Personal Data Protection Policy

Introduction

This translation is provided for information. The legally binding version is the Turkish text.

Basic information on the protection of personal data transmitted to HC ORGANİZE TEKSTİL SAN. TİC. LTD. ŞTİ. is provided below. In order to fulfil its duty to inform under Article 10 of Law No. 6698 on the Protection of Personal Data ("KVKK"), hcorganize presents the following explanations to its customers and to third parties using our website. hcorganize reserves the right to update this Statement on the Protection of Personal Data at any time within the framework of changes that may be made to the applicable legislation.

1) What is the legal basis for hcorganize collecting personal data?

Various laws contain provisions on the use of our customers' personal data. First of all, the KVKK sets out the principles for the protection of personal data. Law No. 6563 on the Regulation of Electronic Commerce also contains provisions on the protection of personal data. Through the provisions of Turkish Penal Code No. 5237, criminal sanctions are also foreseen in certain cases for the protection of personal data. On the other hand, the collection and use of data is required to fulfil our obligations arising from Law No. 6502 on Consumer Protection and the Regulation on Distance Contracts.

2) Which methods does hcorganize use to collect personal data?

Data provided by our customers who make transactions through the website hcorganize.com or mobile applications is processed by HC ORGANİZE TEKSTİL in accordance with our customers' consent and the provisions of the legislation. The website hcorganize.com, owned by HC ORGANİZE TEKSTİL, uses cookies. A cookie is a file, usually consisting of letters and numbers, that is stored in the internet browser or on the hard disk of the device in use and allows that device to be identified.

In order to serve its visitors better and within the framework of its legal obligations, hcorganize.com will collect, process, share with third parties and securely store your browsing information, provided that it is not used outside the purposes and scope defined in this text. hcorganize.com stores the information it collects through cookies, log files, empty gif files and/or third-party sources in order to create a summary of your preferences. hcorganize.com may monitor your browsing information and/or your usage history on the site in order to provide you with tailored promotions, promotional and marketing offers, to improve the content of the website for you and/or to determine your preferences. hcorganize.com may match information collected from you on the site through different methods or at different times, such as information collected online and offline, and may use this information together with information obtained from other sources such as third parties.

3) How are website cookies used?

We use two types of cookies across our site: session cookies and persistent cookies. Session cookies are temporary and are valid only until you close your browser. Persistent cookies remain on your hard disk until you delete them or until they expire (how long cookies remain on your device depends on their "lifetime").

hcorganize.com uses cookies to remember the choices you make (site language and cookie consent) and for form security. Visits are measured by two separate and mutually independent methods; the data of the two is not combined on a per-person basis:

Server-side visit counter (cookieless)

When a page request reaches our server, only the date and time, page address, page language, country, the domain name of the referring website and the device type (desktop, mobile, tablet) are recorded. No tracking code, pixel, cookie or browser storage is added to the page for this counter; it does not require consent. IP address, unique visitor identifier and device fingerprint are not collected; the IP address is used in memory during processing only to determine the country and is not written anywhere. The country is determined on our server without sending a request to an external service (data: IP Geolocation by DB-IP, db-ip.com, CC BY 4.0). Raw records are kept for a maximum of 30 days, then summarised into daily totals and deleted; daily totals, which contain no personal data, are kept for a maximum of 25 months.

Google Analytics (only with permission)

For detailed measurement, such as where you connected to the website from, which content you viewed and the duration of your visit, hcorganize uses the Google Analytics service provided by Google LLC. Google Analytics cookies (_ga, _ga_*) are loaded only if you allow analytics cookies in the cookie window; no request is sent to Google without permission. If you give permission, usage data is transferred to Google LLC (USA) and processed on Google's servers; Google signals and ad personalisation are switched off, and Google Analytics 4 does not store IP addresses. When the quote form is submitted, only a "form submitted" event is sent to Google Analytics; name, email, telephone and company name are not included in this event. You can change or withdraw your permission using the "Cookie settings" link at the bottom of every page; when you withdraw it, the Google Analytics cookies are deleted. For more information on Google Analytics (including opt-out options): https://www.google.com/intl/tr/policies/privacy/

Third-party content embedded in the page, such as YouTube videos and Google Maps, is loaded only if you allow marketing cookies; if you do not, an external link is shown instead of the content.

You can allow or refuse cookies using the following methods:

In addition to the options above, to learn about all cookies and to manage cookies you can visit https://www.allaboutcookies.org and https://www.youronlinechoices.eu/ or use the "Privacy Badger" application (https://www.eff.org/tr/privacybadger). If you refuse persistent cookies or session cookies you can continue to use the website, but you may not be able to access all functions of the website or your access may be limited.

Cookies used on the site

Information on the cookies on hcorganize is given in the table below. The table is kept up to date with the cookies actually used on the site.

