PRIVACY AND PERSONAL DATA PROTECTION POLICY

This Privacy and Personal Data Protection Policy has been prepared to provide information regarding how personal data is collected, used, shared with third parties, what rights Users possess, how they can exercise these rights, and the use of cookies through our website at etgigrup.com (hereinafter referred to as the “Site”), for which ETGİ GRUP A.Ş. (hereinafter referred to as “ETGİ GRUP”) acts as the content provider and data controller, as well as through other channels.

Individuals and entities visiting, using, becoming members of, accessing, or submitting content such as comments, information, images, videos, illustrations, or photographs to our Website (hereinafter referred to as the “User”) shall be deemed to have accepted all terms set forth in this Privacy and Personal Data Protection Policy.

Any amendments and updates made by the Company to this Privacy and Personal Data Protection Policy shall be deemed effective from the moment they are published on our Website. Therefore, we recommend that Users review this Privacy and Personal Data Protection Policy prior to visiting our Website and take into consideration any changes and/or revisions made.

1. Collection of Personal Data
‍1.1. Users are not required to share their personal data to view and visit our Website. However, if a User wishes to participate in, benefit from, or utilize any of the features and services offered by our Website, they may be requested to provide various personal and/or demographic data.
‍1.2. The term “personal data” used in this Privacy and Personal Data Protection Policy refers to any data that directly or indirectly identifies the User, including but not limited to name-surname, e-mail address, telephone number, date of birth, age, gender, and information approved for sharing via social media accounts in the case of connecting through such accounts.
‍1.3. Personal data transmitted by the User to the Company shall be processed within the scope of the purposes specified below and shall under no circumstances be used for purposes other than those foreseen. Personal data belonging to the User may be processed for purposes such as:Enabling the Company to provide better service,Answering User queries and offering effective customer service,Establishing contact when necessary,Sending publications, e-newsletters, or notifications via e-mail,Creating a membership account on behalf of the User,Ensuring the continuity and enhancement of services provided,Re-accessing historical data when needed,Identifying User interests to conduct and improve operational activities such as business development, marketing, and communication using the collected data,Facilitating easier site access via existing social network accounts,Fulfilling our obligations arising from the Law and other applicable legislation,Performing statistical studies and market research, and creating databases.
‍1.4. Personal data, browsing data, traffic information, and Internet Protocol (IP) addresses belonging to the User will be shared with relevant public institutions and organizations upon a formal request from authorized, administrative, and official authorities in accordance with applicable legislation, for the purpose of fulfilling our security and legal obligations (including but not limited to combating crime or threats to state and public security, where we have a legal or administrative duty to report or disclose information).
‍1.5. Personal data belonging to the User may be collected by ETGİ GRUP or real/legal persons processing data on behalf of ETGİ GRUP through verbal, written, automated, non-automated, or electronic methods via contact forms, consumer complaint forms, social networks, the website, various agreements, mobile applications, e-mail, application forms, newsletters, and other similar means.
‍1.6. It is the User’s responsibility to ensure that the information provided is accurate and complete. In the event that inaccurate, misleading, or incomplete information is provided, ETGİ GRUP shall bear no liability whatsoever, and any obligation to indemnify damages incurred as a result shall belong entirely to the User.
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2. Transfer of Personal Data
Personal data belonging to the User may be shared, within the scope of the above-mentioned purposes and in accordance with applicable legislation, with all subsidiaries and affiliates in which ETGİ GRUP holds a direct and/or indirect shareholding interest. It may also be transferred domestically and/or internationally to our business partners, commercial contacts, service providers (assistants in performance), subcontractors, or regulatory/supervisory authorities and official bodies in cases required by relevant legislation in line with the purpose of the services provided. The User accepts and declares that they consent to the transfer of their personal data as described above.

