The principles followed by Gülman Ventures while collecting and using personal data obtained from the users (“User(s)”) within their consent through the website (“Website”) are regulated under this Privacy Policy.
Personal Data That May Be Collected
Gülman Ventures may collect the following data about the User:
– ID – Transaction Security Information
– IP – Legal and Compliance Information
– Contact Information – Request/Complaint Management Information
– User Information – Incident Management Information
– User Transaction Information
and other information that may be required for the performance of services in relation to the Website and that are deemed as personal data pursuant the Law on the Protection of Personal Data and all other applicable legislation. User explicitly consents to processing of such data within the scope and purpose specified under this Privacy Policy.
Pursuant to Article 3 and 7 of the Law on the Protection of Personal Data, data that are irrevocably anonymized shall not be deemed as personal data according to said provisions, and processing activities with regard to such data shall be realized notwithstanding the provisions of this Privacy Policy.
Use of Cookies
Gülman Ventures, automatically collects information regarding the visited sections and clicked areas by the Users during their use of the Website. Such data obtained by using “Cookie” technology are statistical information. The purpose of this technology is to ensure that Users can easily access the content of the sections they visit from the very first visit made to the Website. Most of the browsers are designed to initially enable such “cookies” that are files of technical communication; however, Users, if they wish, may change the browser settings at any time in order not to receive technical communication files or so that a warning will be placed when the technical communication files are sent.
For the purposes of online behavioural advertising and marketing, Gülman Ventures is entitled to associate Users’ behaviour on the Website via a “cookie” placed in the browser and configure remarketing listings based on metrics such as number of page views, duration of visit and target completion numbers. Furthermore, Users may be displayed target-specific advertising content based on their area of interest on the Website or other sites in the visual advertisement network.
Purpose of Use of Data
Gülman Ventures shall use the collected personal data in order for the User to benefit from the Website, to conclude its membership registration to the Website as the case may be, to enhance and develop the services provided, to introduce new services and notify the Users of the new services, to make the necessary notifications in this regard, to contact the User and to perform the obligations arising from the nature of the services provided.
Personal data in question may be processed within the scope of Gülman Ventures reporting and business development activities, and may be used for the purposes of making various statistical assessments, forming a database and engaging in market researches without disclosing the User’s identity. In case the User gives a separate explicit consent, information in question may be processed, stored, transferred to third parties for the purposes of direct marketing by Gülman Ventures and the parties it is in cooperation with within the scope of such consent, and the User may be contacted for the purposes of promoting certain application, goods and services and making notifications with regard to the maintenance and support activities by using such information.
Pursuant to Articles 5 and 8 of the Law on the Protection of Personal Data and/or to the extent the exceptions set forth under the applicable legislation allow it, Gülman Ventures may process and share personal data with third parties without obtaining the User’s consent in the following cases, which are non-exhaustive:
- Processing is specifically provided for under the laws,
- Processing is necessary to protect the vital interests or bodily integrity of the data subject or a third person if the data subject is not in a condition to express his/her consent due to actual impossibility,
- Processing is necessary for execution or performance of a contract between User and Gülman Ventures,
- Processing is necessary for compliance with legal obligations,
- Personal data has been made public by the User itself,
- Processing is necessary for the establishment, exercise or protection of a right,
- Processing is necessary for the purpose of the legitimate interests pursued by Gülman Ventures provided that such interest does not harm the fundamental rights and freedom of the User.
- Prevent the unlawful processing of personal data,
- Prevent the unlawful access to personal data,
- Take necessary technical and administrative measures for ensuring the appropriate security level for the purposes of preserving personal data and to carry out the required audits.