KVKK

This statement provides you with detailed information about activities related to the processing of personal data on the website of Edag Turkey within the scope of Law 6698 Regarding the Protection of Personal Data.

1. Collecting Log Records
   
   Purposes for which the personal data will be used
   Personal data of website users shall be processed and saved to the degree that it is necessary for the full functionality of this channel, the channel content and the services provided by means of this channel.
   
   Data that is recorded during a visit to the website including the IP address shall be made anonymous and used in order to conduct analysis activities and improve and optimize the website, as well as to ensure the security of the information technology systems. Data is not used for marketing purposes. The aforementioned reasons for processing data are limited to the justification that “the processing of data is obligatory for the legal interests of the data controller and other parties, with the condition that no harm is caused to the fundamental rights and freedoms of the person in question.”
   
   Personal data is also processed in order to carry out the procedures stated in the contract, including the establishment of the contract, and to fulfill contractual obligations.
   
   When the purpose for processing personal data ceases to exist, personal data shall only be stored for the storage duration specified by Turkish law, European Law and other national laws to which EDAG Turkey’s stakeholders are subject.
   
   To whom and for what purpose personal data may be transferred
   Log records shall not be transferred to third parties.
   
   Method and legal basis for collecting personal data
   Data and information is automatically collected from any computer system that contacts this website every time this website is accessed, in accordance with the purposes stated above regarding personal data. The data that is gathered is as follows:
   
   (1)    User’s IP address
   (2)    Date and time of access
   (3)    The website that was visited
   (4)    The amount of data sent in bytes
   (5)    The source/connection that was accessed on the website
   (6)    The browser that was used
   (7)    The operating system that was used
   
   Log records of these data shall be stored on the Edag system. No other log record shall be kept regarding the user’s personal data.
   
   Personal data shall be processed in accordance with the legal justifications specified in article 5 of Law 6698 and in accordance with other legal regulations regarding the protection of personal data. The legal justifications for processing personal data are as follows:
   “It is necessary to process personal data belonging to the parties of a contract, with the condition that it is directly related to establishing or executing the contract”, “It is obligatory for the data controller to fulfill a legal obligation”, “The processing of data is obligatory for the legal interests of the data controller and other parties, with the condition that no harm is caused to the fundamental rights and freedoms of the person in question”  and clear consent is obtained from the persons in question in cases where these reasons do not exist.
    
2. Collecting Cookie Records
   
   Description and extent of data processing
   Our website makes use of cookies. Cookies are text files stored on the user's computer system in or by the Internet browser. If a user accesses a website, a cookie can be stored on the user's operating system. This cookie contains a characteristic character string that enables the browser to be clearly identified the next time the website is accessed.
   
   We use cookies to make our website more user-friendly. Some elements of our website require the accessing browser to be identified if the user changes from one page to another.
   
   The following data is stored and transmitted in the cookies:
   
   (1)   User’s IP address
   (2)   Date and time of access
   (3)   Login information
   (4)   The amount of data transferred
   (5)   Enquiring domain
   
   On our website, we also use cookies which make it possible to analyse the user's surfing habits.
   
   The following data are transmitted in this way:
   
   (1) Equipment type, model, brand, screen resolution
   (2) Operating system, versions, families
   (3) Browser, version, configuration, engines, plugins, language, language code
   (4) Location data
   (5) Provider details
   (6) Pages per visit, number of visits, repeat visits, time of visit, date of visit
   (7) Entry pages, exit pages, page URL, title of page, search items, downloads
   (8) Search engines, search item, websites, social networks
   (9) Campaigns, campaign key word
   
   When accessing our website, the user is informed that functional cookies are used, as are cookies for analysis and marketing purposes, and a Cookie Consent Manager is used to obtain his or her consent to the processing of the personal data used in this respect. Information regarding this data privacy statement is also issued in this context.
   
   Detailed information on how the individual cookies work, information on how long they function and details of whether third parties have access to these cookies can also be found in the Cookie Consent Manager. You can access the Cookie Consent Manager any time by clicking the corresponding button in the footer of our website.
   
   Legal basis for data processing
   The legal basis for the processing of personal data using technically necessary cookies is KVKK Art. 5/2-f.
   
