KVKK & GDPR Data Protection Notice

Contact Information

• Company: Centerium LLC
• Address: 109 Fowler Ct, New Castle, Delaware 19720-5409, United States
• Email: [email protected]
• Website: https://ipv4center.com

2.1 Service Delivery and Contract Performance

• Providing IPv4 address sale, lease, and transfer services
• Delivering ASN services
• Account creation, identity verification, and management
• Processing orders and reservations
• Executing transactions with RIRs (RIPE NCC, ARIN, APNIC, LACNIC, AFRINIC)
• Invoicing and payment processing

2.2 Legal Obligations

• Compliance with tax legislation and reporting requirements
• Adherence to commercial law and e-commerce regulations
• KYC (Know Your Customer) and AML (Anti-Money Laundering) obligations
• Responding to lawful requests from competent authorities
• Accounting and audit activities

2.3 Legitimate Interests

• Platform security and fraud prevention
• Service quality improvement and optimization
• Statistical analysis and reporting
• Customer satisfaction measurement and support
• Business process development

2.4 Consent

• Marketing and promotional communications
• Analysis of usage patterns through cookies and similar technologies
• Personalized service and content delivery

3.1 Identity Data

• Full name
• National ID / passport number (where required)
• Tax identification number
• Company name and trade registry information
• Authorized representative name and title

3.2 Contact Data

• Email address
• Phone number
• Billing and office address
• Country of residence

3.3 Financial Data

• Bank account details (for seller payments)
• Invoice information and payment history
• Transaction amounts and currency preferences
• Tax office information

3.4 Transaction Data

• IPv4 address block sale, purchase, and lease records
• ASN service requests and history
• Order, reservation, and contract details
• RIR membership information (Org ID, Reg ID)

3.5 KYC Documents

• Company registration documents
• Articles of association or equivalent
• Signature circulars and authorization documents
• Signed and stamped contract copies

3.6 Technical Data

• IP address
• Browser type and version
• Operating system information
• Cookie data and session information
• Access timestamps and page view data

4.1 Collection Methods

• Account registration and form submissions on the Platform
• Communication via email, phone, and live chat support
• During order and payment processes
• Document uploads during KYC verification
• Automatic collection through cookies and similar technologies
• Transactions conducted through RIR systems

4.2 Legal Bases

• Performance of a contract (KVKK Art. 5/2(c); GDPR Art. 6(1)(b))
• Compliance with legal obligations (KVKK Art. 5/2(ç); GDPR Art. 6(1)(c))
• Legitimate interests of the data controller (KVKK Art. 5/2(f); GDPR Art. 6(1)(f))
• Explicit consent of the data subject (KVKK Art. 5/1; GDPR Art. 6(1)(a))
• Establishment, exercise, or defense of legal claims (KVKK Art. 5/2(e))

5.1 Domestic Transfers

• Competent public authorities as required by law
• Payment service providers and banks
• Accounting and financial advisory service providers
• Legal advisory service providers

5.2 International Transfers

• RIR organizations (RIPE NCC — Netherlands, ARIN — USA, APNIC, LACNIC, AFRINIC) for IPv4 transfer and ASN transactions
• Cloud infrastructure and hosting service providers
• Email and communication service providers
• Payment processing providers (e.g., Stripe)
• Analytics and performance measurement tools

7.1 Technical Measures

• SSL/TLS encryption for all data communications
• AES-256 encryption for sensitive data at rest
• Firewalls and intrusion detection/prevention systems
• Regular security audits and penetration testing
• Access control and authorization mechanisms
• Backup and disaster recovery systems
• Timely application of software updates and security patches

7.2 Organizational Measures

• Personal data processing inventory management
• Data protection awareness training for employees
• Confidentiality agreements and data protection commitments
• Data processing policies and procedures
• Data breach notification and response plan
• Data protection agreements with third-party service providers
• Regular internal audits and compliance assessments

10.1 Application Channels

• Email: Send a written request with identity verification to [email protected]
• Mail: Send a notarized or registered letter to 109 Fowler Ct, New Castle, Delaware 19720-5409, United States

10.2 Application Requirements

Your request must include:

• Full name and signature (if written)
• National ID or passport number
• Residential or business address for correspondence
• Email address, phone, and/or fax number (if available)
• Subject of the request

10.3 Response Time

Your requests will be processed free of charge and concluded within 30 days at the latest. If the request requires additional cost, the fee determined by the Turkish Personal Data Protection Board may apply. For GDPR-based requests, we will respond without undue delay and within one month, which may be extended by two further months for complex requests.