PRIVACY AND COOKIE POLICY

Privacy and Cookie Policy

ALFA Information Technologies Management Consulting Ltd. (ALFA) operates an online website in Turkey and collects information about you for denizorbay.com.

ALFA is aware of your sensitivity regarding how information about you is used and shared, and respects your trust by carrying out its work carefully and sensitively, in accordance with the Personal Data Protection Law No. 6698 (“Law”) and related regulations. This Cookie Policy defines our privacy principles. By visiting this website, you accept the practices described in this Cookie Policy.

In case of any contradiction between the English, other foreign language versions, and the Turkish version of this Cookie Policy, the Turkish version shall prevail.

Who is responsible for the protection of our personal information?

ALFA conducts sales services for products and services offered on the denizorbay.com website.

ALFA; (referred to collectively as “we”) is the data controller for the collection, processing, use, and/or storage of your personal information on this website and our mobile applications compliant with current laws.

Personal information collected

All our activities are based on binding ethical principles and we are committed to providing a good level of protection for the privacy of visitors to denizorbay.com and our mobile applications. Therefore, our manner of collecting and storing information is based on the legal reasons set forth in Articles 5 and 6 of the Law, depending on how our website and related services are used.

Data collected by automated means

For user-friendly, effective, and secure services, various technologies can be used on denizorbay.com and our (mobile) applications. These technologies may lead to data being automatically collected by us and third parties on our behalf. This data does not always contain personal information about the user. Examples of such technologies include cookies, local shared objects, and web analytics.

Clickstream data

Visiting denizorbay.com results in data being automatically received and stored by us or third parties on our behalf, which is transferred from your browser to our server. This data may specifically include:

• IP address of the visitor
• Date and time of the visit
• Referral URL (the site from which the visitor came)
• Pages visited on our website
• Information about the browser used (browser type and version, operating system, etc.)

Cookies

Cookies are used on our website and (mobile) applications. These files are small text files stored by your computer’s hard drive or device’s web browser. During the purchase process, we may use cookies to identify the account holder and store products in the shopping cart. In other words, cookies help make our website or (mobile) applications more user-friendly, effective, and secure. Your web browser enables the use of cookies by default, but this feature can be disabled. However, this may result in some services not being provided. It is also possible to delete cookies after using the web browser. Our cookies do not harm your computer or contain viruses.

Links below provide specific information about the most used web browsers:

• Internet Explorer: http://support.microsoft.com/gp/cookies/en
• Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies
• Google Chrome: http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647
• Safari: http://support.apple.com/kb/PH5042
• Opera: http://www.opera.com/browser/tutorials/security/privacy/

Local shared objects

Local shared objects are a special form of cookies. Unlike regular cookies, these are not created and saved by the browser, but are executed with the Adobe Flash plugin. They may contain more information than regular cookies, cannot be deleted, and may not be disabled with the browser. This process can only be done using tools on the Adobe Flash Player website. For more information about these cookies, please visit the relevant website.

Web beacons and tracking links

Web beacons (also known as pixel codes and clean GIFs) have invisible drawings for users. Tracking links and/or similar technologies consist of several lines of programming code that can be placed on our website or (mobile) applications. These are primarily used for statistical analysis purposes associated with cookies. This technology can be used to determine if emails were received, opened, and responded to, apart from tracking traffic on websites.

Web analytics

Web analytics is a term used to collect and identify visitors’ behaviors towards websites and (mobile) applications. This includes traffic analysis in succession. For example, it is used to determine the frequency of visits to specific sections of a website or (mobile) application and what information and services visitors are most interested in. For these purposes, we utilize clickstream data and other techniques listed above. Web analytics is conducted by Google Analytics and/or other selected parties. More information on processing web analytics can be found in the Google Analytics article mentioned above.

Data provided by you

In addition to data collected by automated means, we also process data provided by you. This includes but is not limited to:

• Contact information including your name and surname, (billing or delivery) address, date of birth, email address, and optionally your phone number. Your email address and (optional) phone number are required for us to contact you for questions or information about your order.
• Information necessary to process your order such as details about products ordered, billing and delivery addresses, and other information like bank and/or credit card details.
• If you have created an online profile, your preferences and interests are stored in this profile (for more detailed information, please refer to the section on profiles below).
• If you have contacted customer service, we use your contact details and communication history to handle your request and provide you with the best possible service.
• If you agree to receive newsletters, we will send them to you. If you have given consent during the sale of a product or service, we may inform you about similar products and services. We may also contact you for feedback after the sale of a product or service. You can always immediately and promptly cancel your consent in these notifications.

