POZITIF SONDAJ SANAYI VE TICARET LIMITED ŞIRKETI CLARIFICATION TEXT ON THE LAW ON THE PROTECTION OF PERSONAL DATA
WEBSITE PRIVACY AND COOKIE POLICY
It is one of our Company’s leading principles to protect the privacy of visitors (Data Owner) of the https://positifsondaj.com.tr website operated by POSITIVE SONDAJ SANAYİ VE TİCARET LİMİTED ŞİRKETİ (“Company”). Our company is very meticulous about the privacy of both visitors to our website and the data it contains. Therefore, we are obliged to inform you, our valued visitors, about the KVKK (personal data protection law) and the Cookie Policy. With the Website Privacy Policy (“Policy”), explanations are made about the (1) processing of the personal data of the Data Owners,
- the enforcement of (3) the Cookie Policy and the Website Privacy
The purpose of this clarification text is to determine the terms and conditions regarding the use of personal data shared with the Company by the users/members/visitors of the Website during the services provided through the website operated by the Company and/or service providers or regarding the use of the Company’s personal data generated during the use of the Website by the Data Owner. The Data Owner declares that he has been informed about the processing of his personal data with the Clarification Text and that he knows that his personal data will be used as specified here.
As POSITIVE SONDAJ SANAYİ VE TİCARET LİMİTED ŞİRKETİ (“Company”), we process your personal data in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) and the relevant legislation, and we provide the necessary protections by taking all the technical and administrative measures stipulated in the laws regarding processing activities.
In this context, Pozitif Sondaj processes your personal data within the framework of the KVKK and the relevant legislation, in accordance with the following principles in Article 4 of the KVKK,
- Compliance with the law and the rule of honesty,
- Being accurate and up‐to‐date, when necessary,
- Processing for specific, explicit, and legitimate purposes,
- Being connected, limited, and restrained with the purposes of processing,
- To be kept for the period required by the relevant legislation or for the purpose for which they are processed.
- Which Data Are Processed Within the Scope of Personal Data?
Under this heading, the data processed by the Company and considered as personal data in accordance with the Law on the Protection of Personal Data are listed below, but not limited to those listed below. Unless expressly stated otherwise, the terms and conditions provided within the scope of the Clarification Text “personal data” shall include the following information:
1‐Identity Information (name, surname) – In case of filling out contact forms or registration forms,
2‐Contact Information (address, e‐mail address) ‐ In case of filling out contact forms or registration forms,
3‐Customer Transaction Information and Marketing Information (Order information and history, campaign, survey, likes),
4‐Transaction Information (behavior and digital trace, IP),
5‐Technical specifications (device type) and software information (operating system) of the vehicle (computer, phone) used,
6‐Location (where the website was accessed from).
The Company can obtain information about the Data Owner’s use of the Website by using cookies, which is a technical communication file, and IP information is collected through cookies to determine the access and usage habits of the services offered on the Website.
Cookies, depending on their types, generally collect data regarding your browsing and usage preferences on the device you access the Website. This data includes the pages you access, our services and products you view, and information about your navigation on the Website.
Pursuant to Articles 3 and 7 of the Personal Data Protection Law, the data that has been irreversibly anonymized will not be considered as personal data in accordance with the provisions of the said law and the processing activities regarding this data will be carried out without being bound by the provisions of this Clarification Text.
2. For What Purposes Are the Data Used?
Your personal data shared by you will be processed for the purposes stated below;
‐ Having you and/or the institutions and organizations you represent benefit from the products and services offered by our Company, carrying out necessary studies, including but not limited to the determination and implementation of our Company’s commercial and business strategies, marketing activities, business development and planning activities,
‐ Execution of administrative operations for communication carried out by our company
‐ Ensuring the physical security and control of our company’s locations in use
‐ Establishing business partner/customer/supplier (authorized or employees) relations,
‐ Ensuring contractual requirements and financial reconciliation regarding the products and services offered with our business partners, suppliers or other third parties,
‐ Execution of our company’s human resources policies,
‐Calling our company’s call center or using the website and/or
‐ Participating in training, seminars or organizations organized by our company
The Company also processes the aforementioned personal data for the improvement of the services it provides, the development of the service and within this scope, the necessary information is given to the Data Owner and the fulfillment of the obligations arising from the nature of the services it provides.
