Privacy Policy

The purpose of this Privacy Policy is to set out the terms and conditions for the use of personal data which, in the course of the services provided through the www.digitallica.com.tr website (the “Site”) operated by Dijital İnsan Kaynakları ve Tasarım LTD. ŞTİ. (the “Company”), is shared with the Company by Site users/members/visitors (the “Data Subject”) or generated by the Company during the Data Subject’s use of the Site. The Data Subject declares that they have been informed by this Privacy Policy about the processing of their personal data and that they consent to the use of their personal data as set out herein.

What Data Is Processed? This section lists which of the data processed by the Company qualify as personal data under the Turkish Personal Data Protection Law No. 6698 (KVKK). Unless expressly stated otherwise, the term “personal data” in the terms and conditions set out in this Privacy Policy covers the information below.

■ First name, last name
■ E-mail address
■ Phone number
■ Employer company information
■ Job title

The Company may obtain information about the Data Subject’s use of the Site by using cookies, which are technical communication files, and IP information is collected via cookies to identify access to and usage habits of the services offered on the Site. You can refer to our Cookie Policy regarding the use of cookies. Pursuant to Articles 3 and 7 of KVKK, data that has been irreversibly anonymized shall not be considered personal data under the provisions of that law, and processing activities relating to such data shall be carried out without being bound by the provisions of this Privacy Policy.

For What Purposes Is Data Used? The Company may process the personal data provided by the Data Subject for purposes including, in particular, promoting Digitallica products and innovations and sharing information, developments and new projects in the e-learning sector with customers and potential customers, as well as having our relevant business units carry out the necessary work and run the related business processes to perform the commercial activities conducted by the Company, planning and executing the Company’s commercial and/or business strategies, enabling relevant persons to benefit from the services offered by the Company and informing those who request it, ensuring the legal, technical and commercial/business security of the Company and of relevant persons in a business relationship with the Company, evaluating and concluding requests and/or complaints from individuals, and coordinating, planning and executing the necessary work with the relevant business units and parties for this purpose. The Company may also process such personal data to improve its services, develop the service and provide the Data Subject with the necessary information in this context, and to fulfill the obligations arising from the nature of the services it offers. Such personal information may be used to contact the Data Subject or to improve the Data Subject’s experience on the Site (such as developing existing services, creating new services and offering personalized services), may be used within the scope of the Company’s reporting and business development activities, and may also be used to perform various statistical analyses, build databases and conduct market research without disclosing the Data Subject’s identity. Such information may be processed and stored by the Company and the persons it cooperates with for direct marketing purposes and transferred to third parties, and the Data Subject may be contacted using such information to promote various applications, products and services and to send notifications regarding maintenance and support activities. In addition, pursuant to Articles 5 and 8 of KVKK and/or where exceptions under the relevant legislation apply, the Company may process personal data and share it with third parties without obtaining the separate consent of the Data Subject. Some of these cases are listed below.

■ It is expressly provided for by law
■ It is necessary to protect the life or physical integrity of a person who is unable to give consent due to actual impossibility or whose consent is not legally valid, or of another person
■ Processing of personal data is necessary, provided that it is directly related to the conclusion or performance of a contract between the Data Subject and the Company
■ It is necessary for compliance with legal obligations
■ The data has been made public by the Data Subject themselves
■ Data processing is necessary for the establishment, exercise or protection of a right
■ Data processing is necessary for the Company’s legitimate interests, provided that it does not harm the Data Subject’s fundamental rights and freedoms

As stated above, the Company may use cookies and, by processing data in this context, may transfer it to third parties for processing within the scope of analytics services provided by third parties, solely to the extent required by such analytics services. The technical communication files mentioned are small text files that the Site sends to the Data Subject’s browser to be stored in the main memory. A technical communication file makes using the internet easier by storing status and preference settings about a website. Technical communication files are designed and used to obtain statistical information on how many people use websites over time, for what purpose and how many times a person visits a website and how long they stay, and to help generate advertising and content dynamically from user pages designed specifically for Users. Technical communication files are not designed to retrieve any other personal data from the main memory. Most browsers are initially set to accept technical communication files; however, users may change their browser settings at any time so that technical communication files are not received or a warning is given when one is sent. The Company also has the right to associate the Data Subject’s behavior on the site with a cookie in the browser and to define remarketing lists based on metrics such as the number of pages viewed, visit duration and number of goal completions, for the purpose of online behavioral advertising and marketing. The Data Subject may then be shown targeted advertising content based on their interests on the Site or on other sites in the display advertising network.

Who Can Access the Data? The Data Subject’s personal data, and new data the Company obtains by using such personal data, may be transferred to third parties whose services the Company uses to perform its commitments to the Data Subject, limited to the provision of such services. The Company may share such data with third parties such as outsourced service providers (including SMS providers), hosting service providers, law firms, research companies and call centers in order to develop the Data Subject’s experience (including improvement and personalization), ensure the Data Subject’s security, detect fraudulent or unauthorized use, conduct operational evaluation research, fix errors relating to the Site or the Company’s services, and achieve any of the purposes set out in this Privacy Policy. The Data Subject accepts that, limited to the purposes stated above, such third parties may store the Data Subject’s personal data on their servers anywhere in the world, and that they consent to this in advance.

