Cookie Policy
The purpose of this Privacy Policy is to set out the terms and conditions relating to the use of personal data shared with the Company by users/members/visitors of the Platform ("Data Subject") during the operation of the website www.harmas.com.tr, operated by Harmas Group ("Harmas Group"), or generated by the Company during the Data Subject's use of the Platform.
The Data Subject declares that they have been informed of the processing of their personal data through this Privacy Policy and that they consent to the use of their personal data in the manner set out herein.
What Data Is Processed?
This section lists the data processed by the Company that is considered personal data under Law No. 6698 on the Protection of Personal Data. Unless expressly stated otherwise, within the terms and conditions set out in this Privacy Policy, the term "personal data" shall cover the following information:
- Customer Information
- Device Information
- Behavior
- Demographic Information
Pursuant to Articles 3 and 7 of the Law on the Protection of Personal Data, data that has been irreversibly anonymized will not be considered personal data under the provisions of that Law, and processing activities relating to such data will be carried out without being bound by the provisions of this Privacy Policy.
For What Purposes Is the Data Used?
The Company may process personal data in order to recommend the products and services offered by the Company to relevant individuals by tailoring them to their preferences, usage habits, and needs; to use it within the scope of direct and indirect marketing activities; and to transfer it for these purposes to the Company's representatives, solution partners, and third-party service providers.
Pursuant to Articles 5 and 8 of the Law on the Protection of Personal Data and/or where exceptions exist under applicable legislation, the Company may process personal data and share it with third parties without obtaining the separate consent of the Data Subject. The main such circumstances are set out below:
- Where expressly provided for by law,
- Where necessary to protect the life or physical integrity of the person themselves or of another person, in cases where the person is unable to give consent due to actual impossibility or where consent is not legally valid,
- Where processing personal data is necessary, provided that it is directly related to the establishment or performance of an agreement between the Data Subject and the Company,
- Where necessary for the Company to fulfill its legal obligations,
- Where the data has been made public by the Data Subject themselves,
- Where data processing is necessary for the establishment, exercise, or protection of a right,
- Where data processing is necessary for the Company's legitimate interests, provided that this does not harm the fundamental rights and freedoms of the Data Subject.
Who Has Access to the Data?
The Company may transfer personal data, and any new data derived from the use of personal data, to third parties from whose services the Company benefits, for the purpose of achieving the objectives set out in this Privacy Policy and limited to the provision of those services. The Company may also transfer data, within the purposes set out in this Privacy Policy, to the Company's business partners and suppliers, as well as to lawfully authorized institutions and organizations.
The Company may share data with third parties — including outsourced service providers (including those sending SMS messages), hosting service providers, law firms, research companies, and call centers — in order to improve the data subject's experience (including enhancement and personalization), ensure the data subject's security, detect fraudulent or unauthorized use, conduct operational assessments, resolve errors relating to Platform services, and achieve any of the purposes set out in this Privacy Policy.
The Data Subject acknowledges and agrees in advance that, limited to the purposes set out above, the aforementioned third parties may store the Data Subject's personal data on servers located anywhere in the world.
Right of Access to Data and Correction Requests
Pursuant to Article 11 of the Law, data subjects have the right to:
- Learn whether their personal data is being processed,
- Request information regarding their personal data if it has been processed,
- Learn the purpose for which their personal data is processed and whether it is used in accordance with that purpose,
- Know the third parties to whom their personal data is transferred, whether domestically or abroad,
- Request the correction of their personal data if it has been processed incompletely or incorrectly, and request that this action be notified to the third parties to whom the personal data has been transferred,
- Request the deletion or destruction of their personal data if the grounds for processing no longer exist, even where the data was processed in accordance with the Law and other relevant legal provisions, and request that this action be notified to the third parties to whom the personal data has been transferred,
- Object to the emergence of a result against themselves through the exclusive analysis of processed data via automated systems,
- Request compensation for damages in the event that they suffer harm due to the unlawful processing of their personal data
under the Law.
Such rights, when submitted by personal data subjects through the methods specified in the Elektronik Bilgi Güvenliği A.Ş. Personal Data Protection and Processing Policy available at www.harmas.com.tr, will be evaluated and concluded as promptly as possible and, in any event, within 30 (thirty) days. While no fee is generally charged for such requests, the Company reserves the right to charge a fee based on the tariff determined by the Personal Data Protection Board.
The Data Subject acknowledges that, should they make a request that results in certain personal data no longer being usable by the Company, they may not be able to fully benefit from the functioning of the Platform, and declares that any resulting liability shall be their own.
Retention Period of Personal Data
The Company will retain personal data provided by the data subject for as long as required by the processing purposes set out above.
In addition, in the event of any dispute that may arise between the Company and the data subject, the Company may retain personal data for the statute-of-limitations periods set out under applicable legislation, limited to the purpose of enabling the necessary defenses within the scope of that dispute.
Data Security Measures and Commitments
Under the terms set out in applicable legislation or expressed in this Privacy Policy, the Company undertakes to:
- Ensure that personal data is not processed unlawfully,
- Ensure that personal data is not accessed unlawfully, and
- Ensure the safekeeping of personal data
by taking the necessary technical and administrative measures to provide an appropriate level of security, and by carrying out the necessary audits.
The Company may not disclose personal data obtained about the Data Subject to others, or use it outside the purpose of processing, in violation of this Privacy Policy or the provisions of the Law on the Protection of Personal Data.
Where links to other applications are provided through the Platform, the Company bears no responsibility for the privacy policies or content of those applications.
Cookies
Cookies are used on the Platform so that Data Subjects can benefit from the Platform in the most efficient way and so that the user experience can be improved. If you prefer not to use cookies, you can delete or block cookies through your browser settings. However, we would like to remind you that this may affect your use of the Platform.
What Are Cookies and Why Are They Used?
Cookies are small text files stored on your device or on a network server by the websites you visit, via your browser. For more detailed information on cookies, you may visit www.aboutcookies.org and www.allaboutcookies.org.
The main purposes of using cookies on our website are set out below:
- To improve the services provided to you by increasing the functionality and performance of the website,
- To improve the website, offer new features through the website, and personalize the features offered according to your preferences;
- To ensure the legal and commercial security of the website, of you, and of our Company.
- To use within the scope of direct and indirect marketing activities
Categories of Cookies Used on the Site
| Cookie Category | Description |
|---|---|
| Technical Cookies | Technical cookies ensure the operation of the Site and identify pages and areas of the website that are not functioning. |
| Authentication Cookies | When visitors log in to the Site using their passwords, these cookies identify the visitor as a logged-in user on every page they visit on the Site, preventing the user from having to re-enter their password on each page. |
| Flash Cookies | These cookies are used to enable image or audio content found on the Site. |
| Customization Cookies | These cookies are used to remember users' preferences when visiting different pages of the website. For example, remembering your selected language preference. |
| Analytical Cookies | Analytical cookies produce analytical results such as the number of Site visitors, the pages viewed on the Site, visit times, and page-scrolling behavior on the website. |
Can the Use of Cookies Be Blocked by Data Subjects?
Data subjects have the ability to personalize their cookie preferences by changing their browser settings. If the browser being used offers this option, it is possible to change cookie preferences through the browser settings. Accordingly, although this may vary depending on the options offered by the browser, data subjects have the ability to block the use of cookies, choose to receive a warning before a cookie is used, or disable or delete only certain cookies.
Cookie preferences may need to be set separately on each device the user uses to access the Platform.
Changes to the Privacy Policy
The Company may change the provisions of this Privacy Policy at any time. The updated Privacy Policy takes effect on the date it is made available to the Data Subject by any means.