1.ARTICLE-INTRODUCTION
Introduction
Law No. 6698 on the Protection of Personal Data (“Law”) imposes important obligations on personal data processors in order to protect the fundamental rights and freedoms of individuals, especially the right to privacy. Headquarters address Atatürk Mah. Ertuğrul Gazi Sokak Metropol İstanbul C1 Blok No:2 B/131 Ataşehir – İstanbul, Kaı Lojistik Limited Şirketi (“Company”), registered in the Istanbul Trade Registry, takes a meticulous and sensitive approach as Data Controller in order to fulfill the relevant obligations and to make all processes related to data processing in accordance with the legislation.
In light of this approach, the Company explains the cookie technology used on the Company’s website https://kailogistics.com/ (Online Area), the processes of processing personal data obtained with this technology in all its dimensions and aims to enlighten and inform the Data Subjects with this text (“Clarification Text”).
Scope
In this Clarification Text, the Data Subjects will be enlightened within the scope of the following questions regarding the personal data processing activity carried out by the Company with the cookie technology used in the Online Area:
- What is the Company’s minimum identification information?
- What are the types and characteristics of the cookies used in the Online Area?
- For what purposes are personal data obtained through cookies processed?
- To whom and for what purpose is the processed personal data transferred by the Company?
- What is the method and legal reason for collecting personal data through cookies?
- What are the methods for changing cookie preferences?
- What are the rights of the Data Subject against the Company’s personal data processing activities?
2.ARTICLE – DEFINITIONS
“Recipient Group” refers to the category of natural or legal persons to whom personal data is transferred by the data controller.
“Online Area” refers to the Company’s website with the domain name https://kailogistics.com/.
“Data Subject” refers to the natural person whose personal data is processed through cookies.
“Personal Data” means any information relating to an identified or identifiable natural person.
“Processing of Personal Data” refers to all kinds of operations performed on personal data such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic means or by non-automatic means provided that it is part of any data recording system.
“Sensitive Personal Data” refers to data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing, association, foundation or trade union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data.
“Data Category” refers to the class of personal data belonging to the data subject group or groups where personal data are grouped according to their common characteristics.
“Data Subject Group” refers to the category of persons whose personal data are processed by data controllers.
“Board” refers to the Personal Data Protection Board.
“Request Management Procedure” refers to the guiding procedure that determines the details of the Data Subject’s right to apply to the Company, which is the Data Controller recognized in Article 11 of the Law, and the Company’s response process regarding the application.
“Data Controller” refers to the natural or legal persons who determine the purposes and means of processing personal data, who are responsible for the establishment and management of the data recording system, and in the specific context of this Clarification Text, the Company responsible for this activity.
3.Cookies Used in the Online Area
Cookie refers to text files consisting mostly of letters and numbers that are placed on the Relevant Person’s devices or server by browsers as a result of visiting the Online Area, which enables the device to be recognized. Cookie usage preferences can be changed at any time by the methods specified in Article 5. Since cookies organize and improve the user experience on the Online Area, making changes in cookie usage preferences may also cause significant changes in the usage experience of the Online Area.
The Company uses cookie technology for various purposes, primarily to improve the user experience in the Online Area of the Data Subject. These cookies may be session cookies or persistent cookies. There may be session cookies that are deleted when the browser used is closed, as well as persistent cookies placed on the hard disk of the device.
- Session cookies: Session cookies are cookies that are saved on the device visited while visiting the Online Area and deleted from the device when the browser is closed.
- Persistent cookies: Persistent cookies are cookies that are saved on the device visited when the Online Area is visited and placed on the hard disk of the device and stored on the device for the lifetime of the browser’s preferences and/or the cookie.
- Third party cookies: The Company also uses third-party cookies. Third-party cookies are cookies that allow third parties’ cookies to be saved on the visited device when the Online Area is visited. Information on these cookies and changing cookie settings is provided in this Clarification Text.
