PROTECTION OF PERSONAL DATA AND PRIVACY POLICY

As Alin Akademi (“Alin Akademi”), the data supervisor, we would like to inform you that we care about the protection of personal data we obtain from our real and potential customers and that we take steps in line with legal regulations on the matter. 

Our company takes the necessary precautions to protect the personal data of our valuable and potential customers who visit our websites (www.kurumsalceviklik.org, www.alinakademi.com, www.yonetimsozlugu.com) and other real persons who have dealings with us in other ways, and we have prepared this Personal Data Protection and Privacy Policy ("Privacy Policy") to inform you of our rules and policies about the processing of personal data and the use of cookies and other similar technologies under the Personal Data Protection Law (“PDP Law”) No. 6698.

We would like to remind you that you will be subject to the privacy policy within this text regarding the privacy, protection, processing, use and modification of customer information and communications and other matters on our company's websites (www.kurumsalceviklik.org) and that you should thoroughly read this text to make sure you accept these terms each time you use our website.


As the data supervisor, our company may provide personal data policies and/or notices not specified within this text to the data owner according to the type and nature of our relations with the data owner. In this case, the special policies and notices provided to the data owner may include different or additional matters than the ones specified in this Privacy Policy, and the data owner should primarily take these special policies and notifications into consideration.

LEGAL BASIS AND GENERAL PRINCIPLES

Protection of personal data has been regulated particularly in the Law No. 6698 and in the Law No. 5651 on Regulation of Publications on the Internet and Fight Against Crimes Committed through These Publications, the Law on Regulation of Electronic Trade No. 6563 and relevant secondary legislation. In addition, several criminal sanctions have been foreseen in the Turkish Penal Code No. 5237 regarding the protection of personal data.

Considering the PDP Law, we see that the term “personal data” refers to all kinds of information about real people with a definitive identity or whose identity can be determined. That is, anonymous and anonymized data and any other data that cannot be associated with a particular person are not considered to be personal data under this Privacy Policy.

Data processing refers to any process on personal data including its procurement (through full or partial automation or non-automation as a part of any data recording system), recording, storage, preservation, modification, rearrangement, expression, transfer, takeover, being made procurable, classification or prevention from use.

Taking the necessary precautions to protect privacy and under compliance with all legal principles regarding the processing of personal data, our company processes personal data for the purposes set out in this Privacy Policy and in line with the principles set out below:

i.    Complying with law and rules of honesty,
ii.   Being accurate and up-to-date when necessary,
iii.  Processing for specific, clear and legitimate purposes,
iv.  Being connected to the purpose of processing, limited and restrained,
v.   Preservation for periods required by the relevant legislation or by the purpose of processing.

DATA PROCESSED BY ALİN AKADEMİ

Our company may process general and special personal data with express consent from the data owner or without express consent in cases stipulated in articles 5 and 6 of the PDP Law. These general and special data processed by our company are exemplified below, and the data to be processed may vary for each data owner depending on various factors such as the type and nature of our relations with the data owner (customer, contracted institution, solution partner, etc.) and the communication channels used.

In line with the relevant legislation and the principles in this Privacy Policy, the following types of data can be processed by our company based the type and nature of our relations with the data owner:

i.    Information for identification such as name, surname, company, position and city
ii.   Contact information such as phone and e-mail,
iii.  Information approved by the data owner to be shared through their social media accounts in case they have used these channels to connect to our Company's web addresses,
iv.  Communication records such as telephone calls, e-mail correspondence and other audio and video data regarding the services purchased by the data owner,
v.   Internet protocol (IP) address, device ID, unique identifier information, device type, ad ID, unique device icon, statistics on web page views, incoming and outgoing traffic information, referral URL, internet log information, location information, websites visited and information regarding actions taken through our websites, platforms, internet network and advertising and e-mail content,
vi.  Data obtained to understand the suitability of the data owner for offers and to communicate with them on the matter,
vii. Following the submission of a relevant offer by our company, the data used to carry out the bid preparation process and to report the approval of the contract, in case of one,
viii.Data regarding any transaction and application made by the data owner on the website.

