Cookie Usage Clarification Text

• 1.1. Introduction

  6With the Law No. 6698 on the Protection of Personal Data ("Law"), important obligations have been imposed on personal data processors in order to protect the fundamental rights and freedoms of individuals, especially the privacy of private life. Headquarters address Beylikdüzü OSB Mah. Hürriyet Bulvarı No:10/9, 34524 Beylikdüzü Istanbul, Ekom Elektrik Elektronik Sanayi ve Ticaret Anonim Şirketi("Company") , registered in the Istanbul Trade Registry, takes a meticulous and sensitive approach in its capacity as Data Controller in order to fulfill the relevant obligations and to ensure that all data processing processes comply with the legislation.
  In light of this approach, the Company explains the cookie technology used on the Company's website www.e-kom.com (Online Area), the processes of processing personal data obtained with this technology in all its dimensions and aims to enlighten and inform the Data Subjects with this text ("Clarification Text").

• 1.2. Scope

  In this Clarification Text, the Data Subjects will be enlightened within the scope of the following questions regarding the personal data processing activity carried out by the Company with the cookie technology used in the Online Area:

  1. What are the minimum credentials of the Company?
  2. What are the types and characteristics of cookies used in the Online Space?
  3. For what purposes are personal data obtained through cookies processed?
  4. To whom and for what purpose are the processed personal data transferred by the Company?
  5. What is the method and legal reason for collecting personal data through cookies?
  6. What are the methods for changing cookie preferences?
  7. What are the rights of the Data Subject against the Company's personal data processing activities?
  
  

• 3.1. What is a Cookie?

  Cookie refers to text files consisting mostly of letters and numbers that are placed on the Relevant Person's devices or server by browsers as a result of visiting the Online Area, allowing the device to be recognized. Cookie usage preferences can be changed at any time by the methods specified in Article 5. Since cookies organize and improve the user experience on the Online Area, making changes in cookie usage preferences may also cause significant changes in the usage experience of the Online Area.

• 3.2. Types of Cookies Used

  The Company uses cookie technology for various purposes, primarily to improve the user experience in the Online Area of the Data Subject. These cookies may be session cookies or persistent cookies. There may be session cookies that are deleted when the browser used is closed, as well as persistent cookies placed on the hard disk of the device.

  1. Session cookies: Session cookies are cookies that are stored on the visited device when the Online Space is visited and deleted from the device when the browser is closed.
  2. Persistent cookie: Cookies that are saved on the device visited when the Online Area is visited and placed on the hard disk of the device and stored on the device for the lifetime of the browser's preferences and/or the cookie.
  3. Third party cookies: The Company also uses third-party cookies. Third party cookies are cookies that allow the cookies of third parties to be saved on the device visited when the Online Area is visited. Information on these cookies and changing cookie settings is provided in this Clarification Text.
  
  
• 3.3. Types of Cookies and Explanations

  Below are the types of cookies used by the Company in the Online Area and their descriptions according to their intended use:

  Cookie Type	Description
  Technical Cookies	Cookies that enable the Online Area to be used correctly. These cookies enable the fulfillment of functions such as creating an account, logging in, submitting forms. Areas and pages that are not working are detected. These cookies are saved on the Relevant Person's device while using the Online Area and are deleted from the device when the use ends.
  Analytical Cookies / Performance Cookies	These cookies are cookies that enable analysis of how the Online Area is used. They collect information about how the Data Subject uses the Online Area. The web pages viewed by the user, the time spent on these web pages, how many visitors visit the Online Area, which resources are used to access the Online Area are examples of this information collected.
  Targeting / Advertising Cookies	These cookies are used to enable the Data Subject to see behavioral and personalized advertisements on third websites and mobile applications according to their interests. By retargeting with these cookies, the pages visited in the Online Area are displayed in the advertising networks of third websites and mobile applications.
  Personalization Cookies / Functional Cookies	These are cookies that allow the Data Subject to adapt the Online Area user experience to their individual preferences. For example, information such as the language you choose while using the Online Area, username, the region where the Data Subject is located is collected to make the Online Area more functional and useful.

