Çerez Politikası

**Protection of Personal Data Communication and Cookie Policy Disclosure Ece Ticari Gayrimenkul Yatırım ve Yönetim Hizmetleri A.Ş.** Ece Ticari Gayrimenkul Yatırım ve Yönetim Hizmetleri A.Ş. (ECE) processes your personal data in the capacity of data controller in accordance with the Law on the Protection of Personal Data No. 6698 (KVKK) and related legislation. Pursuant to Article 10 of the KVKK, which regulates the Obligation to Inform, data controllers are obliged to inform the data subjects whose personal data they process about certain matters. This disclosure has also been drafted in accordance with the Communique On Principles And Procedures To Be Followed In Fulfillment Of The Obligation To Inform, published by the Personal Data Protection Authority, in order to fulfill the legal obligation. **Data Subject** You, whose personal data are processed by ECE, are defined as a Visitor (Internet) due to your visit to our website and you are considered to be a Data Subject by the Law. **Data Controller** ECE is the data controller, who determines the purposes and means of processing your personal data, and is responsible for the establishment and management of the data recording system. **Obtaining Your Personal Data** Your personal data obtained and the methods of obtaining your personal data are provided below. The same personal data can be obtained by more than one method. Method / Environment Data Directly from you with automated methods Electronically Name, Surname, E-Mail Address, Telephone Number, Subject of Communication, Communication authorization, Communication Authorization Source, Communication Authorization Time, Message Content, IP Address, Posting Time, Posting Date, Persistent cookie and Session cookie; **Purposes and Legal Reasons for Processing Your Personal Data** The following table lists the legal grounds and purposes of processing your personal data. Since it is mandatory for the data controller to fulfill their legal obligation in KVKK Art.5/2d For the purpose of carrying out storage and archiving operations Pursuant to the Retention of Communication Permissions (Article 13/2) in the Regulation on Commercial Communication and Commercial Electronic Messages; E-Mail Address, Telephone Number, Communication Authorization, Communication Authorization Source, Communication Authorization Time, and IP Address Provided that the fundamental rights and freedoms of the data subject in Article 5/2g of the KVKK are not violated if data processing is mandatory for the legitimate interests of the data controller. To carry out activities for customer satisfaction Session cookie and Persistent cookie To carry out performance evaluation processes Analytical-Performance Cookies and Targeting-Advertising Cookies To carry out communication activities Communication Authorization Source, Communication Authorization Time, and IP Address To carry out marketing analysis studies Analytical-Performance Cookies and Targeting-Advertising Cookies For the purpose of carrying out storage and archiving operations Name, Surname, E-Mail Address, Telephone Number, Subject of Communication, Message Content, Posting Date, and Posting Time In case you grant your explicit consent according to KVKK Art.5/1 To carry out communication activities Name, Surname, E-Mail Address, Telephone Number, Subject of Communication, Communication Authorization, Message Content, Posting Date, and Posting Time In case you grant your express consent regarding the transfer of personal data abroad, which is regulated in Article 9/1 of the KVKK; To carry out marketing analysis studies Analytical-Performance Cookies and Targeting-Advertising Cookies **Transfer of Your Personal Data** Your personal data may be transferred to the relevant authorities without the obligation to inform and without your explicit consent in case they are requested within the framework of Article 28/1 of the KVKK. In unforeseen circumstances apart from this, your personal data may be transferred to public institutions (administrative authorities such as ministries, Presidential boards, etc.) specified in the law, within the scope and limitations stipulated in the law, if requested in cases clearly stated in the law. Apart from our legal obligations that do not require the obligation to inform and do not require your explicit consent; The following table shows the recipients of your transferred personal data and the purposes for which they are transferred. Buyer / Purpose Data to Google Inc. To carry out website analysis and marketing activities Analytical-Performance Cookies and Targeting-Advertising Cookies; **Your Rights Regarding Your Personal Data** Data subjects must first apply to the data controller in order to exercise their rights regarding their personal data. According to Article 14 of the Law, no direct complaint can be made to the Personal Data Protection Authority. In accordance with the law, you may exercise the following rights regarding your personal data by applying to the data controller, i.e. us. a) Learn whether their Personal Data is processed or not, b) Request information about your personal data if they have been processed, c) Learn the purpose of processing the personal data and whether they are used appropriately for their purpose, d) Know the third parties to whom personal data is transmitted in the country or abroad, e) In case personal data is processed deficiently or incorrectly, request the correction of such, f) Request the deletion or destruction of your personal data in case the reasons that require processing are eliminated, g) Request that the transactions conducted as per sub-clauses (e) and (f) be notified to the third parties to whom your personal data is transferred, h) Object to the occurrence of a consequence against you through analyzing the processed data exclusively on automated systems, i) Request the remedy of damages in case of any damages suffered due to illegal processing of the Personal Data. **Method of Application to the Data Controller** You can apply using one of the following methods: In writing to Gayrettepe Mahallesi Prof. Dr. Bülent Tarcan Cadde No: 5 Beşiktaş / Istanbul; By e-mail to eceplaza@hs01.kep.tr Registered E-Mail (REM) address using your REM address By e-mail to kvkk@pakgrp.com using your e-mail address registered as yours in our systems. Detailed information on the procedures and principles to be followed when making an application can be found in the Communiqué on Procedures and Principles of the Application to Data Controller of the Personal Data Protection Authority. Ece Ticari Gayrimenkul Yatırım ve Yönetim Hizmetleri A.