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1) Privacy Policy website (belongs to Nilgün Bodur) regarding this Personal Data Protection and Processing Policy (“Policy”) and the terms of use of the website; Regardless of whether they send or provide material such as information, images, videos, pictures, photographs to the Web Site, it is in principle to the User by informing the Web Site users who are natural persons, legal entities and/or institutions and organizations visiting the Web Site. aims to protect the confidentiality of information about
The protection of your personal data that you share with us in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) and the use of this information in accordance with KVKK are among our top priorities. That is why we would like to explain to you in more detail the processing of personal data and your rights in this regard.

2) Personal Data That Can Be Collected website, depending on the wishes of the Users, the User's identity information, contact information such as e-mail address, telephone number, which may be necessary for the performance of the services subject to the Website and which are considered personal data in accordance with the KVKK and all relevant legislation. may collect other information. The user expressly consents to the processing of the data he may share with the website, at his own request, within the scope specified in this Policy, for the stated purposes.
Pursuant to KVKK, your personal data is only within the framework explained below; will be processed, recorded, stored, updated and shared with third parties where permitted by the legislation.

3) For What Purpose Personal Data Will Be Processed

Ensuring the legal and commercial security of people who have a business relationship with the website; website, ensuring the execution of human resources processes; For the purposes of determining and implementing the commercial and business strategies of the website, personal data will be processed within the terms and purposes of processing specified in Articles 5 and 6 of the KVKK.

4) Transfer of Your Personal Data

The website will also be able to process and share personal data with third parties without obtaining the User's separate consent, in accordance with Articles 5 and 8 of the KVKK and/or in case of exceptions in the relevant legislation. The main of these situations are listed below:

clearly stipulated in the law,
It is compulsory for the protection of the life or physical integrity of the person or another person, who is unable to express his consent due to actual impossibility or whose consent is not given legal validity,
It is necessary to process personal data, provided that it is directly related to the establishment or performance of any contract between the user and the website,
It is compulsory for the fulfillment of legal obligations,
Being made public by the user himself,
Data processing is mandatory for the establishment, exercise or protection of a right,
Data processing is mandatory for the legitimate interests of the website, provided that it does not harm the fundamental rights and freedoms of the user.
We may share your personal data with the parties whose services we cooperate with, outsourcing service providers and our shareholders, directly or indirectly with our domestic/foreign affiliates in order to perform the services we provide to you.
These parties listed above will be able to store your personal data on their servers located anywhere in the world, provided that they meet the conditions for the transfer of personal data abroad, which are listed in Article 9 of the KVKK.
All your personal data that you have shared with us will be kept confidential in the database on the website, in accordance with Article 12 of the KVKK, and will not be shared with third parties for commercial purposes.

5) Transfer of Personal Data Abroad

The website is intended for use only in foreign countries where personal data is declared to have adequate protection by the Personal Data Protection Board, or in the absence of sufficient protection, where data controllers in Turkey and the relevant foreign country undertake in writing to provide adequate protection, and the Personal Data Protection Board It can be transferred to foreign countries where permission is granted.

6) Measures Regarding the Protection of Personal Data

The website undertakes to keep your personal data confidential, to take all necessary technical and administrative measures and to show due diligence to ensure confidentiality and security, in accordance with Article 12 of the KVKK.
The website takes hashtags, encryption, transaction logs, access management and physical security measures to ensure that information systems containing personal data are protected against unauthorized access and illegal data processing.
Despite the fact that the website has taken the necessary information security measures, in the event that personal data is damaged or in the hands of third parties as a result of attacks on the website and the system, ETİCARET MERKEZİ A.Ş. will immediately report this situation to you and the Personal Data Protection Board. reports.

7) Rights of Personal Data Owner

As personal data owners, if you submit your requests regarding your rights to ETİCARET MERKEZİ A.Ş., using the methods set out below in this Procedure, our Company will conclude the request free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transactions require a cost, it is possible to charge a fee based on the tariff determined in accordance with Article 13 of the KVKK by the Personal Data Protection Board. In this context, personal data owners;

Learning whether personal data is processed or not,
If personal data has been processed, requesting information about it,
Learning the purpose of processing personal data and whether they are used in accordance with its purpose,
Knowing the third parties to whom personal data is transferred at home or abroad,
Requesting correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
Requesting the deletion or destruction of personal data in the event that the reasons requiring its processing have disappeared, although it has been processed in accordance with the provisions of the KVKK and other relevant laws, and requesting the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
In the event that personal data is damaged due to unlawful processing, it has the right to demand the compensation of the damage.
Pursuant to paragraph 1 of Article 13 of the KVKK, you must submit your request to exercise your above-mentioned rights to our Company in “written” or by other methods determined by the Personal Data Protection Board.
In order to exercise your above-mentioned rights, you can send your request by means of a registered mail to the address below, stating which of your rights is related to the exercise of your right specified in Article 11 of the KVKK, together with the necessary information identifying your identity and your explanations about the right you want to use.
Data Controller, whom you can apply within the scope of KVVK provisions:
Nilgun Bodur, owner of the 

8) Cookie

Cookies, which can be defined as small data files saved on your computer during your visit to the Website, are used on the Internet. Cookies are small text files that are sent to and stored on a user's computer in order to allow web pages to recognize regular users and facilitate their access to the site, and to allow sites to collect and compile aggregate data in order to improve and develop their content.
Cookies used on the Website do not store or disclose the User's personal information. In addition, the information transmitted through cookies is not used for any promotional or marketing purposes. The website monitors the usage patterns of the Website in order to increase the usefulness and effectiveness of the Website through cookies. Information obtained through cookies will not be sold and/or shared with third parties. The user can delete the previously installed cookies by making the necessary settings in the internet browser he is using, block the cookies that will be loaded in the future, or have the browser warn the User during the loading of the cookies. However, we would like to point out that these cookies may be necessary for the Website to work properly and to perform certain functions.


9) Deletion, Destruction or Anonymization of Your Personal Data

Your personal data processed for the purposes specified in this Policy; It is deleted, destroyed or anonymized and continued to be used by us when the purpose that requires it to be processed in paragraph 1 of Article 7 of the KVKK disappears and after the periods determined by the Laws according to Article 82 of the Turkish Commercial Code No. 6102 and Article 138 of the Turkish Penal Code.

10) Registration in the Data Controllers Registry

Before starting data processing, the website must be registered with the Data Controllers Registry within the period to be determined and announced by the Personal Data Protection Board.
The following information must be submitted in the application for registration with the Data Controllers Registry:

Identity and address information of website as data controller and its representative, if any.
The purpose for which personal data will be processed.
Descriptions of the data subject group and groups of persons and their data categories.
Recipient or groups of recipients to whom personal data can be transferred.
Personal data intended to be transferred to foreign countries.
Measures taken regarding personal data security.
The maximum period required for the purpose for which personal data is processed.
In case of a change in the information presented in the registration notification, the said changes are immediately notified to the Personal Data Protection Authority.

11) Changes in the Policy

Those who benefit from the services offered on the Website are deemed to have read and accepted all these terms. website reserves the right to change the provisions of this Policy without prior notice. This Policy has entered into force as of 25.10.2018. In case of a change in the Policy, the Policy becomes effective on the date it is presented to the User by any means.
This document has been prepared to inform company website users, investors, customers and suppliers in accordance with KVKK.



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