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Cookies Policy

Cookies Confidentiality Policy 
This Confidentiality Policy ("Confidentiality Policy") establishes the terms and conditions for the use of personal data which is shared with the Company by the users/members/visitors ("Data Owner") of the website, www.e-guven.com ("Site") and its mobile application operated by Elektronik Bilgi Güvenliği A.Ş. (“Company”)   (together will be referred to as "Platform") or which is generated by the Company during the use of the Platform by the Data Owner.  

With this Confidentiality Policy, the Data Owner declares that he/she is provided information about processing of personal data and consents to the use of his/her personal data as described here.  
Which data is processed? 

This title lists what is considered as personal data pursuant to the Turkish Law no 6698 on Protection of Personal Data, which is processed by the Company. Unless otherwise stated, "personal data " shall mean the following information under the terms and conditions of this Confidentiality Policy :

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

Pursuant to the articles 3 and 7 of the Law on Protection of Personal Data; data that has been transformed irreversibly into anonymous data shall not be considered as personal data and processing of such data shall be conducted without applying the provisions of this Confidentiality  Policy.

For what purposes is data used? 
The Company may process personal data to customize and recommend products and services of the Company to people according to their likes, habits of use and needs; to use the data in direct and indirect marketing activities and to transfer such data to the Company's representatives, solution partners and third party service providers for such purposes. 

The Company may process personal data and share it with third parties without obtaining the consent of the Data owner pursuant to the articles 5 and 8 of the Law on Protection of Personal Data and/or in case of any exceptions in the relevant legislations.  These are described below:

• Explicitly stipulated in law,  
• Data processing must be done to protect the life or bodily integrity of someone who cannot give his/her consent due to a physical impossibility or whose content is not considered legally valid or to protect the life or bodily integrity of somebody else,  
• Data processing is required provided that this is directly related with the establishment or execution of an agreement between the Data Owner and the Company,  
• Data processing must be done in order for the company to fulfil its legal obligations,
• Data has been made anonymous by the Data Owner,
• Data processing must be done in order to establish, exercise or protect  a right,
• Data processing must be done for the legitimate interests of the Company provided that no harm is inflicted on the basic rights and freedom of the Data Owner. 

Who has access to Data? 
The Company may transfer personal data and the new data it generates using this personal data to third parties from which the Company outsources services for the purposes set in this Confidentiality Policy provided that this is limited to the provision of such services.

Additionally the Company may transfer data to Company's business partners and suppliers and legally authorized organizations in accordance with the purposes described in this Confidentiality Policy. The Company may share personal data with third parties such as outsourcing service providers including those that provide SMS services, hosting services, law firms, research companies, call centers in order to improve data owner experience (including enhancement and customization), ensure data owner security, detect unauthorized or fraudulent use, conduct operational evaluations, eliminate mistakes in Platform services and any other purposes included in this Confidentiality Policy.

The Data Owner agrees and accepts in advance that the above mentioned third parties may store the data owner's personal data in any of their servers all around the world provided that this is limited to the above mentioned purposes.

Data Access Rights and Correction Requests
Pursuant to the article 11 of the law data owners are entitled to;
• Learn whether their personal data has been processed, 
• If processes, request information about how their personal data is processed,
• Learn the purpose of processing their personal data and whether it is used for the intended purpose, 
• Have information about third parties in the country and abroad to whom their personal data has been transferred, 
• Request correction/amendment if their personal data is processed incorrectly or incompletely and that such correction/amendment is informed to the third parties to whom their personal data has been transferred,
• Request that their personal data is deleted or destroyed despite being processed in accordance with the Law and other applicable regulations if the reasons for their data to be processed no longer exist and that these actions are informed to the third parties to whom their personal data has been transferred, 
• Object to any unfavourable outcome for them based on the analysis of their processed data by automatic systems exclusively, 
• Claim damages in the event that they incur losses due to the reason that their personal data is processed illegally. 

The above mentioned requests to exercise rights shall be evaluated in the shortest time possible and in any case maximum in 30 (thirty) days provided they are informed by the personal data owners using the methods specified in the Policy for Protection and Processing of Personal Data of Elektronik Bilgi Güvenliği A.Ş. as included in the website  www.e-guven.com . Although no fee is basically asked for such requests made, the Company reserves the right to ask for a fee according to the list of fees determined by the Personal Data Protection Committee of the Company. 

In the event that a data owner makes a request which will cause the Company not use any of the data owner's data , the data owner accepts that he/she may not be able to benefit fully from the Platform offerings and declares that he/she takes all responsibilities arising from this.

Retention Period for Personal Data 
The Company shall keep the personal data provided by the data owner for the period that is required by the above mentioned processing purposes.

