Confidentiality Agreement

Disclosure and Privacy Policy Regarding the Protection of Personal Data (“Disclosure and Privacy Policy”) In order to fulfill our obligation to inform under Article 10 of the Personal Data Protection Law No. 6698 (“KVKK”), which determines the principles regarding the processing of personal data and the obligations of natural and legal persons who process personal data, we present the explanations below to our customers (“Customer”) and third parties (“Users”) who use our website and/or mobile application. Ziya Translation reserves the right to update this Disclosure Text Regarding the Protection of Personal Data at any time within the framework of changes that may be made in the applicable legislation.

1. Who is the Data Controller?

Your personal data may be processed by Ziya Turizm Sanayi İç ve Dış Ticaret Limited Şirketi (“Ziya Translation”), registered with the Istanbul Trade Registry under registration number 291863-0 and located at Akşemsettin Mah. Akdeniz Cad. No:100/1 Fatih/Istanbul, as the data controller pursuant to KVKK.

2. Which Personal Data Do We Process? By Which Methods Are the Collected Personal Data Processed?

The data collected by Ziya Translation from Customers and Users through the methods specified below depend on the products purchased and services used by the Customers and Users. Under this heading, the personal data processed within the scope of the Services provided by Ziya Translation and considered as personal data under the Personal Data Protection Law are listed below.

• Name and Contact Information: Name, surname, mobile phone, home phone, work phone, address, email address, billing information, Turkish ID number (national identity number), and other similar documents.
• Identity Verification Information: Users' membership information, used to verify identity and provide account access, such as Username, contact information, password hints, User numbers, ad numbers.
• Demographic Data: Date of birth, age, gender, marital status, educational background, profession.
• Usage Data: Name and Contact Information, Identity Verification Data, and Demographic Data.
• Location Data: Location data to be stored and used via IP address.
• Payment Data: Customer billing and payment information (name, surname, billing address, Turkish ID number, tax identification number).

3. Where Are Personal Data Stored and Processed?

Your personal data that we obtain may be stored within Ziya Translation or service providers with whom we collaborate within the country and may be processed in line with the purposes specified in this Information Text and proportionate to these purposes. The personal data collected within the scope of this Information Text will be processed in accordance with the provisions here and within the scope of the legislation in force in the country where the data are stored and processed, including the prescribed security measures.

4. For What Purpose Will Your Personal Data Be Processed?

In line with the purposes included in this Information Text and the User Agreement, your personal data will be processed in accordance with the Principles and Processing Conditions regulated by KVKK and within the scope of the purposes detailed below:

Name and Contact Information: Internal company evaluation, communication, User registration, obtaining potential customer information, improving post-sales processes, business development, collection, customer portfolio management, promotion, analysis, complaint management, managing customer satisfaction processes, marketing, advertising, research, billing, event notification, conducting operational activities, measuring and improving service quality, audit, control, optimization, customer verification, marketing, sales, advertising, post-sales services, detection and prevention of fraud;

Identity Verification Information: User registration, problem/error reporting, control, developing and conducting operational activities, improving post-sales processes, business development, collection, internal company evaluation, customer portfolio management, measuring service quality, communication, optimization, moderation, audit, risk management, customer verification, detection and prevention of fraud;

Demographic Data: Promotion, internal company evaluation, analysis, communication, improving post-sales processes, business development, collection, usage data and interests, favorites, marketing, sales, advertising, audit and control, risk management, improving post-sales processes, business development, collection, internal company evaluation, customer portfolio management, post-sales services, measuring and improving service quality, communication, conducting complaint management processes, conducting and improving operational activities, registration, problem/error reporting;

Usage Data: User registration, problem/error reporting, control, inquiry, conducting and improving operational activities, post-sales services and improving post-sales processes, business development, collection, internal company evaluation, online behavioral advertising and marketing, customer portfolio management, measuring and improving service quality, communication, optimization, audit, risk management and control, promotion, analysis, determining interests, scoring, profiling, marketing, sales, advertising, communication, conducting complaint management processes, registration, problem/error reporting;

Payment Data: Managing billing process, accounting, improving post-sales processes, business development, collection, internal company evaluation, scoring, profiling, customer portfolio management, post-sales services, communication, marketing, audit, control, processes conducted with payment service providers;