How the collected information is used / For what purpose your personal data is processed

We will use the information we collect about you to provide you with a suitable shopping experience, fulfill your orders, and offer you promotions related to our products and services.

We will use your personal data for purposes related to your order; for example, to inform you about the status of your order or delivery. We may use your data with third parties for the assessment of your credibility.

If you provided us with personal data related to a promotion, event, (mobile) application, we may send you emails or other messages related to the service you requested.

If you contact customer service, we will use your personal data (including your communication history) to process your request and provide you with the best possible service.

If you agree to receive newsletters, we will send them to you. If you consented during the sale of a product or service, we may inform you about similar products and services. We may contact you for feedback after the sale of a product or service. You can always immediately withdraw your consent in these notifications.

If you ask us to contact you for marketing, advertising, and opinion polling purposes via regular (non-electronic) mail, email, SMS, phone, or other electronic means, we may do so. Examples of the content of such communications may include information related to denizorbay.com services/products, e-commerce activities, special offers, promotions, activities, or events. Your reviews of denizorbay.com sales services and products, your communication history with our customer service, newsletter click-through rates, web browsing behavior (web tracking), types of newsletters or event participation (use of mobile applications) may be combined, analyzed, and used. We may transmit your contact information to other units within denizorbay.com for marketing, advertising, and/or opinion polling purposes. Please refer to the “Your Rights” section for information on your rights such as the right to object and the right to request correction, particularly on withdrawing your consent.

Disclosure/Transfer of Information

Your information will be protected according to our basic principles of confidentiality. We will not sell your information to third parties. Your data will be disclosed to third parties when required by law. If necessary for business purposes, your information may be transferred to third-party service providers or data processors, including ALFA servers or database storage facilities abroad. By giving explicit consent, you confirm and accept the transfer and storage of your information as described here. In all other cases, data will not be transferred without your prior consent.

We may use service providers and data processors working for the benefit of ALFA. These may include providers of location services, maintenance services, analysis, email correspondence, shipping services, money transfers, and address verification, among others. These third parties are granted access only to the personal data necessary to perform a specific service.

Non-personal data may be disclosed anonymously to our partners. Examples of non-personal data include the number of visitors to a website or (mobile) application over a specific period. Such information is generally disclosed in an “unidentified” form.

Your Rights

Under Article 11 of the Law, you have the right to:

• Learn whether your personal data is being processed,
• Request information if your personal data has been processed,
• Learn the purpose of processing your personal data and whether it is used appropriately,
• Know the third parties to whom personal data is transferred domestically or internationally,
• Request correction if your personal data is incomplete or incorrect,
• Request the deletion or destruction of your personal data within the scope provided by Article 7 of the Law,
• Request notification to third parties to whom your personal data has been disclosed pursuant to subparagraphs (d) and (e) of this Article,
• Object to the occurrence of a result against you by the analysis of processed data exclusively through automatic systems,
• Demand compensation if you suffer damage due to the unlawful processing of personal data.

If you share your personal information with us via the website or other channels, you do so entirely voluntarily and accept that your information will be used in accordance with this Privacy Policy. If you refuse to provide the required information, you may not benefit from various customer advantages. In some cases, customers who share only the necessary information with us can place product orders, use certain services, and take advantage of activities and offers on our website and (mobile) applications. These cases do not include regular purchase transactions conducted without providing any additional information beyond what is necessary for billing or delivery. Transparency and fairness are important to us, so we offer you various options under specific conditions to manage and view your information online. These options may include displaying and editing information online. It may also be possible to unsubscribe from services, delete user accounts, or obtain information about stored data.

Right to Object

For example, if you wish to stop receiving emails such as newsletters or marketing content sent by denizorbay.com, you have the option to unsubscribe by following the relevant instructions in the email. If you wish to stop receiving emails from us, you can click on the unsubscribe link. In this case, we will immediately stop sending you emails.

If you do not want information about your behavior collected and evaluated on your website or (mobile) application, you can disable web analysis data collection as described below.

If you wish to object to us contacting you for marketing, advertising, and opinion polling purposes via regular (non-electronic) mail, email, SMS, phone, or other electronic means, you can always send an email to dnzorbay@gmail.com. If we have doubts about your identity, we may ask you to identify yourself (e.g., by providing a copy of your passport or ID card).

In relation to maintenance notifications or administrative notifications, since the receipt of such notifications is a mandatory part of the use of user accounts and websites and (mobile) applications, their receipt can only be terminated by deleting your account. You can also delete your account by sending an email to dnzorbay@gmail.com.