In addition to this, in the event of a conflict between the Company and the data owner, personal data may be retained for the prescription period specified in the relevant laws provided that it is limited to the purpose of defence required during the resolution of the conflict. 

Measures and Commitments on Data Security
The company warrants that the company will take necessary technical and administrative measures, and conduct necessary inspections in order to ensure that 

• personal data is not processed unlawfully,  
• personal data is not accessed unlawfully,  
• personal data is protected.

The Company may not disclose any personal data the Company acquires about the Data Owner to third parties and use it for any other purposes other than the processing purposes, in violation of the provisions of the Personal Data Protection Law. 

If there are links to other applications on the platform, the Company shall not be held responsible for the confidentiality policies and contents of such applications. 

Cookies
The Platform uses Cookies in order to allow users to have the optimum benefit from the Platform and enhance their experience. If you do not prefer the use of Cookies, you can delete or disable Cookies using browser settings. However this can affect the way you will use the Platform.

What are cookies and why are they used?
Cookies are small text files that are placed on your device or net server by the websites you visit. For more detailed information about cookies please visit www.aboutcookies.org andwww.allaboutcookies.org  The main purposes of cookies on our website are listed below:

• To improve the service provided to you by increasing the functionality and performance of the website,
• To improve the website and provide new features on the Website and customize such features according to your preferences;  
• To ensure legal and commercial security for the website, for you and our Company.  
• To use in direct and indirect marketing activities 

• Categories of the Cookies Used on the Website

Technical Cookies Technical Cookies

Authentication Cookies

When a visitor visits the website using his/her password, these types of cookies identify the user on each web page he/she visits to eliminate the need for the user to enter his/her password on every page he/she visits.

Flash cookies

Types of cookies that are used to enable video or audio content on the website.

Customization Cookies

Customization Cookies

Analytical Cookies

Analytical Cookies allow to have analytical results such as number of visitors of the website, pages viewed on the website, visiting times, website scroll moves .

 

  • Cookies Used on the Platform

Cookie

Explanation, Duration and Preferences

Analytical Cookies

 

Ad cookies

Used to show behavioural and target oriented ads to visitors. Can be accepted or declined by modifying browser settings.

Market Analysis

used to carry out market analysis Can be accepted or declined by modifying browser settings.

Campaign/Promotion

Used to calculate the effectiveness of campaigns. Can be accepted or declined by modifying browser settings.

Facebook

These types of cookies allow tracking of Facebook members (or non-members) for marketing analysis and product development purposes. Can be accepted or declined by modifying browser settings.

Twitter

These types of cookies allow tracking of social network members or non-members for marketing analysis and product development purposes. Can be accepted or declined by modifying browser settings.

Google Analytics

These types of cookies allow to collect statistical data to improve the use and presentation of the website. Google allows us to understand users better by adding social statistics and data about interests.  Our website uses Google Analytical cookies. Data collected using these cookies are transferred to Google servers in the USA and then stored there in accordance with the data protection principles of Google. You can click here to have more information about Google's principles on protection of personal data and analytical data processing . Cookies control https://tools.qooqle.com/dlpaqe/qaoptout

Technical Cookies

 

Session

Session cookies only last for the duration of the users using the website. Can be accepted or declined by modifying browser settings.

Load Balancer

Load balancers are used to distribute the load to decrease server load. Can be accepted or declined by modifying browser settings.

Security

Security cookies are used for security checks. Can be accepted or declined by modifying browser settings.

Fraud detection

Used to detect click frauds.

Authentication Cookies

 

User ID

User ID cookies are used to allow the users to see only their own information. Can be accepted or declined by modifying browser settings.

Customization Cookies

 

Language

Stores the language the user selects and offers options accordingly. Can be accepted or declined by modifying browser settings.

Mobile

Used to show the main web site if the user is visiting the website using a mobile device. For example whether the device enables Flash or a mobile website that does not require Flash. The website is stored in order to better understand the user's preferences. Can be accepted or declined by modifying browser settings.

Flash cookies

 

Flash cookies

Enable audio and video contents. Can be accepted or declined by modifying browser settings.

 

  • Can the use of Cookies be Blocked by Data Owners?
    Data owners can change their preferences about cookies by modifying browser settings. If the user's browser provides this option, cookie preferences can be modified using the browser settings. Therefore , although this might differ according to the options the browser offers, data owners have the options to block cookies, to have warnings before the use of any cookie or to disable or delete only certain cookies.

    Cookie preferences may need to be made separately on each device with which the user has access to the Platform. 