3. Rights of the Data Subject
‍3.1. Within the scope of the Law on the Protection of Personal Data and other applicable legislation, the User has the right to:
‍a) Learn whether their personal data are processed,
‍b) Request information if their personal data have been processed,
‍c) Learn the purpose of processing personal data and whether they are used in accordance with their intended purpose,
‍d) Know the third parties to whom personal data are transferred domestically or abroad,
‍e) Request rectification if personal data are processed incompletely or inaccurately, and request notification of the transaction performed in this context to third parties to whom personal data have been transferred,
‍f) Request the erasure, destruction, or anonymization of personal data in the event that the reasons requiring their processing cease to exist, despite having been processed in accordance with the Law on the Protection of Personal Data and other relevant statutory provisions, and request notification of the transaction performed in this context to third parties to whom personal data have been transferred,
‍g) Object to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems,
‍h) Request compensation for damages in the event that personal data are processed unlawfully and damage is incurred as a result.
‍3.2. The User may exercise these rights by:
Sending a wet-signed written petition via registered mail with return receipt requested to ETGİ GRUP’s address at:
‍ETGİ GRUP A.Ş. Hacettepe Teknokent 4. Ar-Ge Binası, Üniversiteler Mah. 1596. Cadde No: 95/55, Beytepe, 06800 Çankaya / ANKARA / TÜRKİYE
Utilizing any other method announced by the Personal Data Protection Board.In the application made by the User to exercise the above-mentioned rights, the request must be clear and understandable, the subject matter must be related to the applicant personally (or if made by a representative, proof of representation authority must be documented), the applicant User’s identity and address information must be included, and documents proving the User’s identity must be attached to the application.
‍3.3. To modify or update their personal information and communication preferences, the User must submit their requests to the Company in the manner explained above or via an e-mail sent to bilgi@etgigrup.com. The User’s request will be evaluated and processed as promptly as possible.

4. Use of Social Media Plugins
‍4.1. Social media buttons are used on our Website to allow Users to share or bookmark web pages. When a page containing such plugins on our Website is visited by the User, the social media buttons are initially inactive; the plugins will not become active unless clicked on by the User. By activating the plugins, the User establishes a connection with the relevant social media applications; if the User is currently logged into these social media sites, this visit may be associated with the User's account by those sites, and the User's information may be recorded by them. To prevent a link from being established between their account on social media sites and their visit to our Website, the User must log out of the relevant social media accounts before accessing our Website.  
‍4.2. Social media sites and other third-party websites are beyond our control and fall outside the scope of this Privacy and Personal Data Protection Policy. We accept no responsibility for the activities, privacy policies, or privacy compliance levels of such social media sites and other websites. Therefore, Users should review the terms of use and privacy policies of those sites to learn how they collect and use User information, how this can be prevented, or how such information can be deleted.  

5. Use of Cookies
‍5.1. We use cookies on our Website to facilitate and customize the use of our site. Cookies are small text files placed on the User’s hard drive by their web browser. Every time the User visits our Website, their web browser sends cookies back to our Website, allowing our Website to recognize the User and remember information such as User preferences. The cookies we use do not store personal data and are anonymous.
‍5.2. The User may configure their web browser to warn them before accepting cookies or to simply reject all cookies; however, if cookies are not accepted, it may not be possible to access all features of our Website. The User can make the necessary changes by clicking the “help” button on their web browser to learn how to adjust these settings. As long as the User does not change their cookie settings, they are deemed to have given explicit consent to the use of cookies in accordance with this Privacy and Personal Data Protection Policy.

6. Commercial Electronic Messages
‍6.1. The User shall be deemed to have consented to the collection, storage, processing, use, and transfer (both domestically and internationally) of their personal data to the aforementioned third parties for the purposes of providing various advantages to the User, sending customized promotional, advertising, sales, marketing, survey, and similar electronic communications, and transmitting all forms of communication messages.
‍6.2. If the User does not wish to receive newsletters, announcements, commercial electronic messages, or other notifications/messages from the Company, they should not request such communications or services when registering on the Website. However, if the User consented to receiving such messages/notifications during registration and/or subscribed to the ETGİ GRUP e-newsletter, they shall be deemed to have consented to all electronic communications and other communication messages being sent to them.
‍6.3. E-mails sent to Users subscribed to the ETGİ GRUP e-newsletter include an option to unsubscribe from future communications. Should the User wish to revoke their consent for receiving newsletters, they may alter their preferences by following the instructions provided in the e-mails sent to them.

7. Applicable Law and Jurisdiction
Turkish Law shall govern the interpretation, implementation, and resolution of any disputes that may arise between the User and the Company regarding this Privacy and Personal Data Protection Policy. Ankara Central Courts have jurisdiction to resolve any disputes that may arise from this Privacy and Personal Data Protection Policy.