Privacy Policy

Cozum Bilisim Technologies respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we collect and process your personal data when you use our online platform, interact with our services, or visit our site.

1. Important Information and Who We Are

This privacy policy applies to the use of our site and services provided by Cozum Bilisim Technologies.
Cozum Bilisim Technologies is the controller responsible for your personal data.

2. The Data We Collect About You

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

Identity Data: Includes first name, last name, username or similar identifier.
Contact Data: Includes billing address, delivery address, email address, and telephone numbers.
Technical Data: Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this site.
Profile Data: Includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data: Includes information about how you use our site, products and services.
Marketing and Communications Data: Includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.

We do not knowingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How is Your Personal Data Collected?

We use different methods to collect data from and about you including through:

Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our products or services; create an account on our site; subscribe to our service or publications; request marketing to be sent to you; or give us some feedback.
Automated technologies or interactions: As you interact with our site, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources, including Technical Data from analytics providers and Identity and Contact Data from publicly available sources.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Where you have given your consent.

We may use your personal data for purposes such as:

To register you as a new client or user.
To process and deliver our services.
To manage your relationship with us.
To enable you to participate in surveys or provide feedback.
To administer and protect our business and this site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
To use data analytics to improve our site, products/services, marketing, customer relationships and experiences.
To make suggestions and recommendations to you about goods or services that may be of interest to you.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

5. Disclosure of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes set out in this privacy policy.

External Third Parties such as service providers who provide IT and system administration services.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Regulators and other authorities who require reporting of processing activities in certain circumstances.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Your personal data may be transferred and stored outside of the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.

You can exercise these rights by contacting us using the details below.

You have the right to make a complaint at any time to the relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

10. Third-Party Links

Our site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy policy of every website you visit.

11. Children's Privacy

Our site and services are not intended for children under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16 without verifiable parental consent, we will take steps to remove that information from our servers.

12. Changes to the Privacy Policy

We keep our privacy policy under regular review. This version was last updated recently.

13. Contact Details

To contact us regarding this privacy policy or your personal data rights, please write to us at:

Cozum Bilisim Technologies
15 Cumhuriyet Caddesi
Kat: 7
Istanbul, Şişli, 34360
Turkey