  
  
• 3.4. Cookies Used

  The types, names, types, usage periods and explanations of technical cookies, analytical/performance cookies, targeting/advertising cookies, personalization cookies and flash cookies used by the Company are given below.

  Technical Cookies
  Cookie Name	Description	Cookie Type (Persistent, Session, Third Party)	Storage Time
  (e-kom.com)	Defines site settings to the user.	Session	Session duration
  Analytical Cookies / Performance Cookies
  Cookie Name	Description	Cookie Type (Persistent, Session, Third Party)	Storage Period
  _ga (Google)	Analytical cookie used to distinguish users identified by Google Analytics, which we use to collect data about the number of visits and the user journey.	Third Party	2 years
  _gac_UA_XXXXXXXXXXXXX (Google)	Contains campaign-related information for the user. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you disable it.	Third Party	90 days
  _gat (Google)	This cookie is activated if Google Analytics is added to the site via Google Tag Manager.	Third Party	24 hours
  _gid (Google)	It is used to distinguish users.	Third Party	Indefinite
  Targeting / Advertising Cookies
  Cookie Name	Description	Cookie Type (Persistent, Session, Third Party)	Storage Period
  1P_JAR	It is used to get the statistical data of the site, the ads that the visitor saw before the site and the number of conversions.	Third Party (Google)	1 month
  AID	Coordinates advertising for Google account opened on different devices with Google advertising ID	Third Party (Google)	9 months
  APISID	Google shows personalized ads on Google sites based on a user's past searches.	Third Party (Google)	2 years
  CONSENT	It is used to distinguish anonymous users and measure the effectiveness of ads.	Third Party (Google)	2 years
  DSID ve IDE	Google DoubleClick for Publishers are cookies installed by the ad manager. They are used to improve ad delivery. It detects the user related to the content and prevents the same content from being shown multiple times in order to protect the ad campaign performance.	Third Party (Google)	10 days and 2 years
  G_ENABLED_IDPS	Allows login with Google.	Third Party (Google)	Indefinite
  HSID ve SID	It contains digitally signed and encrypted records of the user's Google account ID and the most recent login time. The combination of these two cookies allows us to block many types of attacks, such as attempts to steal the content of forms you complete on web pages.	Third Party (Google)	2 years
  NID	Google uses this cookie to track if the user has special settings. When you go to another page, it compares and understands this information (e.g. language, search options, etc.).	Third Party (Google)	6 months
  OGPC	Improves web browsing functionality.	Third Party (Google)	1 month
  SAPISID	By using these cookies, Google ensures that Google can collect user information for videos hosted by YouTube.	Third Party (Google)	2 years
  SIDCC	Google defines a security cookie to prevent unauthorized access by users.	Third Party (Google)	3 months
  SSID	Provides secure sign-in with Google service.	Third Party (Google)	2 years
  UULE	It collects anonymous user data and measures whether the ads shown are effective.	Third Party (Google)	2 years
  __gads	It helps measure the success of advertising campaigns by calculating the sum of sales generated by each campaign.	Third Party (Google)	2 years
  _utma	Used to distinguish users and sessions. The cookie is created when the javascript library is executed and there are no existing __hold cookies. The cookie is updated every time data is sent to Google Analytics.	Third Party (Google)	2 years
  __utmt	It is used to track requests and request rates.	Third Party (Google)	10 min
  __utmb ve __utmc	Used to identify new sessions/visits. Cookies are created when the javascript library is executed and there are no existing __utmb cookies. The cookie is updated every time data is sent to Google Analytics.	Third Party (Google)	30 min or session duration
  __utmz	It stores the traffic source or campaign that describes how the user reached your site. The cookie is created when the javascript library is executed and is updated every time data is sent to Google Analytics.	Third Party (Google)	6 months
  __utmv	Used to track custom variable data at visitor level.	Third Party (Google)	2 years
  	Identifies the web browser that connects to Facebook.	Third Party (Facebook)	2 years
  	Used in Facebook ad measurement and targeting.	Third Party (Facebook)	2 years
  	Includes unique browser and user ID. Activates ad targeting.	Third Party (Facebook)	90 days
  	The first value is a maximum two-digit number representing the session number. The second part of the value is the session cookie signature. The third, optional component is the "secure" flag if the user has enabled secure browsing.	Third Party (Facebook)	90 days or session duration
  	Contains the user ID of the logged in user.	Third Party (Facebook)	90 days or session duration
  	It stores the dimensions of the browser window and optimizes the pages to be rendered for subsequent sessions.	Third Party (Facebook)	6 month