Purposes of Using Personal Data

Our company may process personal data for the purposes specified below and to the extent permitted by the relevant legislation and may preserve them for the period required by these purposes.

i.     Fulfilling legal and administrative obligations and exercising the rights arising from the legislation in force,
ii.    Providing information to public officials on public security matters upon request and in line with legislation,
iii.   Negotiating, establishing and executing contracts that are concluded/planned to be concluded, 
iv.   Confirming the identity information of our customers for services received through our website and recording the necessary address and other necessary information for communication,
v.    Providing suggestions and solutions to our customers by our contracted institutions and solution partners and informing our customers about the services we have provided,
vi.   Organizing all records and documents regarding transaction in electronic (internet) or paper environment,
vii.  Increasing customer satisfaction, recognizing our customers who receive services from our Company through our website and using these in customer environment analyses and various marketing and advertising activities, and conducting surveys in electronic and/or physical environment through contracted organizations within this context,
viii. Evaluating customer complaints and suggestions regarding our services,
ix.  Ensuring the security of the websites and other electronic systems and physical environments used by our company,
x.  Notifying of any changes in the legislation or the rules and policies accepted by our Company or other notifications concerning the data owner,
xi.   Investigating, detecting, preventing and reporting to the administrative and judicial authorities the violations of contract and law,
xii.   Resolving current and future legal disputes,
xiii.  Answering requests and questions,
xiv. Developing and improving the written, verbal and visual communication and marketing policies of our company,
xv.   Mandatory data processing for the establishment, exercise or protection of a right,
xvi.  Without harm to the fundamental rights and freedoms of the data owner, protecting the legitimate interests of our Company.

Protection, Security and Control of Your Personal Data

As the data supervisor, our company takes all the necessary technical and administrative measures to ensure the appropriate level of security to prevent the personal data from being illegally accessed or processed. In this context, it is ensured that the business processes and activities of our Company are executed in line with the internal policies and rules prepared for the purpose of personal data protection. It is ensured that employees are informed about the legislation on personal data protection and internal policies and rules prepared in this context; the necessary declarations and commitments are received from employees and individuals and institutions who process data on behalf of our Company, and violation of these commitments is subjected to certain sanctions. The necessary information security measures are implemented to prevent unauthorized access to personal data, and the sufficiency of the measures is checked at certain periods for the purpose of continuously improving the existing data security system.

Sharing Personal Data with Third Parties at Home and Abroad and Storage Time

In line with the general principles enumerated in article 4 of the PDP Law and the conditions stipulated in articles 8 and 9 and by taking the necessary security measures, we may transfer personal data to third parties at home and abroad, and process and store it in servers at home and abroad or in other electronic media, for the purposes shown under “Personal Data Processing Purposes” within this Privacy Policy.

In this context, your personal data may be shared with the program partner institutions and organizations whom we cooperate with to carry out our activities, with domestic/foreign individuals and institutions whose services we use to store the data and receive physical servers and/or cloud services from, domestic/foreign companies we receive services from in sending commercial electronic messages, the inter-bank card center, the banks we have contracts with, internationally certified payment institutions and various domestic/foreign advertising companies, agencies and survey companies or other domestic/foreign business partners under marketing activities to increase customer experience and to provide better service.

Except when a longer period is required or allowed by law, our company stores personal data only for the period of time required to achieve the objectives set out in this Privacy Policy. Personal data with expired storage period is deleted, disposed of or anonymized by our Company under article 7 of the PDP Law.

