Clarification Text & Cookie Policy within the scope of Protection of Personal Data Law (KVKK)

KVKK CLARIFICATION TEXT

Pursuant to the Law on Protection of Personal Data no. 6698 (“KVKK”), we, the undersigned, as Sodrugestvo Turkey Tarım Taşımacılık İthalat İhracat Tic. A.Ş. acting as Data Responsible for the purposes hereof, hereby declare that your personal data and information will be recorded, kept, and, and may be disclosed/transferred to third parties, or be classified, and be processed as otherwise as specified in (KVKK), if and to the extent permitted by the applicable laws, and within the frame described here below.

This information text consists of;

Personal Data: Any information relating to a specific or identifiable natural person,
Law on Protection of Personal Data (“KVKK”): Law No. 6698 on the Protection of Personal Data published in the Official newspaper of Turkish Republic on the date of 07.04.2016
Data responsible: The natural or legal entity who determines the purposes and means of processing the personal data and who is problematic from the establishment and management of the data recording system,
Data Processor: Expresses the natural or legal entity who process the Personal data on his behalf based on the authority granted by the Data responsible.


Data responsible:
According to KVKK, addressee, supplier, customer, employee, trainee, visitor etc. Your personal data that you share with the adjectives is determined by Sodrugestvo Turkey Tarım Taşımacılık İthalat İhracat Tic. A.Ş. will be evaluated by the legal entity within the scope specified below.


1. Collection, Processing and Business Purposes of Personal Data
Your personal data may vary depending on the relationship between you and our Company; Our Company may collect through oral, written or electronic means by means of automated or non-automated methods, units, website, social media channels, mobile applications and written, oral or electronic ways with similar means. Your personal data will be created and updated as long as your relationship with our Company continues.

Your personal data are collected by the relevant business units, the legal and commercial security of the Company and our business relations with the Company, the determination and implementation of our Company's strategies and the execution of the human resources policies of our Company. In accordance with the KVKK Article No. 5. and 6. personal data processing requirements and purposes,

In accordance with the rules of law and integrity,
Accurate and up-to-date,
For specific, clear and legitimate purposes,
Linked to the purpose of the process, limited and measured
to be kept for the period stipulated in the relevant legislation or for the purpose for which they were processed
It will be processed in accordance with the rules mentioned above .


2. To whom and to what purpose the personal data would be processed:
Your personal data collected; In order to ensure the legal and commercial security of the Company and the business relations of the Company and the business and business strategies of our Company and your Company, we shall provide our business partners, suppliers, legally authorized public institutions and private individuals in accordance with the personal data processing requirements and objectives specified in Articles No. 8 and 9 of the KVKK.


3. Method and the legal reason of collecting personal data:
Your personal data, all kinds of verbal, written or electronic media/environment, in accordance with the above mentioned purposes to offer our services within the scope of our company's contract and the liability of the law fully and accurately acquired in order to be fulfilled. Your personal data collected for this legal reason may be processed and transferred for the purposes specified in articles (1) and (2) of this text in accordance with the personal data processing requirements and purposes set out in Articles 5 and 6 of the (“KVKK”) Law.


4. Your rights arising out of article 11 of KVKK:
As personal data holders, if you submit your requests for your rights to our Company by the methods set out below, our Company will finalize it free of charge within 30 days at the latest. However, if a fee is stipulated by the Personal Data Protection Board, the fee set by our Company will be charged. In this context,

You have the right to apply to our Company and

to learn whether your personal data and information are processed or not, and
if processed, to request information in connection therewith, and
to learn the purpose of processing and whether such data are used for the intended purposes or not, and
to learn the identity of third parties who received such data at home or at abroad, and
if your data are under processed or misprocessed, to demand correction of them, and
to demand deletion/destruction of such data under the conditions specified in Article 7 of KVKK, and
to request notification of transactions effected pursuant to subparagraphs (f) and (e) hereinabove to persons to whom the data are transferred, and
to object against a result obtained in disfavor of you due to analysis of such data solely via automatic systems, and
if you incur damages due to processing of your data in violation of the laws, to demand indemnification of your damages. Your rights arising out of this Article will enter into force

Pursuant to Article 13 (1) of the Law, you may submit your request for using your rights mentioned above, in written or personal data, through other methods determined by the Protection Board. Since the Personal Data Protection Board does not specify any method at this stage, you must submit your application in writing to our Company in accordance with the CMLP. In this context, the channels and procedures in which you will submit your application in writing to our Company within the scope of Article 11 of the KVKK are described below.