  
  

The Company processes personal data with cookies for the realization of the explicit and legitimate purposes it has determined and only limited to this. It is aware that a personal data processing activity that does not serve these determined purposes will be contrary to the Law and takes care to process data in moderation with this awareness and sensitivity. Below are the general purposes in the use of cookies and personal data processing purposes according to their categories:
General Purposes:

1. Execution of company / product / service commitment processes
2. Conducting communication activities
3. Execution / supervision of business activities
4. Receiving and evaluating suggestions for improving business processes
5. Carrying out activities to ensure business continuity
6. Execution of goods / service sales processes
7. Execution of customer relationship management processes
8. Conducting activities for customer satisfaction
9. Conducting marketing analysis studies
10. Execution of advertising / campaign / promotion processes
11. Carrying out strategic planning activities
12. Execution of marketing processes of products/services
13. Creation and follow-up of visitor records

Objectives by Category:

Cookie settings can be changed by following the links below and changing the browser settings. These settings are usually found in the "options" or "preferences" menu of browsers. Detailed information on the subject can also be found by clicking on the "help " menu of the browsers. Removing cookies may cause the Online Area not to work as desired and the necessary efficiency may not be obtained.

In addition to these, to have more detailed information about cookies: "All About Cookies", "Your Online Choices" websites and/or use the "Privacy Badger"application.

With this Clarification Text, the Company enlightens the Relevant Persons regarding the processing of personal data through cookies and will use cookies by obtaining explicit consent in a way that leaves no room for doubt.
Personal data obtained through cookies may be transferred to third parties for the purposes listed in the table below, provided that the necessary measures are taken.

• 6.1. Domestic Transfer

  As a rule, data processed with cookies can be transferred domestically if the Data Subject has explicit consent.Personal data may be transferred
  without the explicit consent of the Data Subject if there is a clear regulation in the legislation regarding the transfer of personal data. Personal data may be transferred without the explicit consent of the Data Subject;

  1. If it is mandatory for the protection of the life or physical integrity of the personal data owner or someone else, and if the personal data owner is unable to disclose his consent due to actual impossibility or if his consent is not legally valid, it may be transferred to third parties.
  2. Provided that it is directly related to the establishment or performance of a contract, personal data may be transferred to third parties if it is necessary to transfer the personal data of the parties to the contract.
  3. If personal data transfer is mandatory for the Company to fulfill its legal obligation, personal data may be transferred to third parties.
  4. If personal data has been made public by the personal data owner, it may be transferred to third parties limited to the purpose of publicization.
  5. Personal data may be transferred to third parties if personal data transfer is mandatory for the establishment, exercise or protection of a right.
  6. vProvided that it does not harm the fundamental rights and freedoms of the Data Subject, personal data may be transferred to third parties if it is mandatory for the legitimate interests of the Company.
  
  
• 6.2. Transfer Abroad

  The Company transfers the personal data processed through cookies abroad only with the explicit consent of the Data Subject.
  The Company may also transfer the personal data of the Data Subjects abroad without explicit consent. In cases where the country or countries to which the personal data will be transferred (a) is one of the countries declared by the Board to have adequate protection or (b) if it is not one of the countries declared by the Board, permission has been obtained from the Board by obtaining a written commitment from the data controllers in the relevant foreign country providing adequate protection, personal data may be transferred abroad without explicit consent if one or more of the following conditions are present.