The Rights of the Data Owner under the Law on Protection of Personal Data

As the data owner, in case you wish to exercise any of your rights specified below pursuant to article 11 of the PDP Law:

i.    learning whether your personal data is processed,
ii.   if your personal data has been processed, requesting information on the matter,
iii.  learning the purpose of processing of your personal data and whether they are used in line with such purpose,
iv.  learning about the third parties to whom your personal data is transferred to at home or abroad,
v.   requesting correction in case your personal data is incompletely or incorrectly processed,
vi. requesting the deletion or disposal of your personal data in case the reasons requiring their processing disappear,
vii. requesting your correction and deletion requests to be notified to the third parties whom your personal data has been transferred to,
viii.objecting to the emergence of a result against your interests due to the analysis of the processed data exclusively through automated systems,
ix. requesting compensation for damage in case the emergence thereof due to unlawful processing of your personal data,

you must send your e-mail within the context of this Privacy Policy to info@kurumsalceviklik.org

Requests from data owners shall be evaluated and concluded within thirty days at the latest based on the nature of the request under article 13 of the PDP Law. Positive or negative responses to such requests from data owners can be reported to data owners through electronic environment. Such requests of data owners shall be concluded free of charge as a rule, and if the request requires additional costs, fees may be charged in the amount determined under the relevant legislation.

Method and Legal Reason of Personal Data Collection

Your personal data may be obtained in written form, verbal form, audio or video recording or other physical or electronic forms for the purposes specified in this Privacy Policy and under the conditions set out in articles 5 and 6 of the PDP Law. Personal data may be collected through physical environments that data owners contact, websites, social media and other public channels, or through training, conferences and similar events or by inquiry.

While personal data is most often obtained from the data owners, they may also be obtained through contracted institutions, solution partners and persons and institutions representing/represented by the data owner under the conditions stipulated in articles 5 and 6 of the PDP Law.

USE OF COOKIES AND SIMILAR TECHNOLOGIES

During access to our company's website, electronic platforms, applications or e-mail messages or the advertisements sent by our company, small data files may be placed on users' computers, mobile phones, tablets or other devices to allow certain data to be recorded and collected. These data files may be cookies, pixel tags, flash cookies and web beacons or other similar technologies for data storage purposes. The term “cookie” herein shall refer to cookies and other similar technologies to be used by our company.

Cookies store the information they collect through log files, empty GIF files and/or third-party sources to create a summary of your preferences and can track your browsing information and/or history on the website to make special promotions for you, to offer promotions and marketing offers, to improve the content of the website for you and/or to determine your preferences.

Our website (www.kurumsalceviklik.org) analyzes and interprets visitor movements and preferences, which it monitors during use of the website, apart from the personal information obtained through communication, price and report request forms through “cookies”. Cookie are files consisting mostly of letters and numbers that are stored in the internet browser or hard disk of the device used and allow said device to be detected.

Our website (www.kurumsalceviklik.org) shall collect and process the browsing data of its visitors, share it with third parties and store it securely to provide better service to them under its legal obligation, provided that their use is limited to the purpose and extent specified in this Statement on Protection of Personal Data.

Since not every data collected through cookies may be personal data, it should be noted that the data obtained through cookies shall only be evaluated within this Privacy Policy and the PDP Law and to the extent that they constitute personal data under Turkish law.

Types of Cookies and the Use of Third-Party Cookies

Information collected from you on our company's website (www.kurumsalceviklik.org) may be matched online and offline or at different times, and this information may be used with information from other sources, such as third parties.

Cookies may be classified in terms of duration or domain name. When classified in terms of duration, cookies are divided into two as session cookies and permanent cookies. Session cookies refer to cookies that are deleted when the user closes the browser, and permanent cookies refer to those that remain on the user's computer/device for a predetermined period of time. Our company uses both session cookies and permanent cookies on its website.

When classified according to their domain name, cookies are divided into two as first party cookies and third-party cookies. Cookies placed by the visited domain are referred to as first party cookies, and cookies placed by a different domain are referred to as third party cookies. If people outside the visited domain place cookies on the user device over the visited domain, these are called third party cookies.

In this context, our Company may also use cookies to activate an "advertising technology" to present you advertisements that it thinks you may be interested in when you visit search engines, websites and other websites that said website advertises on. Advertising technology uses information about your previous visits to the website and other websites that said website advertises on to offer special ads for you. When offering these ads, a unique third-party cookie may be stored on your browser for the website to be able to recognize you.