Content: Business development, optimization, customer portfolio management, audit, control, developing operational activities, promotion, internal company evaluation, customer management, analysis, scoring, profiling, improving post-sales processes, collection, post-sales services, communication, measuring and improving service quality, conducting complaint management processes;

Within the framework of contracts made with third real or legal persons with whom Ziya Translation has a business relationship or obligations arising from legal regulations, in order to fulfill legal and commercial obligations, performing obligations arising from contracts made with business partners/customers/suppliers by Ziya Translation, establishing rights, protecting rights, conducting commercial and legal evaluation processes, conducting legal and commercial risk analyses, conducting legal compliance processes, concluding tests conducted to determine whether the user can receive the documents specified in the relevant legal regulations, conducting financial affairs, fulfilling legal requirements, fulfilling the decisions of authorized institutions, organizations, and authorities, responding to their requests, within the personal data processing conditions and purposes specified in Articles 5 and 6 of KVKK.

5. How Long Do We Keep Your Personal Data?

Ziya Translation will retain the personal data it obtains for the period necessary for the purpose for which they were processed, in order to enable Customers and Users to benefit from Ziya Translation Services in the best way, within the conditions specified in this Information Text and the Membership Agreement, and to fulfill the obligations arising from the nature of the Membership Agreement.
In addition, in case of any dispute that may arise, Ziya Translation will keep personal data limited to the purpose of conducting administrative or judicial processes within the scope of the dispute and throughout the statute of limitations determined under the relevant legislation.

6. To Whom and For What Purpose Can the Processed Personal Data Be Transferred?

The sharing of personal data belonging to Customers and Users with third parties takes place within the framework of the consent of Customers and Users, and as a rule, personal data are not transferred to third parties without the approval of the relevant persons. However, personal data are shared with courts and other public institutions due to our legal obligations and limited to them. Necessary technical and legal measures are taken to prevent rights violations during data transfer to third parties.

Your personal data may be shared with our direct/indirect domestic/foreign affiliates, program partner institutions and organizations with whom we cooperate to carry out our activities, domestic persons and institutions from whom we receive cloud storage services, domestic organizations with whom we have an agreement to send commercial electronic messages to our customers, the Interbank Card Center, banks with whom we have an agreement, and various domestic agencies, advertising companies, and survey companies within the scope of various marketing activities to provide you with better service and ensure customer satisfaction, and other domestic third parties and our relevant business partners. Ziya Translation may share personal data belonging to Customers and Users and new data obtained by using these personal data or personal information that Customers and Users enter on the website through their positive actions, primarily to fulfill the requirements of the Membership Agreement, to improve the Customer and User experience (including improvement and personalization), to ensure the security of Customers and Users, to detect and prevent fraud, to develop Services, to carry out inquiry activities that may be of importance for Services, to conduct operational evaluation research, to eliminate errors, to verify User identities, with third real and/or legal persons including corporate members, cargo companies, law firms, research companies, call centers, software companies related to complaint management and ensuring security, agencies, consulting companies, companies in the printing sector, social media platforms, and with authorized institutions, organizations, authorities, administrative and judicial bodies within the scope of legal obligations, to the extent required by the transfer while performing Services. In addition, the User's Name and Contact Information will be shared with payment institutions for the purpose of identity verification in accordance with the payment institution framework agreement that they will approve at the payment stage and the Regulation on Measures Regarding Prevention of Laundering Proceeds of Crime and Financing of Terrorism published in the Official Gazette dated January 9, 2008 and numbered 26751. Your personal data obtained through cookies placed on your device may be shared with third parties within the scope and purposes specified in this Information Text and Privacy Policy. Ziya Translation may transfer personal data to third parties within the country limited to these purposes and proportionate to these purposes within the categories and purposes specified above.

7. Method and Legal Reason for Collecting Personal Data

Data You Provide Directly to Ziya Translation: It refers to the personal data that Ziya Translation collects from Customers and Users on their own initiative before or during the use of our website and for the performance of Services. These personal data include all personal data provided directly by Customers and Users to Ziya Translation as a result of their positive actions. For example, name-surname, contact information, identity information, answers to surveys, demographic data, and content information are included in such data.

8. Data We Obtain When You Use Our Website: It includes personal data regarding the usage habits of Customers and Users received through certain software or technological tools during the services provided by Ziya Translation. For example, location data and interests along with favorites and usage data are included in such data.