The personal information in question will be used for the purpose of contacting the Data Owner or improving the Data Owner’s experience on the Site (such as improving existing services, creating new services and providing personalized services), as well as being used within the scope of the Company’s reporting and business development activities. It will also be used for the purpose of making various statistical evaluations, creating a database, and conducting market research without disclosing the identity of the company.
2. The Parties and Purpose of Transfer of Your Personal Data
In line with the purposes of processing your personal data, it can be transferred to our business partners, group companies, suppliers, legally authorized public institutions and private individuals within the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law.
Your personal data may be transferred in accordance with Article 8 of the KVKK for the following purposes.
The Company may transfer the personal data of the Data Owner and the new data obtained using this personal data to third parties from whom the Company’s services are used, to achieve the purposes specified by the Data Owner in the Information Letter, on a limited basis for the provision of such services.
To eliminate errors related to the Website or Company services and to realize any of the purposes in this Clarification Text, it is shared with the third parties such as subsidiaries and affiliates and group companies, outsourcing service providers, hosting service providers, law firms, research companies, business partners, suppliers, company shareholders, call centers including those who send SMS (in accordance with the provisions of other legislation regarding permissions),
The Company also transfers personal data to third parties, which can process and transfer personal data without obtaining the consent of the Data Owner, in accordance with Articles 5 and 8 of the Personal Data Protection Law and/or in case of exceptions in the relevant legislation. The main of these situations are mentioned below:
‐ Data processing is mandatory for the Company’s legitimate interests, if it does not harm the fundamental rights and freedoms of the Data Owner.
‐ Data processing is mandatory for the establishment, exercise, or protection of a right,
‐ It has been made public by the Data Owner himself,
‐ It is compulsory for the fulfillment of legal obligations,
‐ It is necessary to process personal data, if it is directly related to the establishment or performance of any contract between the Data Owner and the Company,
‐The person who is unable to express his consent due to actual impossibility or whose consent is not given legal validity is compulsory for the protection of himself or someone else’s life or bodily integrity,
‐ Explicitly stipulated in the law.
4. Collection Method and Legal Reason of Your Personal Data
We can collect and process your Personal Data in accordance with the regulations of the Policy, the Law and other relevant legislation, through written, verbal, electronic means, through video/sound recording or by confronting you physically.
Our data collection process can be realized; i) through the Website, mobile applications, e‐mail, digital channels including recruitment portals or software; ii) through means such as contracts, applications, forms, call center, remote support, sales and marketing unit, cookies on Websites, business cards, telephone; or iii) through face‐to‐face meetings with the Data Owner. Within the scope of your visit to our website, your personal data is collected through cookies, which are technical communication files, due to your visit to our website in accordance with the data processing conditions in the Law.
Your personal data will be processed by taking all necessary information security measures, if it is not used outside of the purposes and scope notified to you and will be stored and processed during the legal retention period or, if such a period is not foreseen, for the period required by the processing purpose. When this period expires, your personal data will be removed from our Company’s data streams by deletion, destruction, or anonymization methods
As stated above, the Company uses cookies and, in this context, 01it can process data and transfer it to third parties providing analysis services for the purpose of processing it within the scope of analysis services offered by third parties, only to use these analysis services to the extent required. The aforementioned technical communication files are small text files that the Website sends to the Data Owner’s browser to be stored in the main memory. The technical communication file saves the status and preference settings about a website, making it easier to use the internet in this sense. The technical communication file is designed to obtain statistical information about how many people use the websites in temporal proportion and for what purpose it is used as well as how many times a person visits any website and how long they stay. It is also designed to help dynamically generate advertisements and content from specially designed user pages for users and is used for these purposes. The technical communication file is not designed to receive any other personal data from the main memory. Most of the browsers are initially designed to accept the technical communication file, but users can always change their browser settings so that the technical communication file does not arrive or a warning is given when the technical communication file is sent. The Company also has the right to associate the behavior of the Data Owner on the site with a cookie in the browser, and to define remarketing lists based on metrics such as the number of pages viewed, the duration of the visit and the number of target completions, in order to conduct online behavioral advertising and marketing. Then, targeted advertising content may be shown to the Data Owner on the Site or other sites in the display network, according to their interests.