Purposes of the Use of Cookies by Our Company

Our company mainly stores the information it collects through cookies, log files, empty GIF files and/or third-party sources to create a summary of your preferences and uses cookies to monitor your browsing information and/or browsing history on the website, to provide better services and standards with the purpose of making special promotions and offering promotions and marketing offers, to improve the content of the website for you and/or to determine your preferences.

In addition, our company may use cookies on its website, platform, applications, advertisements and messages for the purposes stated below.

i.Operational use: Our company may use the cookies it deems necessary for the management and security of its website, platform, applications and services. Examples of cookies for operational use include technologies that enable the use of functions available on the website, applications and platforms, and cookies that detect irregular behaviors in these channels.
ii.Functional use: Our company may use cookies to facilitate the use of the website, platform, applications and services and to customize these for users. Examples of cookies for functional use include technologies that enable us to remember user information and preferences.
iii.Performance use: Our company may also use cookies to increase and measure the performance of its website, application, platform and services. Examples of cookies for performance use include technologies that enable us to understand how users make use of our company's website, applications, platforms and services, and to analyze user behavior and whether the messages we send are interacted with.
iv.Advertising use: Our company or third parties may use first party cookies and third party cookies on its website, platform and applications to convey advertisements and similar content for the users' interests. Examples of cookies for advertising use include cookies that measure the effectiveness of ads and those that indicate whether a particular ad was clicked or how many times it was viewed.

Rejecting and Deleting Cookies

While most browsers allow the use of cookies, users can reject the use of cookies or delete them through their browser settings at any time. You may delete permanent cookies by following the instructions provided in the “Help” section of your Internet browser or reject both session cookies and permanent cookies by visiting “www.allaboutcookies.org” or “www.youronlinechoices.eu”. However, changing the settings varies according to the browser used, and how to disable cookies should be learned from the service provider of the browser used.
In case cookies are disabled, you may continue to use the website, but you may not be able to access all functions of the website or may have limited to access certain features of our company's website, application, platform and services.

Authorized Service Providers

Our company may get help from certain service providers that we authorize for the execution and promotion of our company's website, platform, applications and services. These service providers shall also be able to place cookies and similar technologies (third party cookies) on users' computer/device and collect information such as IP address, unique identifier and device identifier to detect the user device.

WEBSITES, PRODUCTS AND SERVICES OF THIRD PARTIES

Our company's website, platform and applications may contain links to third party websites, products and services. Such links are subject to third party privacy policies, and we would like to inform you that third parties and third-party websites are independent of our Company and our Company is not to be held responsible for third party privacy practices. In case of visiting linked websites, we recommend reading the privacy policies of said websites.

MODIFICATIONS

Our company may make modifications to this Personal Data Protection and Privacy Policy at any time, and such modifications take effect by being published on our website (www.kurumsalceviklik.org). The modifications made by our company shall be notified to the relevant parties through our website. Therefore, you can access the current version of the Privacy Policy any modifications to the Privacy Policy on our company's website.

Such modifications shall, as a rule, be made by uploading them to our company's website and shall be valid as of this date, but these modifications may be notified in other ways as deemed appropriate.

COMMUNICATION AND PERMISSION FOR PERSONAL DATA

By accepting this Privacy/Personal Data Protection Policy and Communication Permit, you consent to the collection, storage, processing, use and transfer of your personal data that you consent to be shared with our Company and to third parties whom our company has contractual relations with and whose details are given above for the purposes stated in this Privacy Policy (providing and presenting various advantages and personal promotions, advertisements, sales, marketing, survey and all kinds of electronic communication for similar purposes by phone, text message (SMS), e-mail and other similar means and for sending other communication messages etc.).

If you have any questions, you can contact us at info@kurumsalceviklik.org (info@alinakademi.com, sozluk@yonetimsozlugu.com).