Ş. **COOKIE POLICY** **What is Cookie Policy?** Cookies are small text files that are stored on your computer or mobile device when you visit a website. Your IP address, login information, pages you access, etc. data is stored in these files. Thanks to cookies, your website preferences can be remembered, your session can be kept open, or you can be presented with the content you are interested in. There are different types of cookies according to criteria such as their storage time on mobile devices and by whom they are placed. Within this context, types of cookies can be listed as Persistent Cookies, Session Cookies, First-Party Cookies, and Third-Party Cookies. **Cookies** The Cookie Policy has been drafted to inform website users about cookies and the types of cookies used, and to guide them on how they can manage their cookie preferences. Pak Holding A.Ş. (hereinafter referred to as "Data Controller" or "Company") uses cookies, etc. technologies to improve the visiting experience of website users and increase the quality of service, as with many websites. In order for the Data Controller to most efficiently benefit from the www.pakgroup.com website they manage and to improve the user experience, Cookies are used on these Platforms, subject to the consent granted at the access. If you opt-out of cookies, you can delete or block Cookies from your browser's settings. However, please remember that this may affect your use of the Platforms. **• What is a cookie and why is it used?** Cookies are small text files that are stored on your device or network server via browsers by the websites you visit. Detailed information on cookies can be found at www.aboutcookies.org and www.allaboutcookies.org. 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 our website, • To improve our website, to offer new features on our website, and to customize the features offered according to your preferences; • To ensure the legal and commercial security of our website, you and our Company. • To use within the scope of direct and indirect marketing activities • Categories of Cookies Used on Our Website Technical Cookies The technical cookies ensure the operation of our website and detect the pages and areas of the website that are not working. Analytical Cookies Analytical cookies are cookies that produce analytical results such as the number of visitors to our website, the pages viewed on our website, the visiting hours of our website, and the scrolling movements of website pages. **• Cookies Used on Our Website** **Cookie** **Analytical and Advertising Cookies** **Google** These cookies enable the collection of all statistical data, thereby improving the presentation and use of the website. They are used to display behavioral and target-oriented advertisements to visitors. Google helps us better understand users by adding social statistics and interest data to these statistics. Our website uses Google Analytics cookies. The data collected with these cookies are transferred to Google servers located in the USA and the data is stored in accordance with Google's data protection principles. Please click here to learn more about Google's analytical data processing activities and the personal data protection principles. Control of Cookies https://tools.qooqle.com/dlpaqe/qaoptout **Technical Cookies** **Session** Session cookies are used to ensure the continuity of the session. **Load-Balancing** Load-balancing cookies are used to reduce the server load by distributing the load. •** Can the Use of Cookies Be Blocked by Data Subjects?** Data subjects may customize their preferences regarding cookies by changing their browser settings. If the browser used offers this feature, it is possible to change the preferences regarding Cookies through the browser settings. Thus, although it may differ based on the features offered by the browser, data subjects can prevent the use of cookies, choose to receive a warning before the use of cookies or disable or delete only certain Cookies. Preferences regarding cookies may need to be made separately for each device from which the user accesses the website. Adobe Analytics http://www.adobe.com/uk/privacy/opt-out.html AOL https://help.aol.com/articles/restore-security-settings-and-enable-cookie-settings-on-browser Google Adwords https://support.google.com/ads/answer/2662922?hl=en Google Analytics https://tools.google.com/dlpage/gaoptout Google Chrome http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647 Internet Explorer https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies MozillaFirefox http://support.mozilla.com/en-US/kb/Cookies Opera http://www.opera.com/browser/tutorials/security/privacy/ Safari: https://support.apple.com/kb/ph19214?locale=tr_TR **Protection of Personal Data "Visitor (Internet)" Express Consent and Declaration** According to the Law on the Protection of Personal Data No. 6698, data controller Ece Ticari Gayrimenkul Yatırım ve Yönetim Hizmetleri A.Ş. (ECE) requires your explicit consent to process certain personal data about you. **Your Personal Data to be Processed Based on Your Express Consent and Purposes of Processing** The personal data processed by Pak Holding and the purposes of processing pursuant to KVKK Art.5/1; To carry out communication activities Name, Surname, E-Mail Address, Telephone Number, Subject of Communication, Communication Authorization, Message Content, Posting Date, and Posting Time The personal data that can be transferred abroad and the purposes of processing pursuant to KVKK Art. 9/1; To carry out marketing analysis studies Analytical-Performance Cookies and Targeting-Advertising Cookies I have read the disclosure drafted by Ece Ticari Gayrimenkul Yatırım ve Yönetim Hizmetleri A.Ş., I hereby accept and declare that my personal data can be processed in accordance with the purposes and conditions stated in the disclosure. If you grant the permissions/approvals specified within the scope of the information above, click the "**I accept**" box on the screen to indicate your acceptance, consent, and approval.