Types of Cookies and Explanations
Below are the types of cookies used by the Company in the Online Area and their descriptions according to their intended use:
Cookie Type | Description |
Technical Cookies | Cookies that enable the Online Area to be used correctly. These cookies enable the fulfillment of functions such as creating an account, logging in, submitting forms. Areas and pages that are not working are detected. These cookies are saved on the Relevant Person’s device while using the Online Area and are deleted from the device when the use ends. |
Analytical Cookies / Performance Cookies | These cookies are cookies that enable the analysis of how the Online Area is used. They collect information about how the Data Subject uses the Online Area. The web pages viewed by the user, the time spent on these web pages, how many visitors visit the Online Area, which resources are used to access the Online Area are examples of this information collected. |
Targeting/Advertising Cookies | These cookies are used to enable the Data Subject to see behavioral and personalized advertisements on third websites and mobile applications according to their interests. By retargeting with these cookies, the pages visited in the Online Area are displayed in the advertising networks of third websites and mobile applications. |
Personalization Cookies /Functional Cookies | These are cookies that allow the Data Subject to adapt the Online Area user experience to their individual preferences. For example, information such as the language you choose while using the Online Area, username, the region where the Data Subject is located is collected to make the Online Area more functional and useful. |
Flash Cookies | Cookies that ensure that the images and sounds in the Online Space are loaded on the device and can be viewed and listened to correctly. |
The types, names, types, usage periods and explanations of technical cookies, analytical/performance cookies, targeting/advertising cookies, personalization cookies and flash cookies used by the Company are given below.
Necessary Cookies
| Cookie Key | Area | Road | Cookie Type | Duration End | Description |
| elementor | kailogistics.com | / | First party | Session | This cookie is used by the WordPress theme of the website. It allows the website owner to implement or modify the content of the website in real time. |
Functional Cookies
| Cookie Key | Area | Road | Cookie Type | Duration End | Description |
| _gcl_au | .kailogistics.com | / | First party | 3 months | Provided by Google Tag Manager to test the advertising efficiency of websites using their services. |
| _ga | .kailogistics.com | / | First party | 1 year 1 month 4 days | The _ga cookie installed by Google Analytics calculates visitor, session and campaign data and also tracks site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. |
| _gid | .kailogistics.com | / | First party | 1 day | The _gid cookie installed by Google Analytics stores information about how visitors use a website and generates an analysis report on the performance of the website. Some of the data collected includes the number of visitors, their sources and the pages they visit anonymously. |
| _gat_gtag_UA_* | .kailogistics.com | / | First party | 1 minute | It is set by Google to distinguish users. |
| _ga_* | .kailogistics.com | / | First party | 1 year 1 month 4 days | This cookie is installed by Google Analytics. |
| AnalyticsSyncHistory | .linkedin.com | / | Third party | 1 month | Linkedin has set this cookie to store information about when a synchronization with the lms_analytics cookie occurred. |
| ln_or | .kailogistics.com | / | First party | 1 day | Linkedin sets this cookie to save statistical data about users’ behavior on the website for internal analytics. |
Analytical Cookies
| Cookie Key | Area | Road | Cookie Type | Duration End | Description |
| _gcl_au | .kailogistics.com | / | First party | 3 months | Provided by Google Tag Manager to test the advertising efficiency of websites using their services. |
| _ga | .kailogistics.com | / | First party | 1 year 1 month 4 days | The _ga cookie installed by Google Analytics calculates visitor, session and campaign data and also tracks site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors. |
| _gid | .kailogistics.com | / | First party | 1 day | The _gid cookie installed by Google Analytics stores information about how visitors use a website and generates an analysis report on the performance of the website. Some of the data collected includes the number of visitors, their sources and the pages they visit anonymously. |
| _gat_gtag_UA_* | .kailogistics.com | / | First party | 1 minute | It is set by Google to distinguish users. |
| _ga_* | .kailogistics.com | / | First party | 1 year 1 month 4 days | This cookie is installed by Google Analytics. |
| AnalyticsSyncHistory | .linkedin.com | / | Third party | 1 month | Linkedin has set this cookie to store information about when a synchronization with the lms_analytics cookie occurred. |