You have the right to be informed at any time about the personal data stored about you, its origin, the purpose of storage, and the recipients. For information about stored personal data, please contact us using the contact details in the Contact Information section below.

Right to Request Correction

Subject to the exceptions under applicable laws, you have the right to request correction, addition, deletion, or blocking of your personal data related to you using the contact information in the Contact Information section below.

Information Security and Data Integrity

We take technical and organizational measures necessary to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized use, disclosure, or access, especially when the processing involves transferring data over a network and all other unlawful processing and misuse.

Social Networks

Our website and (mobile) applications provide Social Plug-ins from various social networks. If you prefer to interact with a social network, your activities on our website or (mobile) applications can also be used on social networks such as Facebook and Twitter.

If you log into a social network during a visit to one of our websites or (mobile) applications, the social network may add this information to your profile. If you interact with a Social Plug-in, this information will be transferred to the social network. If you do not want such data transfer, please log out of your social network before visiting our website or (mobile) applications.

We cannot influence this data collection and data transfer via Social Plug-ins. For detailed information on your rights, how to manage adequate privacy settings, and data collection and transfer on social networks, please read the privacy policies of these social networks.

• Facebook: http://www.facebook.com/about/privacy/
• Twitter: http://twitter.com/privacy
• Instagram: https://help.instagram.com/519522125107875/?helpref=hc_fnav&bc[0]=Instagram%20Help&bc[1]=Privacy%20and%20Safety%20Center
• Google +: http://www.google.com/intl/en/policies/privacy/

Google Analytics Web Analytics

Web analysis services on our website and (mobile) applications are provided by Google Analytics (http://www.google.com/analytics/). This means that when you visit our website or (mobile) applications, unless your browser settings prevent such cookies, a cookie from Google Analytics will be stored on your computer or mobile device.

Additionally, when you visit our website or (mobile) applications, web analysis data, including clickstream data, web beacons, data in tracking links, and information stored in Google Analytics cookies, will be sent to Google Analytics for analysis on our behalf. Please note that if you have created an online profile on our website or (mobile) application and logged into it, a unique number identifying this profile may also be sent to Google Analytics to match it with web analysis data.

Google Analytics acts as our processor. This means that we determine the purposes for which the data is used, and Google Analytics will not disclose the information to third parties except as required by law or court order. For more information on our relationship with Google Analytics, please see the “Privacy Policy for Providing Services” under Google Analytics’s privacy policy at the following link: http://www.google.com/analytics/learn/privacy.html.

If you do not want information about your behavior collected and evaluated on your website or (mobile) application by Google Analytics, you can disable Google Analytics data collection using the browser add-on provided. This add-on is available for most modern browsers. Disabling the Google Analytics browser add-on does not prevent information from being sent to the website or other web analytics services in any other way.

You can find more information about the Google Analytics Opt-out Browser Add-on at this address: http://support.google.com/analytics/bin/answer.py?hl=en&answer=181881.

Re-targeting Technologies

Our website and (mobile) application utilize re-targeting technologies within the internet. These technologies enable us to display our advertisements to visitors who have already shown interest in our products on partner websites. We understand that personalized, interest-based advertising is more engaging than ads that are not personally relevant.

We also collaborate with other companies that use tracking technologies to advertise on our behalf across the internet. These companies may collect non-personally identifiable information about your interactions with our websites or (mobile) applications, including visits and engagement with advertisements.

Re-targeting technologies analyze your cookies and display advertisements based on your past browsing behavior on the internet.

We do not store personal information related to this technology, and the use of our re-targeting technology complies with current data protection requirements.

Contact Information

If you have any questions or complaints regarding the processing of your personal information or our Privacy Policy, please contact us using the detailed contact information below:

ALFA Information Technology Management Consulting Ltd.

Address: Koru Mah. 2579 sok. No: 9-2 Daire:34 Çayyolu 06810 Çankaya Ankara

Email: alfa@alfayonetim.com

Please contact us at this address to exercise your privacy rights.

Changes to this Privacy Notice

ALFA is committed to adhering to the fundamental principles of data protection and considers this Privacy Policy to be binding by its nature. Therefore, we regularly review our Privacy Policy to ensure it is free from errors, prominently displayed on our website, contains all necessary information, is implemented comprehensively, and complies with data protection principles. This Privacy Policy may be modified in certain circumstances to keep pace with new developments related to the internet and to remain compliant with current legislation. We will not restrict your rights granted in accordance with this Privacy Policy without your explicit consent. Significant changes to our policy will be published on our website along with an updated version of the Privacy Policy.