I. General
As ADH Holding A.Ş. (“ADH”, “we” or the “Company”) we can use technologies such as cookies or pixel tag, flash cookies and web beacons that enable recording certain data in, and collecting certain data via, your computer, mobile phone, tablet and similar devices which you use to have access to our web site at the address of “adhholding.com/tr/” and at the addresses of“ADH Translation> Professional Translation and Localization Services / Mare Deluxe Residence- Luxury Resort Residence & Villa /ADH Holding 2022 (webflow.io)” which is managed by ADH (the “Web Site”), to our mobile applications, electronic platforms and other applications, and to the electronic mail messages which we send to you or to advertisements. In this Cookie Policy (the “Policy”), in order to express the cookies and similar technologies which can be used by ADH, the term “cookie” has been used. It is possible to collect personal data of the users by means of cookies; however, all data collected by cookies, may not be in the nature of personal data. In case the data collected by cookies, is in the nature of personal data within the framework of the Turkish Law, the Policy shall constitute annex of the Web Site Clarification Text. In this context, to get information regarding how your personal data can be processed and how youcan exercise your rights in this context, we suggest you to read the Web SiteClarification Text, too.
II. What is a Cookie?
Cookies are small information kept in a computer’s hard disc within browsers. They are used to offer a customized experience to the visitors when using a web site and to improve offered services, enhance the experiences. They may contribute to ease of use while surfing within a web site.
III. Cookie Types
Cookies may be categorized according to duration or the domain name, which they originate from. In case the cookies are classified according to duration, they are segregated in two groups, namely the “session cookies” and the “permanent cookies”. Session cookies: Session cookies are used in every session when theWeb Site or the Company’s other applications or environments are visited, and shall be deleted automatically, upon logging off the Web Site or related application. Purpose of this type of cookies is to ensure continuity and reliability of a visit. Permanent cookies: Permanent cookies shall be recorded, for a pre-determined fixed period, in the computer or other devices used by a user during access process, and shall not be deleted automatically, when related session or application is closed. Permanent cookies are used when we need to remember who you are in more than one session. Purpose of this type of cookies is to enhance web site’s functionality by offering visitors a quicker and better service. And, in case the cookies are classified according to the domain name which they originate from, they shall be segregated into two groups, namely the “related party cookies” and the “third party cookies”.Related party cookies: Related party cookies refer to cookies placed on the website, by a visited domain, and which can be read by that web site only. Third party cookies: Third party cookies refer to the cookies placed by a different domain which is visited. In cases where persons out of a visited domain, place cookies on a user’s device via visited domain; these are called third party cookies.
IV. Purpose(s) of Using Cookies
As ADH, we may benefit from the cookies which we use on our web sites, platforms, in our applications, advertisements and messages, for the purposes specified below: Uses for operational purposes: We may use the cookies deemed necessary for supervision and security of our web sites, platforms, applications or services. As example of cookies used for operational purposes; technologies which enable to benefit from the functions available on web sites, applications and platforms, and the cookies which are used to identify irregular behaviours in said media, can be shown. Uses intended for functionality: We may use necessary cookies for the purposes of facilitating use of our web sites, platforms, applications and services, and customizing them for our users. As sample of cookies for functionality purposes; technologies which enable us to recall user information and choices, can be shown. Uses intended for performance purposes: We may also use necessary cookies for the purposes of enhancing and assessing the performance relating to our web sites, platforms, applications or services. As sample of cookies used for this purpose; cookies which enable us to comprehend how the users use our web sites, applications, platforms and services, and to analyze user behaviours, and technologies which enable us to understand whether any interaction is realized, or not may be shown. Uses for advertising purposes: We may use related party cookies and third party cookies for the purpose of sending advertisement and similar contents within the scope of the users’ fields of interest, via web site, platforms and applications which belong to the Company or third persons. As sample of uses for advertising purposes; cookies that assess efficiency of advertisements and cookies that show whether a certain advertisement is clicked, or not, or how many times an advertisement is clicked may be shown.