Changing your cookie preferences

We remember your preferences for 180 days. To change them or withdraw the permission you gave, use the link below or the "Cookie settings" link at the bottom of the page; the settings window will open. Open cookie settings

4) For what purposes does hcorganize use personal data?

Where and to the extent permitted by the legislation, hcorganize may record, store, update, disclose to third parties, transfer, classify and process your personal information. Your personal data is used for the following purposes:

• To verify the identity of the person submitting a request through the website,
• To record the address and other necessary information for communication,
• To communicate with our customers and to provide the necessary information about the conditions, current status and updates of the contracts we conclude under the distance sales contract and the relevant articles of the Law on Consumer Protection,
• To prepare all records and documents that will form the basis of the transaction in electronic (internet/mobile etc.) or paper form,
• To fulfil the obligations undertaken under the contracts we conclude under the distance sales contract and the relevant articles of the Law on Consumer Protection,
• To provide information to public officials on request and as required by legislation on matters relating to public security,
• To provide our customers with a better service experience, to inform our customers about our products that may interest them by taking their interests into account, and to communicate campaigns,
• To increase customer satisfaction, to recognise customers who submit requests through the website applications and to use this in customer profile analysis, to use it in various marketing and advertising activities and, in this context, to conduct surveys electronically and/or physically through contracted organisations,
• To enable our contracted institutions and solution partners to make suggestions to our customers and to inform our customers about our services,
• To evaluate customer complaints and suggestions about our services,
• To fulfil our legal obligations and to exercise our rights arising from the applicable legislation.

5) How does hcorganize protect your personal data?

Personal data shared with hcorganize is under the supervision and control of hcorganize. As data controller, hcorganize has assumed responsibility for establishing the necessary organisation and for taking and adapting technical measures to protect the confidentiality and integrity of information in accordance with the provisions of the applicable legislation. Aware of our obligation in this regard, we inform you that penetration tests are carried out at periodic intervals in accordance with international and national technical standards on data confidentiality, and that we always update our data processing policies in this context.

6) Does hcorganize share your personal data?

The sharing of our customers' personal data with third parties takes place within the framework of customer consent, and as a rule personal data is not transferred to third parties without our customer's approval. However, due to and limited to our legal obligations, personal data is shared with courts and other public institutions. In addition, personal data is transferred to contracted third parties in order to provide the services we have undertaken and to carry out quality control of the services provided.

The necessary technical and legal measures are taken to prevent violations of rights during the transfer of data to third parties. However, hcorganize is not responsible for violations arising from the data protection policies of the third party receiving the personal data or occurring in the risk area under the third party's responsibility.

Your personal data may be shared with hcorganize's shareholders, our direct/indirect domestic/foreign affiliates, the programme partner institutions and organisations we cooperate with to carry out our activities, the domestic/foreign persons and institutions from which we receive cloud storage services, the domestic/foreign organisations we have contracted with for sending commercial electronic messages to our customers, the Interbank Card Centre, the banks we have contracted with, and, within the scope of various marketing activities to serve you better and ensure customer satisfaction, various domestic and foreign agencies, advertising companies and survey companies, other domestic/foreign third parties and our relevant business partners.

7) What are your rights under the Law on the Protection of Personal Data?

We would like to remind you that under the KVKK you have the right, in relation to your personal data, to:

1. learn whether it is being processed,
2. request information if it has been processed,
3. learn the purpose of processing and whether it is used in accordance with that purpose,
4. know the third parties to whom it is transferred in Turkey / abroad,
5. request correction if it is incomplete / inaccurately processed,
6. request its deletion / destruction within the framework of the conditions set out in Article 7 of the KVKK,
7. request that the actions taken under items (d) and (e) above be notified to the third parties to whom it has been transferred,
8. object to a result arising against you through analysis exclusively by automated systems,
9. claim compensation for damage suffered due to processing in breach of the KVKK

as listed above. For the application form and the retention and disposal processes, please see the Personal Data Retention and Disposal Policy page.

8) How can I be informed of changes in personal data legislation?

The rights you have under the KVKK are the obligations of hcorganize. We would like to inform you that we process your personal data with this awareness and to the extent required by the legislation, that in the event of legal changes we will update the information on this page in accordance with the new legislation, and that you can easily follow the updates on this page at any time.

9) How can I be sure that data is kept up to date and accurate?

Under Article 4 of the KVKK, hcorganize is obliged to keep your personal data accurate and up to date. In this context, in order for hcorganize to fulfil its obligations arising from the applicable legislation, our customers need to share their accurate and up-to-date data with hcorganize. If your data changes in any way, please contact us through the communication channels stated below to update your data.

10) Would you like to ask hcorganize about your personal data?

For any questions and opinions regarding your personal data, you can contact us at any time at ik@hcorganize.com.