SINERJI GRUP ENDUSTRI OTOMASYON TIC. VE SAN. LTD. STI. COOKIE DISCLOSURE TEXT
In accordance with Article 10 of the Law on the Protection of Personal Data No. 6698 (KVKK) and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Disclosure Obligation; as Sinerji Grup Endüstri Otomasyon Tic. ve San. Ltd. Şti. (hereinafter referred to as the “Company” or “Sinerji Grup”), we inform you in our capacity as the data controller regarding your personal data processed through cookies used during your visit to our website.
In accordance with the decision of the Personal Data Protection Board dated 26.07.2018 and numbered 2018/90, “The fulfillment of the disclosure obligation by the data controller is not subject to any approval.” Our Company fulfills its disclosure obligation independently of the consent processes, and in accordance with the provision of Article 5/1-f of the Disclosure Communiqué and the rule stated in the same Board decision that “In case the personal data processing activity is carried out based on the explicit consent condition, the disclosure obligation and the obtaining of explicit consent must be fulfilled separately,” it has separated the disclosure and consent-taking processes. Accordingly, the principle that “the processes of fulfilling the disclosure obligation and obtaining explicit consent must be performed separately” is meticulously applied in the infrastructure of our website.
Cookies are small text files stored on your device (computer, smartphone, tablet, etc.) through your browser when you visit our website. As Sinerji Grup, we use cookies on a transaction basis and in accordance with the nature of the activity for the purposes of ensuring the technical operation of our website, improving your user experience, analyzing site traffic, and offering personalized advertising/marketing activities to you.
As clearly stated in the decision of the Personal Data Protection Board dated 10.03.2022 and numbered 2022/229, it is accepted as a fundamental principle by our company that “while explicit consent of the data subjects will not be required for strictly necessary cookies for the proper functioning of a website; the use of cookies operating for advertising, marketing, and performance purposes is subject to the explicit consent of the data subject.”
A) Strictly Necessary Cookies
These are cookies that are mandatory for the fulfillment of the basic functions of our website and for ensuring security. These cookies cannot be disabled.
B) Functional Cookies
These are used to provide you with a more personalized experience by remembering your preferences (language, region, etc.) on our website.
C) Performance and Analytical Cookies
These are cookies that allow us to understand how visitors use our website, measure the frequency of visits to pages, and improve site performance.
D) Advertising and Marketing Cookies (Profiling)
These are cookies placed through our third-party business partners (Google, Meta, etc.) for the purposes of promoting products and services suitable for your interests, carrying out targeted advertising activities, and reaching you on platforms outside our site.
Our Company applies the rule stated in the decision of the Personal Data Protection Board dated 10.03.2022 and numbered 2022/229 that “in case personal data processing activity is carried out with cookies that are not in the status of strictly necessary cookies and one of the processing conditions in Article 5(2) and Article 6(3) of the Law is not present, the explicit consent of the data subject must be sought” regarding non-mandatory (Functional, Performance, and Marketing) cookies.
In line with the same decision, the obligation that “it must obtain explicit consent according to the ‘opt-in’ mechanism, which envisages that cookies do not work as a default setting” is fulfilled on our site. In accordance with the precedent stated in the decision of the Personal Data Protection Board dated 27.02.2020 and numbered 2020/173 that “the assumption that the matters in the privacy notice have been accepted merely by using Amazon services cannot be qualified as a legally compliant explicit consent,” your continued browsing on our website is not accepted as an implied consent. As mandated in the decision of the Personal Data Protection Board dated 28.09.2023 and numbered 2023/1645, “obtaining explicit consent through the ‘opt-in’ method by presenting options for each type of cookie that requires explicit consent” is ensured on our site.
Sinerji Grup may share personal data obtained through cookies with authorized public institutions and organizations for the purpose of fulfilling legal obligations.
However, some Performance/Analytical and Advertising/Marketing cookies used on our website (e.g., Google Analytics, Facebook Pixel) belong to third-party service providers whose servers are located abroad. If you consent to these cookies, your personal data will be transferred abroad.
In the decision of the Personal Data Protection Board dated 17.03.2022 and numbered 2022/249, it was determined that “the transfer of personal data abroad does not differ from other personal data processing activities such as changing, reorganizing, recording, storing, and preserving” and that “there is no legal ground other than explicit consent in the concrete case regarding the transfer activity abroad.” Additionally, in the decision of the Personal Data Protection Board dated 28.09.2023 and numbered 2023/1645, it was emphasized that “in cases where websites operating in Turkey carry out data transfer activities abroad through cookies used via companies resident abroad, this data transfer activity must be carried out in accordance with the conditions in Article 9 of the Law.” In line with these legal requirements, cross-border data transfers occurring through third-party cookies are carried out only based on the explicit consent you provide within the scope of KVKK Article 9.
In accordance with Article 11 of the KVKK, you have the following rights as a data subject:
To exercise these rights, you can fill out the Data Subject Application Form available on our website and submit it in writing to our company’s registered headquarters address with documents verifying your identity, or via your e-mail address registered in our systems. Your applications will be finalized free of charge as soon as possible and within thirty days at the latest, depending on the nature of your request.
You can change your preferences at any time and withdraw your explicit consent through the Cookie Management Panel that appears upon your first entry to our website. You can also completely block or delete cookies from the settings section of the internet browser you use. However, we would like to remind you that if you block strictly necessary cookies, some parts of our website may not function properly.
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