V. Rejecting and Deleting Cookies
Most browsers are set to accept cookies, automatically as default. However, user may reject or delete cookies at any time by changing browser settings, at any time when they wish to do so.Method of changing the setting of browser varies depending on browser; information should be obtained from the service provider relating to used browser, regarding how cookies can be deactivated. Generally, you reject cookies by the methods specified below: Changing your browser’s settings to warn you receive cookie, deactivating current cookies, adjusting settings of your browser to reject cookies automatically. We would like to indicate that, in case cookies are deactivated, it may not be possible to benefit from some features of our web sites, applications, platforms or services. You can change the settings of your browser by clicking related link in following table.Google Chrome - Examine Internet Explorer - Examine Mozilla Firefox - ExamineMicrosoft Edge - Examine Opera- Examine Safari - Examine VI.
VI. Authorized Service Providers
You can receive assistance from some service providers authorized by us, as ADH, for conducting and promoting the Web Site, our platforms, applications and services. These service providers authorized by our Company may also place cookies and similar technologies (third party cookies) on users’ computers and other devices and may collect the information intended for identifying user’s devices, such as IP address, unique identifier and device identifier.
VII. Cookies Used by ADH
Operational, functional and performance-related cookies: They do not cause any harm to your computer, they do not contain any virus. They are required to use the WebSite’s interface and features, as desired. They enable you to comprehend how the Web Site is used by the visitors, and assist you to combine statistical data and to develop content in line with said data. They provide you the opportunity to speed up the activities during visits you shall make in the future. In no circumstance, they enable us to collect, store and process the data by which we can identify you; they are not in the nature of personal data.And, the targeting and advertising cookies are used for the purposes of personalizing the advertisements and analyzing the site’s traffic, within the scope of our legitimate interests and as necessary legal undertakings are taken, provided that your essential rights and freedoms are not prejudiced. In the following table, you can find the information regarding the cookie used byADH and the purpose of using the cookie. Name of the Cookie Purpose of the Cookie Google Analytics is a type of cookie used for the purpose of determining the links that enable the visitors to have access to the Web Site, their numbers and distribution according to the areas regarding which they are placed on the Web Site, the tabs which are of their interest on the Web Site and the time they spent therein.
VIII. WebSites, Products and Services of Third Persons
Our web sites, platforms or applications may contain various links in relation to web sites, products and services of third persons. Said links are subject to cookie and confidentiality policies of third persons, and one should be aware that any third persons and web sites of third persons are independent from ADHand that ADH shall not be responsible for cookie and confidentiality practices of third persons. In case the web sites, to which link is provided, are visited, we suggest that cookie and confidentiality policies of those web sites be read..
I. Method of Collecting Your Personal Data
We, as ADH, collect the personal data of the visitors of our Web Site, by completely or partially automatic means; when you visit the Web Site, by the cookies contained in the Web Site, when you fill in the “Communication Form”contained in the “Communication” tab in the Web Site, by contents of e-mail messages which you send to the info address contained in the Web Site, when you complete the content of “Sign In” contained in the Web, by e-mail correspondences made with ADH via the corporate e-mail address, by your curriculum vitae you send to the “ik@adhholding.com” e-mail address contained in the Web Site.
II. YourData, Legal Reason of Processing and Collecting Your Data
Your personal data which we shall obtain by the collecting methods explained above, shall be as defined in the following table: Personal Data Categories Data TypesIdentity Data Name Surname Communication Data E-mail address, Phone CustomerTransaction Data Legal consent given for sending electronic commercial messages, Request and complaint information Transaction Security Data Web site; connection/log in-off (log record) and time information relating to your visit,IP address Marketing Data Information obtained by used cookies OtherInformation Subject title, Message content information, Your curriculum vitae information, E-mail content information (content of e-mails which you send, bye-mail, to ADH’s corporate e-mail addresses and the information contained in your e-mail signature) Your personal data contained in related table shall be processed for the purposes of taking and evaluating the measures intended to improve business processes and the services we offer, conducting the customer or visitor relations management processes, ensuring your distinguishability by your name, surname and e-mail address within the Web Site, enabling you to be distinguished by your name and surname among the visitors within the scope of conducting communication activities and following requests and complaints, responding to your all kinds of questions and complaints relating to our services and activities, by classifying them according to the subject of the question you ask, responding to your all kinds of questions and complaints relating to our services and activities, in a way most convenient for your request, by making our internal researches based on specific information you provide us, making correspondences regarding offers and agreements for the purpose of conducting the