 

Adobe Analytics

http://www.adobe.com/uk/privacy/opt-out.html

AOL

https://help.aol.com/articles/restore-security-settings-and-enable-cookie-settings-on-browser

Google Adwords

https://support.google.com/ads/answer/2662922?hl=en

Google Analytics

https://tools.google.com/dlpage/gaoptout

Google Chrome

http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647

Internet Explorer

https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

MozillaFirefox

http://support.mozilla.com/en-US/kb/Cookies

Opera

http://www.opera.com/browser/tutorials/security/privacy/

Safari:

https://support.apple.com/kb/ph19214?locale=tr_TR

 

  • Changes in the Confidentiality Policy

The Company may change the provisions of this Confidentiality Policy anytime. The Current Confidentiality Policy becomes effective when it is presented to the Data Owner using any method.

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Disclosure Form
ELEKTRONIK BILGI GUVENLIGI A.S. DISCLOSURE FORM REGARDING THE PROCESSING OF PERSONAL DATA

This Disclosure Form has been issued by Elektronik Bilgi Guvenligi Anonim Sirketi (the “Company”) with a view to inform the customers of the Company in accordance with the Law No. 6698 on the Protection of Personal Data as to the processing of their personal data by the Company.

The details regarding the processing of your personal data within the framework of this Disclosure Form are available within Elektronic Bilgi Guvenligi A.S. Policy for the Protection and Processing of Personal Data at [www.e-guven.com].

a) Methods of and Legal Reasons for the Collection of Personal Data

Your personal data are collected electronically or physically. Your personal data collected on account of the legal reasons provided herein may be processed and shared in accordance with the requirements for the processing of personal data as set forth within Articles 5 and 6 of the Law.

b) Purposes of Processing of Personal Data

Your personal data are processed in accordance with the requirements for the processing of personal data as set forth within Articles 5 and 6 of the Law for the purpose of the planning and performance of the activities as necessary for the offering and publicity of the products and services offered by the Company to the data subjects in such forms as customized to the appreciation, habits of use and needs of the data subjects, the performance by the business units of necessary activities to make the products ad services offered by the Company available to the data subjects and the execution of the related business processes the performance by the business units of the activities necessary for the performance of the commercial operations maintained by the Company and the execution of the related business processes, the planning and implementation of the commercial and/or the business strategies of the Company, and the ensuring of the legal, technical and commercial - business security of the Company and the parties, who are in business relation with the Company.

c) The Parties, to Whom Personal Data May Be Disclosed, and Purposes of Disclosure

Your personal data may, in accordance with the requirements for the processing of personal data as set forth within Articles 8 and 9 of the Law, be shared with and disclosed to the business partners and suppliers of the Company as well as legally competent authorities and bodies and legally authorized private legal entities for the purpose of the planning and performance of the activities as necessary for the offering and publicity of the products and services offered by the Company to the data subjects in such forms as customized to the appreciation, habits of use and needs of the data subjects, the performance by the business units of necessary activities to make the products ad services offered by the Company available to the data subjects and the execution of the related business processes the performance by the business units of the activities necessary for the performance of the commercial operations maintained by the Company and the execution of the related business processes, the planning and implementation of the commercial and/or the business strategies of the Company, and the ensuring of the legal, technical and commercial - business security of the Company and the parties, who are in business relation with the Company.

d) The Rights of Data Owners and Exercise of Such Rights

In the event you, being a personal data owner, file your request under your rights provided below with the Company through the methods specified within Elektronik Bilgi Guvenligi A.S. Policy for the Protection and Processing of Personal Data, which is available at [www.e-guven.com]; your request so filed will be replied and addressed as soon as practicable but, in any case, no later than 30 (thirty) days.

You, being a personal data owner, have the following rights pursuant to the provisions of Article 11 of the Law:

  • Learn whether or not you personal data have been processed,
  • Request information as to processing if your data have been processed,
  • Learn the purpose of processing of you personal data and whether your data are used in accordance with their purpose,
  • Know the third parties based at home or in abroad, to whom your personal data have been transferred,
  • Request notification of the operations performed as a consequence of such requests as rectification, deletion and destruction to third parties to whom you personal data have been transferred, in the cases where your personal data have been processed incompletely or inaccurately,
  • Request your personal data to be delete or destroyed in the event the reasons that may have required the processing of your personal data in spite of the fact that they have been processed in compliance with the Law and other applicable laws and regulations, and request notification of the relevant operation to third parties to whom personal data have been transferred,
  • Object to occurrence of any result that is to your detriment by means of analysis of your personal data exclusively through automated systems,
  • Request compensation for the damages in case the you incur damages due to unlawful processing of your personal data.