   The legal basis for the processing of personal data using functional cookies and cookies for analysis and marketing purposes is KVKK Art. 5/1 along with the analogous provisions in accordance with the applicable data protection legislation.
   
   Purpose of data processing
   Depending on their intended use and function, we divide cookies into the following categories: 
   
   a) Technically  necessary cookies
   Technically necessary cookies guarantee functions without which our website cannot be be put to its intended use. These cookies are used exclusively by us, i.e. they are first party cookies. This means that all information stored in the cookies is returned to our website. Technically necessary cookies are used, for example, to ensure that users who have logged in always remain logged in when accessing various sub-pages of our website, and so do not have to re-enter login data every time they access a new page.
   
   It is possible and permissible to use technically necessary cookies on our website without first obtaining consent. For this reason, individual technically necessary cookies cannot be activated or deactivated. These purposes are also in our legitimate interests in the processing of personal data under KVKK Art. 5/2-f. Our interest in ensuring the unobstructed provision of our website and the services it offers prevails.
   
   b)    Functional cookies
   Functional cookies enable our website to store information that has already been input (such as registered name, language selection or a user's location) and, on the basis of this information, offer improved and more personalised functions. The way in which these cookies collect and store data ensures that user behaviour on other websites cannot be tracked.
   
   c)    Performance cookies
   In order to improve the website's attractiveness, content and functionality, performance cookies collect aggregated information about how it is used. These cookies help us to determine whether, how often and how long which website subpages are visited and what content is of particular interest to users. 
   These cookies do not store any information that would allow the user to be identified. The information collected is aggregated, and does not allow us to directly identify the individual. The only purpose it serves is to compile statistics in order to better tailor the content of our website to the needs of our users, to improve user experience, and to optimise our range of services.
   
   d)    Marketing cookies
   Marketing cookies come from external advertising companies (third party cookies) and are used to collect information about the websites visited by the user, to create targeted advertising for the user, and to display advertisements based on the user's interests. They are also used to limit the frequency with which an advertisement appears, and to measure the effectiveness of advertising campaigns. This information may be shared with third parties, advertisers for instance.
   
   Storage duration, right to object and right of elimination
   Cookies are stored on the user's computer, from which they are transmitted to our website. As the user, you therefore have complete control over the use of cookies. 
   Even if you have consented to the use of cookies, you can revoke your consent at any time, with future effect. Please use one of the following options to do this:
   •  You can inform us that you wish to withdraw your consent or change your settings in our Cookie Consent Manager, which can be accessed at any time via the website.
   •  You can prevent cookies from being stored by adjusting your browser software accordingly; we would, however, like to draw your attention to the fact that if you do so, this might possibly result in your not being able to use all the functions offered on this website to the full.
   •  Cookies which have already been stored can be removed from your settings at any time. This can also be done automatically.
   •  Further, you can prevent the collection of data generated by the cookie and relating to your use of our websites (including your IP address) to Google and the processing of this data by downloading and installing the plug-in available for your browser.
   •  You can also use the tools developed as part of self-regulation programs in many countries, e.g. www.aboutads.info/choices/ (USA) or www.youronlinechoices.com/uk/your-ad-choices (EU), to manage marketing cookies.
    
3. E-Mail Communication
   
   Purposes for which the personal data will be used
   E-mail addresses and the personal data they contain are only processed in order to establish communication. When it is evident that the relevant issue has been resolved, the communication is considered to have ended and it shall be deleted because the purpose for processing data has ceased to exist.
   
   To whom and for what purpose personal data may be transferred
   Personal data communicated via e-mail cannot be revealed to third parties.
   
   Method and legal basis for collecting personal data
   Personal data communicated by the user via e-mail is stored. Such data is processed according to the justification that “the processing of data is obligatory for the legal interests of the data controller and other parties, with the condition that no harm is caused to the fundamental rights and freedoms of the person in question.” If the purpose of the communication is to establish a contract, personal data is also processed with the justification that “It is necessary to process personal data belonging to the parties of a contract, with the condition that it is directly related to establishing or executing the contract.”
4. Web Monitoring
   
   Purposes for which the personal data will be used
   This website that you are visiting uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). By enabling the analysis of a user’s activities on different devices, it is possible to associate a user nickname with data, logins and interaction on more than one device.
   
