Cookie Policy

Cookie Privacy Policy

The objective of this Privacy Policy is to specify the terms and conditions regarding the use of personal data disclosed to Elektronik Bilgi Güvenliği A.Ş. and Plum Technologies B.V. (“Company”) by the users/members/visitors of the website at www.e-guven.com (“Site”) and its mobile application (collectively referred to as the “Platform”), or generated by the Company during the Data Subject’s use of the Platform.   

By accepting this Privacy Policy, the Data Subject acknowledges that he/she has been informed about the processing of personal data and consents to the use of such personal data as specified herein. 

Which Data Are Processed?

This section specifies the data processed by the Company which are considered personal data in accordance with Law No. 6698 on Protection of Personal Data. Unless otherwise expressly specified, the term “personal data” shall refer to the following information within the scope of the terms and conditions stipulated under this Privacy Policy: 

• Customer Information
• Device Information
• Behaviour
• Demographic Information
• Marketing Information
• Behavioural Advertising

Data anonymized in a non-reversible manner in accordance with Articles 3 and 7 of the Personal Data Protection Law shall not be considered personal data pursuant to the provisions of the aforementioned Law, and processing activities relating to such data shall be carried out without being subject to the provisions of this Privacy Policy.

For Which Purposes Are the Data Used?

The Company may process personal data for the purposes of personalising the products and services offered by the Company in accordance with the preferences, usage habits and needs of the relevant persons and recommending them to such persons; using such data within the scope of direct and indirect marketing activities; and transferring such data for these purposes to the Company’s representatives, solution partners and third-party service providers.

The Company may process personal data and share them with third parties without obtaining additional consent from the Data Subject pursuant to Articles 5 and 8 of the Personal Data Protection Law and/or where exemptions under the applicable legislation apply. The main examples of such circumstances are as follows:

• It is expressly stipulated by law,
• It is necessary for the protection of the life or physical integrity of the person or another person where the Data Subject is unable to provide consent due to actual impossibility or where his/her consent is not legally valid,
• It is necessary to process personal data belonging to the parties to an agreement, provided that such processing is directly related to the execution or performance of an agreement between the Data Subject and the Company,
• It is necessary for the Company to fulfil its legal obligations,
• The personal data has been made public by the Data Subject,
• Data processing is necessary for the establishment, exercise or protection of a right,
• Data processing is necessary for the legitimate interests of the Company, provided that the fundamental rights and freedoms of the Data Subject are not infringed.

Who Is Authorized to Access the Data?

The Company may transfer personal data and new data generated by using such personal data to third parties from which the Company receives services, for the purpose of achieving the objectives specified in this Privacy Policy and limited to the provision of such services. The Company may also transfer data to its business partners and suppliers, as well as legally authorized institutions and organizations, for the purposes specified in this Privacy Policy.

The Company may share such data with third parties such as outsourced service providers, including SMS service providers, hosting service providers (hosting services), law firms, research companies and call centres in order to improve the Data Subject’s experience (including improvement and personalization), ensure the Data Subject’s security, detect fraudulent or unauthorized use, conduct operational assessment research, resolve errors relating to Platform services and achieve any of the purposes specified under this Privacy Policy.

The Data Subject agrees that, provided that it is limited to the purposes specified above, the aforementioned third parties may store the Data Subject’s personal data on servers located anywhere in the world and gives prior consent to such storage.

About the Right to Access Data and Rectification Requests

Pursuant to Article 11 of the Law, Data Subjects have the right to:

• Learn whether personal data is processed or not,
• Request information if personal data has been processed,
• Learn the purpose of processing personal data and whether it is used in accordance with such purpose,
• Know the third parties in Türkiye or abroad to whom personal data is transferred,
• Request correction of personal data in case of incomplete or incorrect processing and request notification of the action taken for this purpose to third parties to whom personal data is transferred,
• Request deletion or destruction of personal data where the reasons requiring processing no longer exist, even though the data has been processed in accordance with the Law and other applicable provisions, and request notification of the action taken for this purpose to third parties to whom personal data is transferred,
• Object to an adverse outcome resulting from analysis of processed data exclusively through automated systems,
• Request compensation for damages in case of loss arising due to unlawful processing of personal data

Data Subjects may exercise these rights using the methods specified in the Elektronik Bilgi Güvenliği A.Ş. Personal Data Protection and Processing Policy available at www.e-guven.com. Applications will be evaluated and concluded as soon as possible and, in any case, within 30 (thirty) days. Although applications are generally processed free of charge, the Company reserves the right to charge a fee in accordance with the tariff determined by the Personal Data Protection Board.

The Data Subject acknowledges that he/she may not be able to benefit fully from the operation of the Platform if he/she makes a request resulting in the Company being unable to use any of his/her personal data and declares that he/she shall bear all liability arising in this respect.

Retention Period for Personal Data

The Company shall retain the personal data provided by the Data Subject for as long as required by the purposes of processing specified above.

In addition, in the event of any dispute arising between the Company and the Data Subject, the Company may retain personal data for the limitation periods stipulated under the applicable legislation, limited to the purpose of making the necessary legal defences in connection with such dispute.

Measures and Commitments Regarding Data Security

The Company undertakes, under the conditions specified in the applicable legislation or in this Privacy Policy, to take the necessary technical and administrative measures and carry out the necessary audits in order to:

• prevent unlawful processing of personal data,
• prevent unlawful access to personal data, and
• ensure the safeguarding of personal data

and thereby ensure an appropriate level of security.

The Company shall not disclose personal data obtained regarding the Data Subject to another person in breach of this Privacy Policy or the Personal Data Protection Law and shall not use such data for purposes other than the purpose of processing.

Where links to other applications are provided through the Platform, the Company shall not be responsible for the privacy policies or content of such applications.

Cookies

Cookies are used on the Platform to ensure that Data Subjects can benefit from the Platform in the most efficient manner and to improve the user experience. If you do not wish to use cookies, you may delete or block cookies through your browser settings. However, please note that this may affect your use of the Platform.

• What Is a Cookie and Why Is It Used?

Cookies are small text files stored on your device or network server through browsers by the websites you visit. For more detailed information about cookies, you may visit www.aboutcookies.org and www.allaboutcookies.org.

The main purposes of using cookies on our Website are listed below:

• To improve the services offered to you by increasing the functionality and performance of the Website,
• To improve the Website, offer new features through the Website and personalize the features offered according to your preferences,
• To ensure the legal and commercial security of the Website, you and our Company.
• To use them within the scope of direct and indirect marketing activities
• Categories of Cookies Used on the Site

• Cookies Used on the Platform

• Can Data Subjects Block the Use of Cookies?

Data Subjects have the option to customize their cookie preferences by changing their browser settings. If the browser supports this feature, cookie preferences can be changed through the browser settings. Accordingly, although this may vary depending on the features offered by the browser, Data Subjects may block the use of cookies, choose to receive a warning before cookies are used, or disable or delete only certain cookies.

Cookie preferences may need to be configured separately for each device through which the user accesses the Platform.

• Amendments to the Privacy Policy

The Company may amend the provisions of this Privacy Policy at any time. The current Privacy Policy comes into effect on the date it is presented to the Data Subject by any means.