Ziya Translation collects usage data such as the number of pages viewed, visit duration, and target completion number based on metrics by associating the behaviors of the user who visits the site with a cookie (browser) in the browser, even if they are not members, for the purpose of online behavioral advertising and marketing. How cookies are managed is also specified in our Cookie Policy under Article 8 below.

Your personal data collected by these methods are based on the legal reasons specified in Articles 5 and 6 of KVKK:
• Being explicitly stipulated in the laws,
• Being mandatory for the fulfillment of legal obligations (legal regulations regulating electronic commerce activities, financial and tax matters, consumer protection, and other issues),
• Being necessary for the establishment or performance of the contract directly related to the processing (Membership Agreement, Terms of Use, and performance of the contract based on them, establishment and protection of the right),
• Being mandatory for legitimate interest,
• Being made public by you,
• Being mandatory for the establishment, use, or protection of a right,
• Having your explicit consent
These legal reasons are based on.
Your personal data collected by these methods can be processed and transferred for the purposes specified in this Information Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of KVKK.

Legal grounds for collecting personal data:

Performance of the contract based on the Membership Agreement, Terms of Use, and based on them, establishment and protection of the right Legal regulations regulating electronic commerce activities, financial and tax matters, consumer protection, and other issues It is based on the legitimate interest of Ziya Translation in collecting the necessary data to carry out its services, especially to prevent fraud, in the activities carried out through its website.

9. How Are Website Cookies Used?

Ziya Translation has the right to associate the behaviors of the user who visits the site with a cookie in the browser, even if they are not members, for the purpose of online behavioral advertising and marketing, and to define remarketing lists based on metrics such as the number of pages viewed, visit duration, and target completion number, to use marketing automation tools, and to send special messages/offers and suggestions to the user. Later, it may display targeted advertising content to this user on the site or other sites according to the interests of the users. In addition, during the redirection of Google AFS ads to Ziya Translation, Google may place cookies on USERS' browsers or read cookies placed there or use web beacons to collect information.

10. Our Measures and Commitments Regarding Data Security

Personal data shared with Ziya Translation are under the supervision and control of Ziya Translation. Ziya Translation undertakes to keep personal data securely. Necessary technical and administrative measures are implemented using various methods and security technologies to prevent unlawful processing and access to personal data and to ensure the preservation of personal data at an appropriate security level.

In case links are given to other applications through the website, Ziya Translation is not responsible for the privacy policies and contents of the linked applications. The Customer and User undertake that the information subject to this Disclosure and Privacy Policy is complete, accurate, and up-to-date, and that they will immediately update such information in case of any changes. In case the Customer and User do not provide up-to-date information, Ziya Translation will not have any responsibility.

11. Rights of the Personal Data Owner Enumerated in Article 11 of KVKK

Pursuant to Article 11 of the Law, data owners have the right to;
a. Learn whether their personal data is processed or not,

b. Request information if their personal data has been processed,

c. Learn the purpose of processing personal data and whether they are used in accordance with their purpose,

d. Know the third parties to whom personal data is transferred domestically or abroad,

e. Request correction of personal data if they are incomplete or incorrectly processed and request that the transaction performed within this scope be notified to third parties to whom personal data is transferred,

f. Although it has been processed in accordance with the provisions of the Law and other relevant laws, request the deletion or destruction of personal data in case the reasons requiring processing disappear and request that the transaction performed within this scope be notified to third parties to whom personal data is transferred,

g. Object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems and, in case of damage due to unlawful processing of personal data, request compensation of the damage.

You can submit your request to exercise your rights specified above, in Turkish and with the attached Application Form, to Ziya Translation as the data controller, in writing to the address specified in the Application Form with documents identifying your identity, via notary or by other methods determined by the Personal Data Protection Authority. Ziya Translation will conclude the said requests by evaluating them within 30 days. Ziya Translation reserves the right to charge a fee over the fee tariff determined (if any) by the Personal Data Protection Board regarding the requests.

You can reach us at any time at the email address ziyatercume@ziyagroup.com.tr for any questions and opinions regarding your personal data.

Ziya Translation reserves the right to verify your identity before responding.

Ziya Turizm Sanayi İç ve Dış Ticaret Limited Şirketi