Privacy Statement

The principles followed by HACI ÖMER SABANCI HOLDİNG ANONİM ŞİRKETİ (“Sabancı 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

Sabancı 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.

Cookie Applications
Regarding the processing of your personal data obtained automatically through the placement of cookies used on the Website on your device, you can find information below about what types of cookies we use for what purposes and how you can manage these cookies.

What is a Cookie?
A cookie is a small text file that is saved on your computer or mobile device through your browser when you visit a website. Cookies allow a website to work more efficiently, as well as to provide personalized pages in order to provide a faster and more suitable visit experience for your personal needs. Cookies only contain information about your visit history on the internet and do not collect any information about the files stored on your computer or mobile device.

Types of Cookies Used on the Website, Purposes of Use and Reasons for Legality

• Types of cookies according to the duration of use: Our website uses session cookies and persistent cookies according to the duration of use. Session cookies are used to ensure the continuity of the session and these cookies are also deleted when you close your browser. Persistent cookies, on the other hand, are not deleted when you close your internet browser and are automatically deleted on a certain date or after a certain period of time.
• First-party and third-party cookies: Whether the cookie is first-party or third-party varies according to the cookie placed by the Website or domain. First-party cookies are placed directly by the Website you visit, i.e. the internet address shown in the address bar of the browser. Third-party cookies are placed by a domain different from the Website you visit. Third party cookies are not used on the Website.
• Types of cookies according to their intended use: Mandatory cookies are used on the Website according to the purpose of use. These cookies are cookies that are necessary for the Website to function. These cookies are first-party cookies and process personal data during the session (except for cookies regarding your privacy preferences, as these cookies last longer than the session duration) and are automatically deleted when the session ends. These cookies are used compulsorily in order to fulfill an information society service you have requested (log-in, form filling and remembering privacy preferences). In addition, the cookie for performance and analytical purposes allows counting visitors and measuring traffic on our website and is first-party. In this way, we are able to measure and improve the performance of our website. These cookies help us understand which pages on our website are the most popular and which pages are the least popular.

Your personal data collected through these cookies are processed within the scope of subparagraph (c) of paragraph (2) of Article 5 of the Law "Provided that it is directly related to the establishment or performance of a contract, it is necessary to process personal data belonging to 51 parties of the contract" or subparagraph (f) "Provided that it does not harm the fundamental rights and freedoms of the person concerned, it is mandatory to process data for the legitimate interests of the data controller".

Cookie Type, Purpose, Type and Storage Period

How can you control cookies?
You can change your preferences regarding cookies at any time by clicking the icon on the Website. Turn the buttons on the cookie management panel on or off according to your preference and click the "Save settings" button. Refresh the page to make your settings active.
In addition, partial control can also be provided through browser settings. You can access information on the management of cookies in frequently used browsers via the links below:

• Google Chrome : https://support.google.com/accounts/ answer/61416?co=GENIE.Platform%3DDesktop&hl=en
• Mozilla Firefox: https://support.mozilla.org/tr/kb/masaustufirefox-surumunde-gelismis-izlenme-koruma
• Safari: https://help.apple.com/safari/mac/9.0/#/sfri40732
• Opera: https://help.opera.com/en/latest/web-preferences/

Purpose of Use of Data

Sabancı 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 Sabancı 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 Sabancı 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, Sabancı 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 Sabancı 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 Sabancı Holding provided that such interest does not harm the fundamental rights and freedom of the User.

Sharing the Data

Sabancı 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 Sabancı 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 Sabancı Holding services, and realizing any of the objectives set forth under this Privacy Policy or other privacy notes provided to the User, Sabancı 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 Sabancı 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 Sabancı Holding by filling out the Data Subject Request Form and sending the form to Sabancı Holding by following the procedure explained in the form. Sabancı 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 Sabancı 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. Sabancı 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 Sabancı Holding in case he/she makes a request that will prevent Sabancı 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

Sabancı 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, Sabancı Holding may keep the personal data, in case a conflict arises between Sabancı 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, Sabancı 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, Sabancı Holding shall not be held liable for the privacy policies and contents of such applications.

Sabancı 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. Sabancı 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.