Privacy and cookie notice
Last updated: 24 September 2026
Who we are
This website is operated by Tugam, a growth and B2B partnership consultancy founded by Tunahan Gamgam. For any privacy question, contact [email protected].
What we collect
- Messages you send us by email or WhatsApp, including your name, contact details and the content of your message. We use them only to reply and to discuss a potential engagement.
- Analytics data, only if you consent: pages viewed, approximate location (country/city), device and browser type and referral source, collected through Google Analytics 4 with IP anonymisation.
- Technical data processed by our hosting provider, Cloudflare, to deliver and secure the site (for example, IP address in server logs).
Legal bases
We process analytics data on the basis of your consent (GDPR Art. 6(1)(a); Turkish KVKK Art. 5), which you can withdraw at any time via cookie settings. Correspondence is processed on the basis of our legitimate interest in responding to enquiries and taking steps before entering into a contract (GDPR Art. 6(1)(b) and (f)).
Cookies and similar technologies
| Name | Purpose | Type | Duration |
|---|---|---|---|
| tugam_consent_v1 | Stores your cookie choice | Essential (local storage) | Until cleared |
| _ga | Distinguishes visitors (Google Analytics) | Analytics, consent only | 2 years |
| _ga_* | Maintains session state (Google Analytics) | Analytics, consent only | 2 years |
Analytics cookies are not set unless you select "Accept all" or enable analytics in cookie settings. We use Google Consent Mode, so no analytics storage takes place while consent is denied.
Sharing and transfers
We do not sell personal data. Data may be processed by Google (analytics), Cloudflare (hosting) and Meta (WhatsApp) as independent providers, which may involve transfers outside the EEA or Türkiye under their standard contractual safeguards.
Retention
Correspondence is kept for as long as needed to handle your enquiry and any resulting engagement. Analytics data is retained for 14 months.
Your rights
You may request access to, correction or deletion of your personal data, object to or restrict its processing, and withdraw consent at any time. You also have the right to lodge a complaint with your data protection authority (for example, the Dutch Autoriteit Persoonsgegevens or the Turkish KVKK Authority). Write to [email protected].