5. Rights of Data Owners within the Scope of Article 11 of the Law on the Protection of Personal Data
‐Learning whether your data is processed or not,
‐ If your data has been processed, requesting information about it,
‐Learning the purpose of processing the data and whether they are used in accordance with its purpose,
‐ To know the third parties to whom the data is transferred, in the country or abroad,
‐ If the data is incomplete or incorrectly processed, to request that they be corrected and to notify the third parties to whom the data has been transferred,
‐Demanding the deletion or destruction of the Data and the notification of the transaction made within this scope to the third parties to whom the Data has been transferred,
‐ Objecting to the emergence of a result against the person himself by analyzing the Processed Data exclusively through automated systems
You have the right to claim the compensation of the damage in case you suffer damage due to unlawful processing of the data.
However, in accordance with the provision of Article 28/2 of the Law on the Protection of Personal Data, in the following cases, you cannot use your rights listed above, except for your right to demand the compensation of the damage:
‐Personal data processing is necessary for the prevention of crime or for criminal investigation.
‐ Processing of personal data made public by the person concerned.
‐Personal data processing is required by the authorized and authorized public institutions and organizations and professional organizations in public institutions, for the execution of supervisory or regulatory duties and for disciplinary investigation or prosecution, based on the authority given by the law.
‐Personal data processing is necessary for the protection of the economic and financial interests of the State re‐ In case you want to exercise your rights, you can submit your requests to our Company in writing or by registered electronic mail (KEP), secure electronic signature, mobile signature or your e‐mail address previously reported to our Company and registered in our Company’s system, by filling out the form in Turkish, which you can obtain by clicking the link below. In written applications, the wet signed form is sent to our company’s Kızılırmak Mah. Ufuk Univ. Chad. You can send it to 11 Number B Blok Kat:16 No:57‐58‐59 Arma Kule Plaza‐ 06520 Çankaya/Ankara‐Turkey via a notary public or you can deliver it to the same address in person or through a proxy.garding budgetary, tax and financial matters.
‐ In case you want to exercise your rights, you can submit your requests in writing or by registered electronic mail (KEP), secure electronic signature, mobile signature, or via your e‐mail address previously notified to our Company and registered in our Company’s system by filling out the form in Turkish, which you can obtain by clicking the link below. In written applications, you can send the wet signed form to the address below of our company through a notary public; Kızılırmak Mah. Ufuk Univ. Chad. You can send it to 11 Number B Blok Kat:16 No:57‐58‐59 Arma Kule Plaza‐ 06520 Çankaya/Ankara‐Turkey or you can deliver it to the same address in person or through a representative.
For applications to be made by other means (electronically) as stated above, you can fill out the form and send it to the following addresses:
E‐mail: pozitif@pozitifsondaj.com.tr
Documents proving your identity, supporting your request, if any, and if you want to exercise this right through your attorney, a copy of the power of attorney containing special authorization must be submitted in the annex of the form.
Your requests sent with the form will be answered free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the Board may be charged.
In cases such as incomplete or incorrect sharing of information in the application, the request not being expressed clearly and intelligibly, the failure to transmit the documents supporting the request at all or as required, the failure to include a copy of the power of attorney in the applications made by proxy, we may have difficulties in meeting your requests and there may be delays in the research process. For this reason, it is important that you comply with these issues in the use of your rights. Otherwise, our company will not be responsible for any delays. Our company’s legal rights are reserved in the face of erroneous, untrue/illegal, malicious applications.
6. Retention Period of Personal Data
The Company will keep the personal data provided by the Data Owner for as long as required by the above‐mentioned processing purposes. In addition, in case of any dispute that may arise between the Company and the Data Owner, the Company will be able to store personal data, limited to the purpose of making the necessary defenses within the scope of the dispute, and during the statute of limitations determined in accordance with the relevant legislation.
7. Data Security Measures and Commitments
In the conditions specified in the relevant legislation or expressed in this Clarification Text, the Company undertakes to take the necessary technical and administrative measures and to carry out the necessary inspections to ensure the appropriate level of security in order to ensure that personal data is not processed unlawfully, that personal data is not accessed unlawfully, and that personal data is preserved.
The Company cannot disclose the personal data obtained about the Data Owner to others in violation of the provisions of this Information Text and the Law on the Protection of Personal Data and cannot use it for purposes other than processing.
In case of linking to other applications on the site, the Company does not bear any responsibility for the privacy policies and contents of the applications.
8. About the Cookie Policy
Cookies are files containing small pieces of data, such as usernames and passwords, that are exchanged between the user’s computer and the web server to identify specific users and improve their browsing experience.
This Cookie Policy explains what cookies are and how we use them. You can change or withdraw your consent in the Cookie Notice on our website at any time.