Right of Access to Data and Rectification Requests By applying to the Company, the Data Subject has the following rights with respect to themselves:

■ To learn whether personal data is processed
■ To request information if personal data has been processed
■ To learn the purpose of processing personal data and whether it is used in line with that purpose
■ To know the third parties to whom personal data is transferred domestically or abroad
■ To request rectification of personal data if it is incomplete or inaccurately processed
■ To request the erasure or destruction of personal data under the conditions set out in the relevant legislation
■ To request that rectification, erasure and destruction carried out under the relevant legislation be notified to third parties to whom the personal data has been transferred
■ To object to a result against the person arising from the analysis of processed data exclusively through automated systems
■ To claim compensation for damage suffered due to unlawful processing of personal data

The Data Subject may submit the above requests to the Company in writing (to the address Akasya Towers Acıbadem Mah. Çeçen Sok. No:25 A Daire:150 Üsküdar – İSTANBUL). The Company concludes the Data Subject’s requests according to the nature of the request and within 30 days at the latest. If the procedures incur a cost, a fee may be charged based on the tariff that may be set by the Personal Data Protection Board. The Data Subject undertakes that the information subject to this Privacy Policy is complete, accurate and up to date, and that they will update it immediately in case of any change. The Company shall have no liability if the Data Subject has not provided up-to-date information. The Data Subject accepts that, if they make a request that results in any of their personal data becoming unusable by the Company, they may not fully benefit from the services the Company has committed to provide, and declares that all liability arising in this context will be theirs.

Retention Period of Personal Data The Company will retain the personal data provided by the Data Subject for as long as the services are provided, in order to fulfill the obligations arising from the nature of the services it offers. In addition, in the event of any dispute that may arise with the Data Subject, the Company may retain personal data for the statutory limitation periods set by the relevant legislation, limited to the purpose of making the necessary defenses in that dispute. For more detailed explanations about personal data, you can access the Company’s “Personal Data Protection and Processing Policy” via the links below:
Personal Data Protection and Processing Policy
Data Subject Application Form

Data Security Measures and Commitments Under the conditions set out in the relevant legislation or stated in this Privacy Policy, the Company undertakes to take the necessary technical and administrative measures, and to have the necessary audits carried out, to ensure an appropriate level of security in order to:

■ prevent unlawful processing of personal data,
■ prevent unlawful access to personal data, and
■ ensure the safekeeping of personal data.

The Company may not disclose the personal data it obtains about the Data Subject to others, or use it outside the purpose of processing, in breach of this Privacy Policy and the provisions of KVKK (Law No. 6698). Where links to other applications are provided through the Site, the Company bears no responsibility for the privacy policies or content of those applications.

Changes to the Privacy Policy The Company may amend the provisions of this Privacy Policy at any time. The updated Privacy Policy enters into force on the date it is made available to the Data Subject by any method.

COOKIES USED ON OUR WEBSITE (OUR COOKIE POLICY)

■ What Are Cookies and Why Are They Used?
Cookies are small text files stored on your device or network server via browsers by the websites you visit. The main purposes of using cookies on our Website are listed below.

■ To improve the services offered to you by enhancing 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

■ Types of Cookies Used on Our Website Session Cookies
Session cookies are temporary cookies used during our visitors’ visits to the Website and deleted after the browser is closed. The main purpose of using such cookies is to ensure that the Website functions properly during your visit. For example, they enable you to fill in online forms consisting of multiple pages.

Persistent Cookies
Persistent cookies are types of cookies used to increase the functionality of the Website and to provide our visitors with a faster and better service. Such cookies are used to remember your preferences and are stored on your device via browsers. Some types of persistent cookies may be used to offer you personalized recommendations, taking into account matters such as your purpose in using the Website. Thanks to persistent cookies, if you visit our Website again with the same device, it is checked whether there is a cookie created by our Website on your device; if so, it is understood that you have visited the site before, the content to be delivered to you is determined accordingly, and thus a better service is offered to you.

■ Cookies Used on Our Website Technical Cookies
Technical cookies ensure that the website works and identify pages and areas of the website that are not working.

Authentication Cookies
When visitors log in to the website using their passwords, these cookies identify the visitor as a site user on each page they visit, so that the user does not have to re-enter their password on every page.

Flash Cookies
These are cookies used to enable image or audio content on the website.

Customization Cookies
These are cookies used to remember users’ preferences when they visit different pages of the website. For example, remembering the language you have selected.

Analytical Cookies
Analytical cookies are cookies that enable the generation of analytical results such as the number of visitors to the website, identification of the pages viewed on the website, website visit times and scrolling movements on website pages.

■ Can Data Subjects Block the Use of Cookies?
You can personalize your cookie preferences by changing your browser settings.

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