Website Visitor Privacy Notice

In this Privacy Notice, the principles regarding the processing of your personal data by Sabancı Digital Technology Services Inc. ("Company"), located at "Küçük Çamlıca Mahallesi, Kısıklı Caddesi, No. 56, Üsküdar/Istanbul/Turkey" in accordance with the Law No. 6698 on the Protection of Personal Data ("Law") and related legislation are stated below.

1. Purpose of Processing Personal Data:

Your personal data obtained as a result of your visit to our website may be processed by our Company for the following purposes:

- Upon request through the contact section and/or social media accounts,

- Conducting necessary activities by our business units to benefit individuals from the services offered by our Company,

- Execution of related business processes, provision of information, consideration of wishes/suggestions, and enabling complaints to be lodged,

- Planning and execution of activities necessary for customizing the services offered by our Company according to the preferences, usage habits, and needs of the relevant individuals, and for their promotion and introduction,

- Conducting necessary activities by our relevant business units for the realization of commercial activities carried out by the Company and the execution of related business processes, planning, and execution of the Company's business strategies,

- Planning and execution of the Company's commercial and/or business strategies,

- Sending commercial electronic messages and benefiting from our e-bulletin services if you give your explicit consent,

- Ensuring the legal, technical, and commercial-business security of the Company and the individuals in business relationship with the Company.

2. Method of Collection and Legal Basis for Processing Personal Data:

Your personal data is collected by our Company through technical communication files known as cookies when you visit our website, and it is collected in whole or in part by automated methods as part of the data recording system, in written and electronic media in accordance with the purposes stated in this Privacy Notice. For detailed information about cookies, please review the Cookie Information Notice. In addition to cookies, your personal data collected through non-automated methods by filling out forms on the website.

Your personal data is processed based on the legal grounds listed below:

- Pursuant to Article 5/2 (a) of the Law, where it is explicitly prescribed in laws,

- Pursuant to Article 5/2 (c) of the Law, where it is necessary for the data controller to fulfill its legal obligations,

- Pursuant to Article 5/2 (f) of the Law, where it is necessary for the processing of data for the legitimate interests of our Company, provided that it does not harm your fundamental rights and freedoms,

- Obligation to store traffic data within the scope of the Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed Through These Publications.

3. Places Where Processed Personal Data is Transferred and Purpose of Transfer:

Your obtained personal data may be transferred to our business partners (external service providers, hosting service providers), company subsidiaries, and legally authorized public institutions and private individuals in accordance with the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law, in line with the purposes of processing your personal data.

4. Ways to Apply to the Data Controller and Your Rights:

In accordance with Article 11 of the Law, you have the right to: a) learn whether your personal data is being processed or not, b) If your personal data is being processed, request information regarding such processing, c) learn the purpose of the processing and whether it is being used in accordance with its purpose, d) learn the recipients to whom your personal data has been transferred domestically or abroad, e) request correction of your personal data if it is incomplete or inaccurate, f) request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the Law, g) request notification of the operations carried out to third parties to whom your personal data has been transferred, pursuant to paragraphs (e) and (f) above, h) object to the occurrence of a result against you by analyzing your personal data exclusively through automated systems, i) demand compensation for damages in case you suffer any damages due to unlawful processing.

You can submit your applications to exercise your rights listed above by filling out the Data Subject Application Form , which you can find on our website, and posting it to Küçük Çamlıca Mahallesi, Kısıklı Caddesi, No. 56, Üsküdar/İSTANBUL or sending it to the sabancidijital.kvk@sabancidijital.hs03.kep.tr registered electronic mail address.

Our company will conclude your requests, depending on the nature of the request, as soon as possible and no later than thirty days, with the first request being free of charge. However, in subsequent requests related to the same subject matter or if the processing of the initial request requires additional costs, a fee may be charged. Our company reserves the right to accept or reject the request and may provide an explanation for the rejection in writing.

In cases where the application is rejected following the procedure mentioned above, the response is found insufficient, or no response is provided within the specified period, you have the right to file a complaint with the Personal Data Protection Board ("Board") within thirty days following the notification of the response and in any case within sixty days from the date of application. However, the complaint cannot be filed without exhausting the application process.

The Board conducts the necessary examination in matters falling within its jurisdiction upon a complaint or upon learning of an alleged violation. Upon receipt of a complaint, the Board examines the request and provides a response to the relevant parties. If no response is provided within sixty days from the date of the complaint, the request is deemed rejected. Following the examination conducted upon a complaint or ex officio, if the existence of a violation is determined, the Board decides on the rectification of the identified legal violations by the data controller and notifies the relevant parties. This decision is implemented without delay and no later than thirty days from the date of notification. In cases where it is difficult or impossible to remedy the damages and there is a clear violation of the law, the Board may decide to suspend the processing of data or the transfer of data abroad.

We thank you for the trust you have placed in us and assure you that your data is carefully protected within our Company.