  1. If there is a clear regulation in the legislation regarding the transfer of personal data, it can be transferred abroad.
  2. If it is mandatory for the protection of the life or physical integrity of the personal data owner or someone else and if the personal data owner is unable to disclose his consent due to actual impossibility or if his consent is not legally valid, it may be transferred abroad.
  3. Personal data may be transferred abroad if it is necessary to transfer the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract without the explicit consent of the Data Subject.
  4. If personal data transfer is mandatory for the Company to fulfill its legal obligation, personal data may be transferred abroad.
  5. If personal data is publicized by the owner, it may be transferred abroad limited to the purpose of publicization.
  6. Personal data may be transferred abroad if personal data transfer is mandatory for the establishment, exercise or protection of a right.
  7. Personal data may be transferred to third parties without the explicit consent of the Data Subject, provided that it does not harm the fundamental rights and freedoms of the Data Subject, if personal data transfer is mandatory for the legitimate interests of the Company.

  Special Categories of Personal Data; The Company may transfer Special Categories of Personal Data abroad by taking the Explicit Consent of the Data Subject by applying administrative and technical measures and by complying with the special measures taken by the Board. In order for the Company to transfer Special Categories of Personal Data abroad even without obtaining the Explicit Consent of the Data Subject, the country or countries to which the personal data will be transferred (a) must be one of the countries declared by the Board to have adequate protection or (b) if it is not one of the countries declared by the Board, permission must be obtained from the Board by obtaining a written commitment from the data controllers in the relevant foreign country providing adequate protection, and (c) one or more of the following conditions must be present.

  1. i. Sensitive Personal Data other than health and sexual life: The Company will be able to process Sensitive Personal Data other than health and sexual life without obtaining the explicit consent of the data subject if explicitly stipulated in the legislation.
  2. ii. Sensitive Personal Data related to health and sexual life: For the protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, persons under the obligation of confidentiality or authorized institutions and organizations can be processed without seeking explicit consent.

During the use of cookies, the Company acts in accordance with the basic principles and the Law, as in its approach to personal data processing in general. The method and purposes of data collection with cookie technology are detailed in the light of the above articles.
Personal data collected for these purposes and legal reasons can also be processed and transferred for the purposes specified in Articles 3.5, 4 and 6 of the Clarification Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law.

• 8.1. Rights of the Data Subject

  The Data Subject has the right to apply to the Company regarding his/her personal data in the following matters;

  1. Learn whether personal data is being processed,
  2. Request information if their personal data has been processed,
  3. To learn the purpose of processing personal data and whether they are used for their intended purpose,
  4. iv. To know the third parties to whom personal data are transferred domestically or abroad,
  5. To request correction of personal data in case of incomplete or incorrect processing,
  6. Request deletion or destruction of personal data,
  7. In the event that personal data is incomplete or incorrectly processed, to request that third parties to whom personal data is transferred be notified of the transactions regarding the correction and/or deletion or destruction of personal data,
  8. To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
  9. In case of damage due to unlawful processing of personal data, to demand compensation for the damage.
  
  
• 8.2. Application to the Company

  The Company has prepared a Procedure in order to protect the rights of the Data Subject regulated in the Law and this Clarification Text and to fulfill its own obligations in this regard. In accordance with this Procedure, the Company shall make maximum effort to provide the information requested by the Data Subject by applying to the Company regarding the personal data of the Data Subject free of charge as soon as possible, within thirty days at the latest. If the transaction requires an additional cost, the fee in the tariff determined by the Board may be charged to the Data Subject. As a result of the examination of the request, the Company accepts the request or rejects it by explaining its reasoning and notifies its response to the Relevant Person in writing or electronically. If the request in the application is accepted, the Company shall fulfill the requirements of the request. In case the application is caused by the Company's error, the fee charged shall be refunded to the Relevant Person.The Relevant Persons may exercise their rights specified in Article 8.1. by filling out the Request Application Form and submitting it to Beylikdüzü OSB Mah. Hürriyet Bulvarı No:10/9, 34524 Beylikdüzü - İstanbul in person or by hand delivery through a proxy, by sending it to info@e-kom.com e-mail address or by sending it to ekom@hs02.kep.tr KEP address.