LegalThis Cookie Policy and Privacy Notice (the “Policy”) has been drawn up to ensure that the personal data of users, members and visitors (the “Data Subject”) of the website (the “Site”) operated by our Company, acting as data controller, is processed, stored and protected in full compliance with the Law on the Protection of Personal Data No. 6698 (“KVKK”), the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform and the related secondary legislation, and the principle decisions of the Personal Data Protection Board (the “Board”).
1. What Is a Cookie and What Data Is Processed?
1.1. Cookies are small text files that the websites you visit store on your device or network server through your browser. Cookies are created by the servers associated with the website visited and allow the server to recognise the device when the same site is visited again.
1.2. Through the cookies used on our Site, personal data such as IP address, operating system, browser type and version, device identification information, on-site navigation logs, click data, and session and preference information is processed.
1.3. No special categories of personal data set out in Article 6 of Law No. 6698, such as biometric, genetic or health data, are processed through the cookies on our Site.
2. Types of Cookies, Purposes of Processing and Legal Grounds
The cookies used on our Site are separated on an activity basis according to their duration, source and purpose of use, and are processed on the specific legal grounds set out in Article 5 of KVKK:
| Cookie Category | Description and Purpose of Processing | Legal Ground (KVKK Art. 5) | Consent Requirement |
|---|---|---|---|
| Essential Cookies | Necessary for the Site to work properly from a technical point of view, to provide information society services, to maintain the session and to ensure system security. | KVKK Art. 5/2-c (Establishment and performance of a contract) and Art. 5/2-f (Legitimate interest) | Explicit consent is not required. |
| Functionality Cookies | Remember preferences for language, region, theme and personalisation of the user experience. | KVKK Art. 5/1 (Explicit Consent) | Optional (Opt-in). |
| Performance and Analytics Cookies | Allow the number of visitors, page traffic and usage statistics of the Site to be analysed in anonymous/aggregated form and performance to be measured. | KVKK Art. 5/1 (Explicit Consent) | Optional (Opt-in). |
| Marketing and Targeting Cookies | Used to profile users according to their interests, offer personalised advertising/campaigns and measure advertising effectiveness. | KVKK Art. 5/1 (Explicit Consent) | Optional (Opt-in). |
3. Managing Cookie Preferences and the Opt-In (Explicit Consent) Mechanism
3.1. Our Company adopts the principle of active and voluntary explicit consent (“opt-in”) for the use of all non-essential cookies (functionality, performance, marketing).
3.2. The “Accept”, “Reject” and “Manage Preferences” options on the Cookie Management Panel (Banner) shown to the user on first visiting the Site are designed with equal visibility and accessibility.
3.3. All cookie categories other than essential cookies are presented “off/inactive” by default. The Data Subject not making an active choice or continuing to browse the Site is never treated as implied consent.
3.4. The provision of the service or the use of the Site cannot be made conditional on accepting non-essential cookies (“bundling/tying prohibition”). Even if the Data Subject rejects cookies, they have the right to use all core functions of the Site.
3.5. The Data Subject has the right to withdraw the explicit consent they have given, or update their preferences, at any time and without any burden, through the Cookie Management Panel or the “Cookie Settings” link in the footer of the Site.
4. Transfer of Cookie Data and Safeguards for Transfers Abroad
4.1. Personal data collected through cookies may be transferred, only to the extent of the stated processing purposes and in line with Article 8 of KVKK, to legally authorised public institutions and organisations and to our authorised domestic business partners from whom technical infrastructure, information security and hosting services are obtained.
4.2. Where the servers of third-party cookie providers such as Google Analytics, Adobe Analytics and similar are located abroad, the cross-border transfer of cookie data is carried out under Article 9 of KVKK based on the Data Subject’s separate and explicit consent to the transfer of data abroad, or on appropriate safeguards approved by the Board (standard contract/undertaking).
4.3. Under competition law rules, data obtained through cookies cannot be subject to unauthorised data combination (cross-data matching) with group companies, affiliates or third parties, or to the sharing of competition-sensitive commercial data.
5. Data Security, Retention Periods and Destruction
5.1. Our Company takes all necessary technical and administrative measures under Article 12 of KVKK (access authorisation matrices, logs, masking, encryption and regular audits) to prevent the unlawful processing of and access to personal data processed through cookies, and to ensure its safekeeping.
5.2. Cookies are retained for a reasonable period necessary for the purpose for which they are processed, taking into account the limitation periods set out in the legislation. Session cookies are irreversibly deleted when the browser is closed, and persistent cookies when the purpose of use ends, their maximum validity period expires or the Data Subject withdraws consent, in accordance with the Regulation on the Deletion, Destruction or Anonymisation of Personal Data, or are destroyed or anonymised.
6. Managing Cookies Through Browser Settings
Data Subjects can completely block or delete the cookies stored on their devices by changing their browser settings. The cookie management guides of common browsers are available at the following links:
- Google Chrome: https://support.google.com/chrome/answer/95647
- Mozilla Firefox: https://support.mozilla.org/tr/kb/cerezleri-silme-ve-engelleme
- Apple Safari: https://support.apple.com/tr-tr/guide/safari/sfri11471/mac
- Microsoft Edge: https://support.microsoft.com/tr-tr/microsoft-edge/tan%C4%B1mlama-bilgilerini-silme-63947406-40ac-c3b8-57b9-2a946a29ae09
- Google Analytics Opt-Out: https://tools.google.com/dlpage/gaoptout
7. Rights of the Data Subject and Application Procedure
7.1. Under Article 11 of KVKK, Data Subjects have the right to learn whether their personal data is processed, request information if it has been processed, learn the purpose of processing and whether it is used in line with that purpose, know the third parties to whom their personal data is transferred in Türkiye or abroad, request correction if the data is incomplete or inaccurately processed, request its deletion or destruction, and claim compensation if they suffer loss due to unlawful processing.
7.2. Applications may be submitted in writing or electronically through our Company’s data controller contact channels (company physical address, KEP address or the email address registered in our system), in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller.
7.3. Data Subject applications are concluded effectively, with reasons and lawfully, as soon as possible depending on their nature and at the latest within 30 (thirty) days, and notified to the applicant.
8. Entry into Force of the Policy and Amendments
8.1. This Policy enters into force on the date it is published on our website.
8.2. Our Company reserves the right to amend the provisions of the Policy in line with changes in legislation, Board decisions or updates to data processing processes. Amendments take effect when the updated text is published on the Site and, where necessary, the consent mechanism for cookie preferences is presented to the Data Subject again.
8.3. Even if this Policy is prepared in more than one language other than Turkish, the Turkish text prevails in the event of any difference in interpretation or meaning between the texts.
8.4. For detailed information on the processing of your personal data, please review the KVKK Privacy Notice on our website.