1. Definitions

In this Document, the following terms shall have the following meanings:

• “Controller” means the natural or legal person determining the purposes and means of processing personal data.
• “Processor” means the natural or legal person processing personal data on behalf of the Controller.
• “Data Subject” means an identified or identifiable natural person whose personal data is processed.
• “Personal Data” means any information relating to an identified or identifiable natural person.
• “Processing” means any operation performed on Personal Data, such as collection, recording, storage, adaptation, alteration, retrieval, consultation, use, disclosure, alignment, combination, blocking, erasure or destruction.

2. Privacy Policy

We, as Controller, respecting both the EU General Data Protection Regulation (GDPR) (Regulation 2016/679) and the Turkish Law on Protection of Personal Data (KVKK No. 6698), commit to processing Personal Data fairly and lawfully. This Policy outlines how we collect, process, retain, and disclose Personal Data in connection with our services.

2.1 Purpose and Legal Basis

We collect Personal Data for the following purposes: service provision, customer support, fraud prevention, marketing communications, and compliance with legal obligations. Processing is based on:

• Consent of the Data Subject (GDPR Art. 6(1)(a); KVKK Art. 5).
• Performance of a contract to which the Data Subject is a party (GDPR Art. 6(1)(b)).
• Compliance with a legal obligation (GDPR Art. 6(1)(c)).
• Legitimate interests pursued by the Controller (GDPR Art. 6(1)(f)), such as service improvement and network security.

2.2 Categories of Personal Data

We may collect and process the following categories of Personal Data:

• Identification Data (name, date of birth, nationality).
• Contact Data (postal address, email address, telephone number).
• Technical Data (IP address, device identifiers, browser type).
• Financial Data (payment details, transaction history).
• Usage Data (login times, pages visited, interaction with content).

2.3 Data Subject Rights

Under GDPR Articles 15–22 and KVKK Articles 11–13, Data Subjects are entitled to the right to:

• Access their Personal Data.
• Rectify inaccurate or incomplete data.
• Erase (“right to be forgotten”) under certain conditions.
• Restrict processing.
• Object to processing (including for marketing).
• Data portability.

Requests may be submitted to privacy@example.com. We will respond within one month.

2.4 Retention and Security

Personal Data will be retained only for as long as required by the purposes outlined or by applicable law. We implement appropriate technical and organizational measures, including encryption, access controls, and regular audits, to safeguard Personal Data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.

3. Cookie Policy

Our website uses cookies and similar tracking technologies. By continuing to browse, you agree to our use of cookies in accordance with this Policy.

3.1 Types of Cookies

• Strictly Necessary: Required for basic site functionality and cannot be disabled.
• Functional: Enable enhanced functionality and personalization.
• Performance: Collect anonymous data on site usage to improve performance.
• Targeting/Advertising: Track browsing habits to deliver relevant ads.

3.2 Managing Cookies

You may set your browser to refuse all or some cookies or to alert you when websites set or access cookies. Disabling cookies may affect site features and functionality.

3.3 Third-Party Cookies

Third-party services such as Google Analytics and social media platforms may set cookies on your device. We encourage you to review their privacy policies for more information.

4. Terms of Use

4.1 Acceptance

By accessing or using our website and services, you agree to comply with these Terms. If you do not agree, please do not use our services.

4.2 User Obligations

Users must maintain the confidentiality of account credentials, refrain from unauthorized access attempts, and use services only for lawful purposes. Prohibited activities include infringement of intellectual property rights, distribution of malicious content, and any behavior that disrupts service availability.

4.3 Service Changes

We reserve the right to modify, suspend, or discontinue any part of the service at any time without notice. We may also impose limits on certain features or restrict access to parts or the entire service.

4.4 Termination

We may terminate or suspend access to the service immediately, without prior notice or liability, for any reason, including breach of these Terms.

5. Limitation of Liability & Disclaimer

TO THE FULLEST EXTENT PERMITTED BY LAW, THE CONTROLLER AND ITS AFFILIATES SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, DATA, GOODWILL, OR OTHER INTANGIBLE LOSSES, ARISING OUT OF OR IN CONNECTION WITH THE ACCESS, USE, OR INABILITY TO USE THE SERVICE, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

THE INFORMATION PROVIDED ON THIS WEBSITE DOES NOT CONSTITUTE LEGAL, FINANCIAL, OR INVESTMENT ADVICE. PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE RESULTS. USERS SHOULD CONSULT A QUALIFIED PROFESSIONAL FOR SPECIFIC ADVICE TAILORED TO THEIR SITUATION.

ALL CONTENT IS PROVIDED “AS IS,” WITHOUT WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT.