At XPLORE WORK (Xw), our mission is to enable producers of all sizes around the world to connect within a secure, transparent, and efficient commercial network. At the core of this mission lies our commitment to providing the highest level of transparency regarding how the data we collect from our users is processed, stored, and shared.
This Privacy Policy applies when you use our Services (as defined below). Through this policy, we aim to provide a clear and understandable framework explaining how we collect, use, and share your data.
This Privacy Policy should be considered together with our Cookie Policy, KVKK Disclosure Statement, Explicit Consent Text, and all other data processing disclosures specified within the application settings. We place great importance on clearly presenting the options and control mechanisms you have regarding your personal data while using the application.
1. Introduction
We are a professional commercial network and online platform designed for producers of all sizes.
Users utilize our Application to discover new business opportunities, list their products using international product codes, establish connections with other producers, access market data, and create business collaborations. Our Privacy Policy applies to all Members who use our Services.
The term “Designated Countries” refers to the geographical regions where data processing activities are carried out within the European Union (EU) and the Republic of Türkiye. Members and Visitors in these regions may exercise their data rights as defined under KVKK. For details regarding rights and obligations under KVKK, please review our KVKK Disclosure Statement.
Xplore Work is a global trade platform operating under both B2B (business-to-business) and B2C (business-to-consumer) models. Accordingly, data processing activities are conducted in compliance with the Personal Data Protection Law No. 6698 of the Republic of Türkiye (“KVKK”), the General Data Protection Regulation of the European Union (“GDPR”), and other applicable international data protection regulations.
By using the Platform, you acknowledge that you have read and understood the data processing practices described in this Privacy Policy.
2. Data Controller
The data controller responsible for your personal data is:
Xplore Work Software Trading Limited Company Güvenevler Mah. 1928 Sok. Ekinci Global Business Center Site Floor: 14 No: 5/25 Yenişehir, Mersin / Türkiye E-mail: support@xplorework.com
3. Personal Data Collected
Due to the nature of the services provided, Xplore Work may process the following categories of data:
3.1 Identity and Contact Data
Name, surname, company name, tax number, business activity code, email address, phone number, address details, and authorization information.
3.2 Corporate and Official Documents
Tax certificates, producer certificates, trade registry documents, activity permits, and other official documents provided for verification purposes.
These documents are processed for company verification, legal compliance, and security purposes and are securely stored on company servers.
3.3 Account and Usage Data
IP address, device information, operating system, browser details, session logs, transaction history, listing activities, and messaging records.
3.4 Financial Data
Subscription plan details, payment status, and billing information. Card details are processed directly by payment providers and are not stored by Xplore Work.
3.5 Location Data
Listing display via map services and company location information.
4. Purposes of Processing Personal Data
Your personal data is processed for the following purposes:
- Account creation and identity verification
- Company and document verification
- Management of subscription and payment processes
- Provision, improvement, and security of services
- Prevention of fraud, money laundering, and sanction violations
- Compliance with international trade regulations
- Fulfillment of legal obligations
- Dispute resolution and legal defense
Data is processed for specific, explicit, and legitimate purposes and is limited to what is necessary in relation to these purposes.
5. Legal Basis
Data processing activities carried out by Xplore Work are based on legal grounds defined under both KVKK and GDPR. Personal data is evaluated separately for each processing activity and processed in accordance with the appropriate legal basis provided by applicable legislation.
When you register on the platform and use our services, your personal data is primarily processed based on the legal basis of contract formation and performance. In this context, identity, contact, account, and subscription data are processed to create your account, conduct company verification processes, publish listings, and enable commercial connections.
Processing activities carried out in compliance with tax law, commercial law, electronic commerce regulations, and data protection legislation are based on the fulfillment of legal obligations.
Data processing activities aimed at ensuring platform security, preventing fraud and money laundering risks, maintaining system integrity, and protecting legal rights are carried out based on the legitimate interests of the data controller. In such cases, a balance is maintained between the company’s legitimate interests and your fundamental rights and freedoms.
Where explicit consent is required—such as for marketing communications or non-essential cookie usage—data processing activities are carried out based on your consent, which you have the right to withdraw at any time.
Under GDPR, processing activities are particularly based on Articles 6(1)(b), 6(1)(c), and 6(1)(f).
6. International Data Transfers and Firebase Infrastructure
Xplore Work utilizes Google Firebase services within its technical infrastructure. Firebase is used for data hosting, authentication, analytics, and system management. Accordingly, your personal data may be processed and stored in Google’s data centers located within the European Union or other countries.
International data transfers are carried out based on technical necessity and contract performance. In addition, appropriate safeguards are implemented in accordance with Article 9 of KVKK and Articles 44 and subsequent provisions of GDPR.
During international transfers, the following measures are applied:
- Standard contractual clauses
- Appropriate technical and administrative safeguards
- Encryption and access control mechanisms
Official documents (such as tax certificates, producer certificates, and commercial activity documents) are stored on servers under the company’s direct control and are accessible only by authorized personnel.
7. Data Retention Period
Your personal data is retained for as long as necessary for the purposes for which it is processed. In determining retention periods, the following are taken into account:
- Legally required retention periods
- Duration of contractual relationships
- Potential dispute periods
- Financial record obligations
Your personal data continues to be processed as long as your account remains active. In the event of account closure, your data is not immediately deleted; data required to be retained under applicable laws will be stored for the relevant period.
At the end of the retention period, data is deleted, destroyed, or anonymized.
8. Data Security
Xplore Work implements appropriate technical and administrative measures to prevent unlawful processing and unauthorized access and to ensure data security.
These measures include:
- Data encryption systems
- Secure server infrastructure
- Authorization and role-based access controls
- Logging and monitoring systems
- Security and penetration testing
- Employee confidentiality obligations
However, it should be noted that data transmission over the internet cannot be guaranteed to be completely secure. Users are also expected to take necessary precautions to ensure the security of their accounts.
9. Data Subject Rights
Under Article 11 of KVKK and Articles 15–22 of GDPR, data subjects have the following rights:
- To learn whether personal data is processed
- To request information if processed
- To learn the purpose of processing and whether it is used appropriately
- To know third parties to whom data is transferred domestically or abroad
- To request correction of incomplete or inaccurate data
- To request deletion or destruction when processing grounds no longer exist
- To request restriction of processing
- To request data portability in a structured and machine-readable format
- To object to processing
Requests may be submitted in writing or via support@xplorework.com and will be evaluated within the legally prescribed timeframe.
10. Automated Decision-Making and Profiling
The platform may use algorithmic systems to improve user experience and optimize commercial matching processes. These systems may be used for listing recommendations, matching algorithms, content ranking, and risk analysis.
However, such automated processes do not constitute fully automated decision-making that produces legal effects or significantly impacts users.
Users have the right to object to such processing.
11. Children’s Data
The platform is not intended for individuals under the age of 18. Personal data of children is not knowingly collected.
If it is determined that data belonging to a minor has been processed, such data will be deleted immediately.
12. Updates
This Privacy Policy may be updated in accordance with legal changes, technical infrastructure updates, or changes in the scope of services.
The updated version enters into force upon publication on the Platform. Users may be notified of significant changes.
Continued use of the Platform constitutes acceptance of the updated Privacy Policy.