product and/or service sales and/or supply processes, conducting the agreement and settlement processes relating to the product and/or service sales and/or supply processes, conducting the storage and archive operations intended for proving the legal relations, to which ADH is party, making necessary transactions in relation to requests and messages sent, by e-mail, to thee-mail addresses with ADH extension, conducting the selection and recruitment processes by the curriculum vitae which you send us via the e-mail addressik@adhholding.com, sending results of applications to the candidates via various means, within the scope of conducting the activities we carry out, in compliance with the legislation, fulfilling our obligation to keep traffic records, explicitly set forth in the Law no.5651 on Regulating the PublicationsMade in Internet Environment and Combating Against Crimes Committed by way ofThose Publications, and related legislation, with regards to legal consents given by you, fulfilling the Company’s legal obligations and keeping the consent records in compliance with the law, if you give consent, sending advertisement and promotion contents relating to services we offer you, conducting the marketing analysis works and strategic planning activities, conducting the product or service marketing processes, providing use of the Web Site more efficiently, quickly and easily, customizing the services and activities offered by you, according to your usage manner and your needs, and recommending them to you, and providing necessary technical support and quality according to your requests, being able to perform necessary works for you to be informed about current articles, news and bulletins relating to fields of activities for which we offer services, and to avail yourself of our services and activities, taking all necessary technical and administrative measures within the scope of data security, performing necessary audits in order to ensure technical security thereof; and shall be collected by ADH based on the legal reasons set forth in article 5 of the LPPD (Law on Protection of Personal Data), namely; it is necessary to process personal data of the parties since it is directly related with conclusion and implementation of related agreement; it is explicitly set forth in the laws; processing of personal data is required for the purpose of fulfillment of ADH’s legal obligation; processing of personal data is required for establishing, exercising or protecting a right; provided that related person’s fundamental rights and freedoms are not prejudiced, processing of personal data is required for legitimate interests of ADH.
III. Persons to Whom Your Personal Data Shall Be Disclosed and Purpose of Disclosure
Your personal data may be disclosed, within the scope of the personal data processing terms and conditions and purposes set forth in articles 8 and 9 of the LPPD; to ADH HOLDING companies for the purposes of managing the Company, conducting the business, implementing the Company’s policies; to developer firms with which we have agreement, for the purpose of improving ADH internet services; and to message sending service providers with which we have agreement, for the purposes of sending you commercial electronic messages and non-commercial electronic messages for information purposes, if you give consent; and to lawyers, auditors, tax consultants and other third persons from whom we receive consulting services, for the purposes of enabling us to conduct our business processes in accordance with the law and our other legitimate interests, to exercise our defence right in a potential judicial process; to regulatory and supervisory agencies and official authorities like courts and execution offices and other public institutions and organizations authorized to demand your personal data, for the purpose of fulfillment of our legal obligations; to your proxies and representatives authorized by you, for the purpose of meeting your requests.
IV. Your Rights Relating to Your Personal Data
You have the rights;
a. To learn whether your personal data is processed or not,
b. If your personal data is processed, to request information in relation thereto,
c. To learn the purpose of processing your personal data and whether it is used appropriately for its intended purpose,
d. To know the third persons, to whom your personal data is disclosed in Türkiye and abroad,
e. Incase your personal data is processed incompletely or incorrectly, to request correction thereof,
f. To request erasure or destruction of the personal data within the framework of the conditions set forth in article 7 of the LPPD,
g. To request that the transactions made according to the subparagraphs (e) and (f),be notified to third persons to whom personal data is disclosed,
h. To object to any outcome which shall occur to your disadvantage as a result of analysis of your processed data exclusively via automated systems,
i. Incase you suffer any damages due to processing of your personal data illegally, to request indemnification of such damages suffered by you. You can make your requests within the scope of said rights you have, personally or send them via notary public in writing or by using registered electronic mail (REM), secure electronic signature, mobile signature or your electronic mail address which shall be declared by you to the Company in advance and which shall be registered in the Company’s system. Your application shall be answered according to related provisions set forth in the LPPD, and in order to verify that the applicant is the correct person, ADH may request identifying information from your; such information shall be requested only for the purposes of identifying actual data subject and sharing application results, with the right person.
V. Communication Details
ADH Holding A.Ş.
Mersis No: ************
REM Address: adhholding@******.kep.tr
CommunicationLink: http://www.adhholding.com/iletisim
Address: Esentepe Mah. Kore Şehitleri Cad. Istanbloom No: 16/1 K: 4 D: 39-40 Zincirlikuyu, Şişli, İstanbul, Türkiye