Cookie Policy

The principles followed by ORTADOĞU HOLDİNG A.Ş. (“Ortadoğu Holding”) while collecting and using personal data obtained from the users (“User(s)”) within their consent through the website (“Website”) are regulated under this Privacy Policy.

Personal Data That May Be Collected

Ortadoğu Holding may collect the following data about the User:

• • ID
• • Transaction Security Information
• • IP
• • Legal and Compliance Information
• • Contact Information
• • Request/Complaint Management Information
• • User Information
• • Incident Management Information
• • User Transaction Information

and other information that may be required for the performance of services in relation to the Website and that are deemed as personal data pursuant the Law on the Protection of Personal Data and all other applicable legislation. User explicitly consents to processing of such data within the scope and purpose specified under this Privacy Policy.

Pursuant to Article 3 and 7 of the Law on the Protection of Personal Data, data that are irrevocably anonymized shall not be deemed as personal data according to said provisions, and processing activities with regard to such data shall be realized notwithstanding the provisions of this Privacy Policy.

Use of Cookies

Ortadoğu Holding, automatically collects information regarding the visited sections and clicked areas by the Users during their use of the Website. Such data obtained by using “Cookie” technology are statistical information. The purpose of this technology is to ensure that Users can easily access the content of the sections they visit from the very first visit made to the Website. Most of the browsers are designed to initially enable such “cookies” that are files of technical communication; however, Users, if they wish, may change the browser settings at any time in order not to receive technical communication files or so that a warning will be placed when the technical communication files are sent.

For the purposes of online behavioural advertising and marketing, Ortadoğu Holding is entitled to associate Users’ behaviour on the Website via a “cookie” placed in the browser and configure remarketing listings based on metrics such as number of page views, duration of visit and target completion numbers. Furthermore, Users may be displayed target-specific advertising content based on their area of interest on the Website or other sites in the visual advertisement network.

Purpose of Use of Data

Ortadoğu Holding shall use the collected personal data in order for the User to benefit from the Website, to conclude its membership registration to the Website as the case may be, to enhance and develop the services provided, to introduce new services and notify the Users of the new services, to make the necessary notifications in this regard, to contact the User and to perform the obligations arising from the nature of the services provided.

Personal data in question may be processed within the scope of Ortadoğu Holding’s reporting and business development activities, and may be used for the purposes of making various statistical assessments, forming a database and engaging in market researches without disclosing the User’s identity. In case the User gives a separate explicit consent, information in question may be processed, stored, transferred to third parties for the purposes of direct marketing by Ortadoğu Holding and the parties it is in cooperation with within the scope of such consent, and the User may be contacted for the purposes of promoting certain application, goods and services and making notifications with regard to the maintenance and support activities by using such information.

Pursuant to Articles 5 and 8 of the Law on the Protection of Personal Data and/or to the extent the exceptions set forth under the applicable legislation allow it, Ortadoğu Holding may process and share personal data with third parties without obtaining the User’s consent in the following cases, which are non-exhaustive:

• • Processing is specifically provided for under the laws,
• • Processing is necessary to protect the vital interests or bodily integrity of the data subject or a third person if the data subject is not in a condition to express his/her consent due to actual impossibility,
• • Processing is necessary for execution or performance of a contract between User and Ortadoğu Holding,
• • Processing is necessary for compliance with legal obligations,
• • Personal data has been made public by the User itself,
• • Processing is necessary for the establishment, exercise or protection of a right,
• • Processing is necessary for the purpose of the legitimate interests pursued by Ortadoğu Holding provided that such interest does not harm the fundamental rights and freedom of the User.

Sharing the Data

Ortadoğu Holding may transfer User’s personal data and new data generated by using such personal data within the scope of the Website, for the purpose of enabling the performance of the services provided to the User, to third parties providing service to Ortadoğu Holding provided that such transfer is limited to the purpose of the provision of such services. In this regard, for the purposes of improving User experience (including enhancing and customization), ensuring the security of the User, identifying fraudulent or unauthorized use, operational evaluation research, recovery of errors in relation to the Website or Ortadoğu Holding services, and realizing any of the objectives set forth under this Privacy Policy or other privacy notes provided to the User, Ortadoğu Holding may share the User data with third parties such as outsource service providers, hosting service providers, law firms, research companies and call centers.

User agrees in advance that aforementioned third parties may store the User’s personal data in the servers located in any part of the world, limited to the aforementioned purposes.

Right of Access of the User to the Personal Data and Rectification Requests

By applying to Ortadoğu Holding the User is entitled to:

• Learn whether or not personal data relating to him/her are being processed,
• Request further information if personal data relating to him/her have been processed,
• Learn the purpose of the processing of personal data and whether or not personal data are being processed in compliance with such purpose,
• Learn the third party recipients to whom the personal data are disclosed within the country or abroad,
• Request rectification of the processed personal data which is incomplete or inaccurate,
• Request erasure or destruction of data in accordance with the terms set forth under the relevant legislation,
• Request notifying the third persons to whom the personal data are disclosed, about the rectification, erasure or destruction processes made in accordance with the relevant legislation,
• Object to negative consequences about him/her that are concluded as a result of analysis of the processed personal data by solely automatic means,
• Demand compensation for the damages he/she has suffered as a result of an unlawful processing operation.

The User can apply to Ortadoğu Holding by filling out the Data Subject Request Form and sending the form to Ortadoğu Holding by following the procedure explained in the form. Ortadoğu Holding may give its reasoned affirmative/negative response with regard to the above listed requests, in written form or digitally. As a general rule, the actions undertaken in order to answer the requests are free of charge. However, in case the actions require a cost, a fee may be charged pursuant to the tariff specified by the Data Protection Authority pursuant to Article 13 of the Law on the Protection of Personal Data.

The User undertakes that information provided to Ortadoğu Holding by himself/herself under this Privacy Policy is complete, accurate and up to date, and shall immediately update such information in case a change occurs with respect to such information. Ortadoğu Holding shall not be held responsible in case the User does not update such information.

User agrees and represent that he/she may not fully benefit from the services undertaken by Ortadoğu Holding in case he/she makes a request that will prevent Ortadoğu Holding from using any of its personal data and he/she shall be held liable for any matter arising in this regard.

Storage Period of Personal Data

Ortadoğu Holding shall keep the personal data provided by the User for the purposes of performing the obligations arising from the nature of the services, during the entire time of the provision of the services.

Additionally, Ortadoğu Holding may keep the personal data, in case a conflict arises between Ortadoğu Holding and the User, limited to the purpose of making the necessary defences within the scope of the conflict and for the period of time limitation specified by the applicable legislation.

Measures, Warranties and Liability with respect to Data Security

Subject to the terms set forth under the applicable legislation or this Privacy Policy, Ortadoğu Holding undertakes to:

• • Prevent the unlawful processing of personal data,
• • Prevent the unlawful access to personal data,
• • Take necessary technical and administrative measures for ensuring the appropriate security level for the purposes of preserving personal data and to carry out the required audits.

In case the website provides links to other applications, Ortadoğu Holding shall not be held liable for the privacy policies and contents of such applications.

Ortadoğu Holding cannot be held liable for damages that may arise from any use of personal data which falls within the scope of the abovementioned terms.

Amendments to the Privacy Policy

Users benefiting from the services provided on the Website shall be deemed to have read and accepted all terms herein. Ortadoğu Holding reserves the right to amend the provisions of the Privacy Policy without prior notice. The updated Privacy Policy shall become effective on the date it is presented to the User in any manner.