As Hitit Bilgisayar Hizmetleri Anonim Şirketi (“Hitit”, “Site Owner”), we are working and endeavoring to ensure that confidentiality of the members using our site is protected so as to provide for our users full and secure utilization of and benefiting from our services. In parallel thereto, this Confidentiality Policy (“Policy”) is prepared for processing of our members’ personal data in full compliance with Law Number 6698 For Protection Of Personal Data (“Law”) and advise our users to this effect.

Purpose of this Policy comprises of setting forth and determining the terms and conditions with respect to the usage of personal data shared by and between Hitit and members/visitors/users (all together to be jointly referred to as “Relevant Person”) in the course of operating of such Internet site (“Site”) with domain name https://hitit.com/by Hitit or such personal data processed by the Relevant Person during usage of the Site.

1.    Monitoring of conditions regarding confidentiality and security/alteration: Site Owner is entitled to make changes in and to the provisions concerning confidentiality and security any time without notifying in advance or bring forth any extra provisions to that effect. Any and all changes made for being advised and acknowledged about the qualities and characteristics of any data collected in the course of usage, how the same are used, under which conditions and circumstances such data are shared with third parties as well as being aware of any necessary confidentiality provisions. As the Site Owner keeps reserved its right to make changes in the confidentiality provisions, it is necessary that confidentiality and security provisions should be regularly followed-up and read.

2.    User data: User is responsible for any and all kinds of contents placed in the Site by the User, transmitted or conveyed via the Site (including but not limited to any and all kinds of written material, documents, music, notices, advertisements, ideas and opinions transmitted, all kinds of contents containing voice or writing or mobile/immobile images). Users declare and guarantee the reliability, accuracy of all sorts of data and information transmitted/forwarded to the Site, that they are not violating any rights of third parties nor in breach of laws. Hitit hereby keeps reserved its right to remove from the Site either partially or in full or prohibit access, any contents placed by the Users in the Site, believing to bring any damage or burden to other Users or third parties, or which are contrary to the legislations currently in practice Notwithstanding the foregoing, it has no further obligation other than the context set forth and prescribed under the relevant legislations to that effect.

3.    Protection of data: Hitit is exhibiting maximum effort for security of all pages on the web site. In order to protect and ensure the confidentiality, security and integrity of all data available in the Site, it is being made use of various technical and administrative applications.

4.    Auxiliary programs of the Site: The User might be required to use auxiliary programs for benefiting from certain sections and parts of the Site. In case of making use of such parts and sections, data and particulars with respect to the form and scope of utilization could possibly be entered and recorded in the Site’s database. Similarly, for your ease of utilizing and making use of the parts and sections, it might be made use of certain “cookies”, we could send certain data to the user through these. You are welcome to Access to Hitit Cookies Policy from the link (https://hitit.com/cookie-policy) contained hereunder.

WHICH DATA ARE PROCESSED FOR WHAT PURPOSE?

·       Hitit is capable of collecting and compiling such personal data like name, surname, address/place of residence, IP data, e-mail, telephone number. These data and particulars are data provided by the Relevant Person to the Site and recorded thereunder. In case the User prefers to share its personal data as well as contents sent under the selected level of sharing with other users or any third parties, such data and contents so recorded shall be open to other users and third parties as well.

·       Hitit could use any personal data provided by the User, upon obtaining express consent of the User in such circumstances deemed necessary, in parallel to such purposes like enabling access to the Site, member access and entry, providing for security of the Site, analysis of user habits, likings and preferences, formation of statistics, communication, marketing, making announcements, in accordance with the legislations in practice as well as Personal Data Policy, process and keep the same and share these in parallel to these purposes with such third parties both locally as well as abroad, cooperated with, further use the same within framework of advertising, marketing, notification in connection with the field of operations of Hitit and such other similar activities, categorize and keep the same under data bases, make use of such data available in these databases. To this end, Site Owner could as well process the site activity data, tools of access and any browser data.

·       Sensitive Personal Data: Site Owner is strictly not requesting from the Users in any way and manner howsoever, any sensitive data and particulars such as those pertaining to racial and ethnic identity, religious/political/philosophical thought and belief, physical or mental health condition and particulars. Hitit bears no responsibility whatsoever on grounds of any of the aforesaid data and particulars having been provided, entered or disclosed by the user.

·       Commercial communication: In case of your express approval to that effect, Hitit could possibly send electronic messages or commercial electronic messages to the site or to your correspondence address communicated to its side or entered/caused to be entered. You are entitled any time to use your right to cancel any authorization/approval given and refuse receiving any electronic messages of commercial character. Rejection requests shall be processed by Hitit within no later than 3 business days. 

FOR HOW LONG ARE PERSONAL DATA KEPT AND PRESERVED?

Personal data of the Relevant Person are to be kept and maintained for a period of time prescribed under the relevant legislations in practice to enable Hitit perform its obligations under the Law or required for the purpose for processing of the same and in the event of removal of the causes necessary for  processing thereof, personal data shall be erased, deleted or made anonymous by Hitit in parallel to the request of the Relevant Person to that effect.

VIOLATION OF CONFIDENTIALITY AND SECURITY PROVISIONS

In the event of failing to be complied with the confidentiality provisions or in case of any attempts towards acquisition of the processed personal data by others through illegal ways and methods, Hitit shall be advising and informing any such circumstance both to the Relevant Person as well as to the Board as soon as possible, regardless of whether or not violation is realized in full.  To this end, it keeps reserved the right, in order to provide for and ensure data security, including the right of rejection of any data available in the system, removing from the content and deleting the same, suspending access of the users to the site as well as any of the services without giving any notice in advance, termination and cancellation of membership (although not compulsory). This rule is valid for any circumstances in case of indirect breach or attempted breach of the provisions by any individual acting in the name of the User.

WHAT ARE THE RIGHTS OF THE PERSONAL DATA OWNER?

Site Owner is informing you related to your respective rights pursuant to Article 10 of the Law, directing you regarding how the subject matter rights are to be used and fulfilling any necessary internal functioning, administrative and technical arrangements and organizations required therefore. Pursuant to Article 11 of the Law, Site Owner explains to the individuals whose Personal Data are received, that they are entitled;

·   To learn whether or not their personal data are processed,

·   If their personal data are processed, to request information accordingly, ,

·   To learn about the purpose for processing of the personal data and whether or not they are used in accordance with such purpose,

·   Being informed in connection with any third parties both locally as ell as abroad, whom personal data are transferred to,

·   To ask for correction and rectification of personal data if these are processed as incomplete or incorrect,

·   To ask for deletion or elimination of personal data within framework of the conditions prescribed under Article 7 of the Law,

·   To ask for informing any third parties whom personal data are transferred to, the transactions made pursuant to items (d) and (e) of Article 11 of the Law,

·   To raise objection to any result adverse to the individual himself/herself in the event of analysis of the processed data exclusively via automatic systems,

·   To claim for elimination of any loss and damage suffered on grounds of illegal processing of personal data.

Data Responsible in Charge: Hitit Bilgisayar Hizmetleri Anonim Şirketi

E-mail: [email protected]

Kep Address: [email protected]

Address: Reşitpaşa Mah. Katar Cad. No: 4/1 Arı Teknokent 2 İç Kapı No: 601 - 34469 Maslak/Sarıyer/İstanbul