Cookie Policy

As Cerebra (“Company“), we attach great importance to protecting the security of your personal data that we process in our capacity as data controller within the scope of the Personal Data Protection Law No. 6698 (“KVKK“). Therefore, we would like to inform you about the processing of your personal data.

This Cookie Policy has been prepared by the Company in accordance with the KVKK and the relevant legislation and explains which types of cookies we use for what purposes and how you can manage these cookies regarding the processing of personal data obtained automatically through the placement of cookies used on the Company’s Website on your device.

What is a Cookie?

Cookies are pieces of information that we collect in order to provide better service to the visitors of the Website. They can also be defined as small files containing letters and numbers that can be placed on your device when you visit a website or use an application. We use cookies for the purposes set out below, together with improving your experience on the Website by remembering your preferences. Please note that without the use of cookies, your experience on the Website will be less user-friendly.

Which Types of Cookies Does the Company Use?

Types of Cookies by Duration of Use: Session cookies and persistent cookies are used on the Website according to the duration of use. Session cookies are used to ensure the continuity of the session and these cookies are also deleted when the browser is closed. Persistent cookies, on the other hand, are not deleted when the internet browser is closed and are automatically deleted on a certain date or after a certain period of time.

First Party and Third-Party Cookies: Whether the cookie is first-party or third-party varies according to the cookie placed by the website or domain. First-party cookies are placed directly by the website that the user visits, i.e. the URL shown in the address bar of the browser. Third-party cookies are placed by a domain different from the domain visited by the user. Both first-party cookies and third-party cookies are used on the Website. 

Types of Cookies by Purpose of Use: The following cookies are used on the Website according to the purpose of use: 

  • Mandatory Cookies: These cookies are cookies that are necessary for the operation of the Website.
  • Functional Cookies: These are cookies used for the purposes of personalization and remembering preferences used on the website or applications. Such cookies are used to provide functionalities other than mandatory cookies.
  • Performance and Analytical Cookies: These are cookies that allow statistical measurement in order to analyze the behavior of users. These cookies are often used to improve the site, including the measurement of the effect of advertisements on the relevant people. In addition, performance and analytical cookies allow counting visitors and measuring traffic on the website.
  • Advertising/Marketing Cookies: With these cookies, it is aimed to track the online movements of users in the internet environment, to determine their personal interests and to show advertisements to users in the internet environment for these interests.

You can access information about the cookies on the Website and the retention periods for these cookies and our business partners through the Website Cookie Management.

What is the Purpose and Legal Reason for Processing Your Personal Data?

Mandatory Cookies are used in order to fulfil the basic functions required for the active operation of the Website and an information society service you have requested. Your personal data collected through these cookies are processed within the scope of subparagraph (c) of paragraph (2) of Article 5 of the KVKK “Provided that it is directly related to the establishment or performance of a contract, it is necessary to process personal data belonging to the parties to the contract” or subparagraph (f) “Provided that it does not harm the fundamental rights and freedoms of the person concerned, it is mandatory to process data for the legitimate interests of the data controller“.

Functional Cookies are used to make the Website more functional and personalize it (to ensure that your other preferences, except for your privacy preferences, are remembered when you re-enter the site). Your personal data collected through these cookies are processed by obtaining your explicit consent in accordance with paragraph (1) of Article 5 of the KVKK.

Performance and Analytical Cookies are used for the purposes of counting visitors on the Website, measuring traffic, measuring, and improving the performance of our website. Your personal data collected through first-party cookies are processed within the scope of subparagraph (f) of paragraph (2) of Article 5 of the KVKK within the scope of “Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject”.  Your personal data collected through third party cookies are processed by obtaining your explicit consent within the scope of paragraph (1) of Article 5 of the Law.

Advertising/Marketing Cookies are used by our business partners to profile you according to your interests and to show you relevant advertisements. Your personal data collected through these cookies are processed by obtaining your explicit consent in accordance with paragraph (1) of Article 5 of the KVKK.

How Can You Manage Your Cookie Preferences?

For cookies other than mandatory cookies that we use on the Website, the explicit consent of the users is obtained, and they are provided with the opportunity to change their consent at any time. Users can see the types of cookies used on the Website through the “Site Cookie Management” and can set their preferences for all cookies other than mandatory cookies. Again, users can change their preferences at any time through the Site Cookie Management. By switching the buttons on the Site Cookie Management on or off according to your preference, click the “Confirm My Choices” button.

In addition, partial control can also be achieved through browser settings. You can access information on the management of cookies in frequently used browsers via the links below:

 

 

What Are Your Rights Regarding Your Personal Data and How Can You Exercise Them?

Your rights as a personal data subject are as follows:

  1. To learn whether personal data is being processed,
  2. Request information if personal data has been processed,
  3. To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
  4. To know the third parties to whom personal data are transferred domestically or abroad,
  5. To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this framework to third parties to whom personal data is transferred,
  6. To request the deletion, destruction or anonymization of such data within 30 (thirty) days in accordance with the provisions of the Regulation on the Deletion, Destruction or Anonymization of Personal Data in the event that the reasons requiring its processing disappear, although it has been processed in accordance with the provisions of the KVKK and other relevant laws, and to notify the third parties to whom the personal data has been transferred,
  7. To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
  8. In case of damage due to unlawful processing of personal data, to demand compensation for the damage.

The above-mentioned requests shall be submitted to the Company as the data controller in writing or by other methods to be determined by the Personal Data Protection Board (”Board”).

In this context, you can send your request regarding your above-mentioned rights to our e-mail address given below, via your registered electronic mail (KEP) address, by using your secure electronic signature, mobile signature or your e-mail address previously notified by you to the Company and registered in the Company’s system (by attaching documents identifying your identity), or you can hand-deliver a wet-signed petition with documents identifying your identity to our postal address below or send it through a notary public. Our contact information may change from time to time.

In the application that you have as a personal data owner and that you will make in order to exercise your rights mentioned above and that includes explanations regarding the right you request to exercise; the matter you request must be clear and understandable, the subject you request must be related to your person or if you are acting on behalf of someone else, you must be specifically authorized in this regard and this authorization must be documented, the application must contain your identity and address information.

How Long Will It Take to Receive a Response to Your Requests Regarding the Processing of Your Personal Data?The Company finalizes the requests in the application free of charge as soon as possible and within thirty days at the latest (if there is no cost) depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff to be determined by the Personal Data Protection Board may be charged. If the answers to the applications exceed 10 (ten) pages, a transaction fee of 1.00 (one) TL will be charged for each page. If the answer is requested to be given in a recording medium such as CD, flash memory, a fee will be charged according to the cost of the requested recording medium.

Cerebra reserves the right to change the terms of use and Cookie Policy regarding cookies.

Data Controller : Cerebra

Postal address: Büyükdere Cad. Quasar No:76 /172 Şişli / Istanbul 34394 Türkiye

E-mail address : [email protected]

* Cerebra Danışmanlık Hizmetleri Limited Şirketi & Cerebra Denetim Serbest Muhasebeci Mali, Müşavirlik Anonim Şirketi