Find out more about who we are, how you can contact us and how we process personal data in our Privacy Policy
Your consent is applied to the following areas:
- https://pozitifsondaj.com.tr/
- com
- com
- com
What is a cookie?
Cookies are small text files used to store small information. Cookies are stored on your device when the website is loaded in your browser. These cookies allow us to make the website work properly, make the website more secure, provide a better user experience and analyze how the website is performing and what is working and where it needs improvement.
We use Cookies so that you can make the most of our website and improve your user experience. If you do not prefer the use of cookies, you can delete or block Cookies from your browser’s settings. However, we would like to remind you that this may affect your use of our website.
How Do We Use Cookies?
Third‐party cookies used on our websites are mainly used to see how the website performs, how you interact with our website, to keep our services secure, to serve ads relevant to you, and to provide you with a better service, all of them. It helps speed up your user experience and future interactions with our website.
The main purposes of using cookies on our website are listed below:
‐To improve the services offered to you by increasing the functionality and performance of the website,
‐ To improve the Website and to offer new features on the Website and to customize the features offered according to your preferences;
‐To ensure the legal and commercial security of the Website, you, and our Company.
What kind of cookies do we use?
Like most online services, our website uses first‐ and third‐party cookies. First‐party cookies are mostly necessary for the website to function properly, and they do not collect any of your personally identifiable data.
Basic: Some cookies are necessary for you to experience the full functionality of our site. They allow us to maintain user sessions and prevent security threats. They do not collect or store personal information. For example, these cookies allow you to log in to your account and add items to your cart and pay securely.
Statistics: These cookies store information such as the number of visitors to the website, the number of unique visitors, which pages of the website were visited, and the source of the visit. This data helps us analyze and analyze how well the website is performing.
Marketing: Our website advertises. These cookies are used to personalize the ads we show you in a way that is meaningful to you. These cookies also help us track the efficiency of these advertising campaigns.
The information stored in these cookies may also be used by third‐party advertising providers to show you advertisements on other websites in the browser.
Functional: These are cookies that assist some non‐essential functions on our website. These functions include embedding content such as videos or sharing website content on social media platforms.
Preferences: These cookies help us save your settings and determine your browsing preferences, such as language preferences, so that you have a better and more efficient experience on future visits to the website.
How Can I Control Cookie Preferences?
In addition, different browsers offer different methods to block and delete cookies used by websites. You can change your browser’s settings to block/delete cookies. To learn more about how to manage and delete cookies, visit wikipedia.org, www.allaboutcookies.org.
Types of Cookies Used on Our Website
Google Ads (Advertisement) Cookies: Google Ads cookies are used to remember your safe search preferences, show you more relevant ads, determine how many visitors you get to a page, help you sign up for our services, protect your data, or remember your ad settings. This helps the website remember information about your visit (for example, your preferred language and other settings). Information about your use of this Website (including your IP address) is transferred to Google and stored by Google on servers in the USA. Google will use this information to evaluate your use of the Website, to compile Website activity for the Company and to provide other services related to Website activity and internet usage but will not match your IP address with other data stored by Google.
Analytical Cookies: These are the cookies that provide the production of analytical results such as the number of visitors to the website, the detection of the pages viewed on the website, the hours of visits to the website, the scrolling movements of the website pages.
Can the Use of Cookies Be Blocked by Data Owners?
You can customize your preferences regarding cookies by changing the settings of your browser. For more information, you can visit the links in the table below:
Adobe Analytics: http://www.adobe.com/uk/privacy/opt‐out.html AOL:https://help.aol.com/articles/restore‐security‐settings‐and‐enable‐cookiesettings‐on‐browser Google Adwords: https://support.google.com/ads/answer/2662922?hl=en
Google Analytics: https://tools.google.com/dlpage/gaoptout GoogleChrome:http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647 Opera: http://www.opera.com/browser/tutorials/security/privacy/
Safari: https://support.apple.com/kb/ph19214?locale=tr_TR
Enforcement of Website Privacy Policy
Website Privacy Policy is dated 24.05.2022. The Company may change the provisions of this Information Text at any time. In case of renewal of all or certain articles of the Policy, the effective date of the Policy will be updated. The policy is published on the Company’s website at Pozitifsondaj.com.tr and is made available to the relevant persons upon the request of the personal data owners. Detailed information on the processing of your personal data can be found in the Company’s Personal Data Protection and Processing Policy, which has been shared with the public at the internet address positive@positifsondaj.com.tr.