each time a new form request is processed. There is no separate scheduled deletion at the moment, so a row can stay longer if nobody uses a form in the meantime.
- Emails: no fixed period has been set. A message is kept for as long as needed for the purpose it was sent for (answering it, a project, a privacy request or a legal record) and is deleted when no longer needed. You can ask for deletion at any time, unless the law or an ongoing legal matter requires keeping it.
- Admin account data: kept while the account is active and removed when access ends.
- Data in your browser: stays on your device until you clear it.
We decide periods by the purpose of the data, legal requirements and your requests.
13. Security measures
- All pages and APIs are served over HTTPS through Cloudflare.
- Admin sign-in uses salted, hashed passwords (PBKDF2). Repeated wrong passwords lock the account temporarily.
- Sign-in cookies are
HttpOnly,SecureandSameSite=Strict. Signing out ends the session on the server too. Admin actions check the session, the permissions and that the request comes from the same site. - Forms have rate limits, size limits, a hidden spam trap field and a cap on stored entries; demo forms do not keep personal details.
- Pages and APIs send headers that stop other websites from embedding them in a frame.
No system is perfectly secure. If a breach affects your personal data, we will notify the people and authorities concerned as the law requires.
14. Your rights under KVKK
Under Article 11 of KVKK you may apply to the data controller to:
- learn whether your personal data is processed;
- request information if it has been processed;
- learn the purpose of processing and whether it is used accordingly;
- know the third parties to whom it is transferred, in Türkiye or abroad;
- request correction if it is incomplete or inaccurate;
- request deletion or destruction within the conditions of Article 7;
- request that those corrections, deletions or destructions be notified to third parties the data was transferred to;
- object to a result against you that arises from analysis exclusively by automated systems;
- claim compensation for damage caused by unlawful processing.
You may also complain to the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu) within the periods set by the law. The full information notice is on the KVKK Notice page.
15. GDPR
Scope. The GDPR applies to a controller outside the EU only if it offers goods or services to people in the EU, or monitors their behaviour there (Article 3(2)). This website is a personal portfolio written in Turkish and English. Its own code does not monitor behaviour (no analytics or tracking tools of ours), and being reachable from the EU does not by itself make the GDPR apply. We therefore do not assume that the GDPR applies in general, but we treat requests from people in the EU or EEA in the same way as KVKK requests. No EU representative (Article 27) has been appointed.
Rights, where the GDPR applies to you: access to your personal data, correction, erasure, restriction of processing, objection to processing based on legitimate interests (Article 21), portability where Article 20 applies, and withdrawal of consent where processing is based on consent. You may also lodge a complaint with a supervisory authority, for example in the country where you live or work.
16. Deletion and how to apply
Everyday requests. For privacy questions, or to have an entry you made in a demo deleted, send an email to [email protected] with the subject "Privacy request". Please say which demo or page it concerns, roughly when you entered the information and the name, phone number or email you typed, so that we can find it. We may ask for information to verify who you are before we act. We answer as soon as possible and at the latest within 30 days.
Formal KVKK applications follow the methods in the KVKK Notice (section 8), which also explains the cost rules and the right to complain to the Personal Data Protection Board. An ordinary email is enough for everyday requests but is not by itself one of the formal application methods.
If we have to say "no" to a request, we will explain why.
17. Updates to this policy
We update this policy when the website, its demos or the law change. The date at the top of this page shows when it was last updated. Material changes are made before the change takes effect.