Your request, including your right to use your rights and the information required to identify your identity and use the rights specified in Article 11 of the KVKK, in a clear and comprehensible manner, including the identification and documentation of the identification and address information. You must send it to g.yetim@sodru.com or Suadiye Mahallesi Bağdat Caddesi No:461 Daire:10 Kat:4 34744 Kadıköy / İstanbul by mail or notary, written and wet signed by hand.
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COOKIE POLICY WITHIN THE SCOPE OF KVKK

Sodrugestvo Turkey Tarım Taşımacılık İthalat İhracat Tic. A.Ş. (“ Company”), owns small data files that allow users to save and collect certain data to their computers, mobile phones, tablets or other devices used during the access to the websites, electronic platforms, applications or e-mail messages or advertisements sent by the Company. These data files placed on computers and other devices may be cookies, pixel tags, flash cookies and web beacons, as well as other similar technologies for data storage. “Cookie” term is used to refer to cookies and similar technologies that may be used by the Company in this Policy. Although it is possible to collect personal data through cookies, any data collected through cookies may not be personal data. For this reason, it should be taken into consideration that the data obtained through cookies will only be considered within the scope of this Law and the Protection of Personal Data Act (KVKK) to the extent that they constitute personal data under Turkish law.

1- Types of Cookies
Cookies can be classified by time or by the domain name they belong to, Cookies are divided into session cookies and permanent cookies if they are classified in time. Session cookies are cookies that are deleted when the user closes the browser, while persistent cookies are cookies left on the user's computer / device for a predetermined period of time. In the event that cookies are classified according to the domain they belong to, they are divided into related party cookie and third party cookie. Cookies are placed by the visited area are called related party cookies, while cookies are placed by a different area visited are referred to as third party cookies. A third party cookie is available if people outside the visited area place cookies on the user's device over the visited area.

2- Usage Purpose of Cookies
The Company may use the cookies in its websites, platforms, applications, advertisements and messages for the purposes stated below.

Usage of Operational Purpose: We may use cookies that we deem necessary for the administration and security of the Company's website, platforms, applications and services. Examples of cookies used for operational purposes include technologies that enable the use of the functions on the website, applications and platforms, and cookies used to detect irregular behavior in these channels

a. Usage for Functionality: The Company may use cookies to facilitate the use of its website, platforms, applications and services and to customize it for users. Examples of technologies that enable us to remember user information and preferences are cookies that use functionality.

b. Performance oriented Usage: The Company may use cookies in order to increase and measure the performance of the Company's website, applications, platforms and services. Examples of cookies used for this purpose include technologies that enable us to understand how users use the Company's website, applications, platforms, and services, and to understand whether they are interacting with the messages we send with cookies that allow us to analyze user behavior.

c. Usage for Advertising purposes: We may use party cookies and third party cookies related to the Company or any third party's web site, platform and applications to transmit ads and similar content to the interests of the users. Examples of advertising purposes include cookies that measure the effectiveness of ads, and cookies showing whether a particular ad was clicked or the number of times the ad was displayed.

3- Rejecting and Deleting Cookies
While most browsers allow the use of cookies, users can change or delete cookies at any time by changing their browser settings. The method of changing the settings depends on the browser used, and how the cookies can be disabled should be learned from the service provider for the used browser. In the event that cookies are disabled, some features of the Company website, applications, platforms and services may not be utilized.

4- Authorized Service Providers
We may obtain assistance from some service providers that we authorize to conduct and promote the Company's website, platforms and applications and services. These service providers will be able to place cookies and similar technologies (third party cookies) on the user's computer / device and collect information such as the IP address, unique identifier and device identifier to identify the user device.

5- Third Party Site, Products and Services
Company websites, platforms and applications may contain links to third party websites, products and services. These links are subject to the privacy policies of third parties and should be aware that the third party and third party sites are independent of the Company and that the Company is not responsible for the privacy practices of third parties. In case of visiting the linked websites, we recommend reading the privacy policies of these sites.