   It uses cookie data on behalf of the website owner in order to evaluate the use of this website, to compile reports about the website’s activities, and to develop other services for the website owner related to the use of the website and the Internet.
   
   The goal of using the web analysis service is to analyze the use of the website and to implement regular improvements. The statistics that are gathered makes it possible for us to improve our services and make them more attractive for users.
   
   To whom and for what purpose personal data may be transferred
   As a rule, information about your use of the website that is created and stored in cookies is transmitted to Google servers in the USA. If IP address anonymization has been activated for this website, Google leaves your IP address at the border of European Union member states and the border of other states that are party to the Agreement on the European Economic Area.
   
   For exceptions in which personal data is transmitted to the U.S., see the EU-U.S. Privacy Shield at https://www.privacyshield.gov/EU-US-Framework or the Swiss-U.S. Privacy Shield at https://www.privacyshield.gov/welcome.
   
   In the event that you do not disable cookie data, your data over which you have control will be transmitted outside of the country.
   
   Method and legal basis for collecting personal data
   This website that you are visiting uses Google Analytics, a web analysis service provided by Google Inc. (“Google”). This usage includes the Universal Analytics mode. By enabling the analysis of a user’s activities on different devices, it is possible to associate a user nickname with data, logins and interaction on more than one device.
   
   Google Analytics uses the cookies stored on your computer and makes it possible to analyze website usage.
   
   In order to achieve the aforementioned goals, the following data that are relevant to the user are processed:
   
   (1)      User’s IP address
   (2)      Date and time of access
   (3)      Login data
   (4)      The amount of data transferred
   (5)      The domain name that was queried
   (6)      Type of hardware and its model, brand and screen resolution
   (8)     Operating system and its version and family
   (9)     Location data
   (10)   Details about the service provider
   (11)   Sites visited, number of visits, duration and date
   (12)   Landing pages, exit pages, page URLs, page heading, search elements and downloads
   (13)   Search engines, search elements, websites and social networks
   (14)    Promotions and promotion keywords
   
   Data sent by Google and data related to cookies, user identity verification or advertising identities are deleted after 14 months. According to Google, data that has reached the end of its storage time limit are automatically deleted once per month. We would like to draw attention to the fact that we have no control over how long data is stored by Google.
   
   You can adjust your browser to prevent cookies from being stored, but disabling cookies may cause you to not be able to take full advantage of all the functionality presented on this website.
   
   Furthermore, you can prevent Google from obtaining and using data that is created by cookies and related to website usage (including your IP address) by downloading and installing the browser plugin on this link: https://tools.google.com/dlpage/gaoptout?hl=en.
   
   Disabling cookies prevents your data from being obtained when you visit this website. In order to prevent Universal Analytics from obtaining data from multiple devices, you need to activate an exclusion for all systems being used. To disable cookies, click here: https://tools.google.com/dlpage/gaoptout?hl=en&text=deaktivate_google_analytics
   
   This website uses the "_anonymizeIp()" function of Google Analytics. This ensures that IP addresses are used in a truncated fashion, which makes it impossible to track a specific user. If there is a possibility that a direct personal connection would be created to the data that is gathered about you, it is immediately prevented, and personal data is thereby immediately deleted.
   
   We also use Google Tag Manager. Google Tag Manager is a solution that enables marketers to manage their website tags with a single interface. The Tag Manager tool, which applies tags, is an area that does not involve cookies and does not collect any personal data. The tool triggers other tags that can collect data themselves under certain conditions, but Google Tag Manager does not access that data. If deactivation is carried out at the domain name or cookie level, all tracking tags implemented by Google Tag Manager will remain invalid. You can access more information here: http://www.google.de/tagmanager/use-policy.html
   
   To disable data collection by Google Tag Manager, click here.
   
   Web monitoring has been activated / deactivated on this page. Deactivate Now / Activate Now

The use of Google Analytics is carried out based on the legal justification that the person in question has clearly provided consent.

OTHER RIGHTS AFFORDED BY LAW 6698 TO THE PERSON IN QUESTION
The persons in question can always exercise their rights that are described in article 11 of Law 6698.

Version: June 2020