| ln_or | .kailogistics.com | / | First party | 1 day | Linkedin sets this cookie to save statistical data about users’ behavior on the website for internal analytics. |
Advertising Cookies
| Cookie Key | Area | Road | Cookie Type | Duration End | Description |
| test_cookie | .doubleclick.net | / | Third party | 15 minutes | test_cookie is set by doubleclick.net and is used to determine whether the user’s browser supports cookies. |
| _fbp | .kailogistics.com | / | First party | 3 months | This cookie is set by Facebook to display advertising on Facebook or a digital platform powered by Facebook advertising after you visit the website. |
4.Cookie Usage Purposes
The Company processes personal data with cookies for the realization of the explicit and legitimate purposes it has determined and only limited to this. It is aware that a personal data processing activity that does not serve these determined purposes will be contrary to the Law and takes care to process data in moderation with this awareness and sensitivity. Below are the general purposes in the use of cookies and personal data processing purposes according to their categories:
General Objectives
- Execution of company / product / service commitment processes
- Conducting communication activities
- Execution / supervision of business activities
- Receiving and evaluating suggestions for improving business processes
- Carrying out activities to ensure business continuity
- Execution of goods / service sales processes
- Execution of customer relationship management processes
- Conducting activities for customer satisfaction
- Conducting marketing analysis studies
- Execution of advertising / campaign / promotion processes
- Carrying out strategic planning activities
- Execution of marketing processes of products/services
- Creation and follow-up of visitor records
5.Change in Cookie Settings
Cookie settings can be changed by following the links below and changing the browser settings. These settings are usually found in the “options” or “preferences” menu of browsers. Detailed information on the subject can also be found by clicking on the “help” menu of the browsers. Removing cookies may cause the Online Area not to work as desired and the necessary efficiency may not be obtained.
In addition to these, to have more detailed information about cookies: https://www.allaboutcookies.org , https://www.youronlinechoices.eu/ and/or use the “Privacy Badger” application (https://www.eff.org/tr/privacybadger)
6.Transfer to Third Parties
With this Clarification Text, the Company enlightens the Relevant Persons regarding the processing of personal data through cookies and will use cookies by obtaining explicit consent in a way that leaves no room for doubt.
Personal data obtained through cookies may be transferred to third parties for the purposes listed in the table below, provided that the necessary measures are taken.
Buyer Group | Transfer Purpose |
1.Natural persons or private legal entities (Company lawyer, advertising agency, business partners, etc.) 2.Authorized public institutions and organizations (Courts, etc.) | 1. Ensuring business continuity 2. Execution of goods / service sales processes 3. Execution of customer relationship management processes 4. Conducting activities for customer satisfaction 5. Conducting marketing analysis studies 6. Execution of advertising / campaign / promotion processes 7. Carrying out strategic planning activities 8. Execution of marketing processes of products/services 9. Carrying out storage and archive activities 10. Informing authorized persons, institutions and organizations |
Domestic Transfer
As a rule, data processed with cookies can be transferred domestically if the Data Subject has explicit consent.
Personal data may be transferred without the explicit consent of the Data Subject if there is a clear regulation in the legislation regarding the transfer of personal data. Personal data may be transferred without the explicit consent of the Data Subject;
- If it is mandatory for the protection of the life or physical integrity of the personal data owner or someone else, and if the personal data owner is unable to disclose his consent due to actual impossibility or if his consent is not legally valid, it may be transferred to third parties.
- Personal data may be transferred to third parties if it is necessary to transfer personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract.
- If personal data transfer is mandatory for the Company to fulfill its legal obligation, personal data may be transferred to third parties.
- If personal data has been made public by the personal data owner, it may be transferred to third parties limited to the purpose of publicization.
- Personal data may be transferred to third parties if personal data transfer is mandatory for the establishment, exercise or protection of a right.
- Provided that it does not harm the fundamental rights and freedoms of the Data Subject, personal data may be transferred to third parties if it is mandatory for the legitimate interests of the Company.
Transfer Abroad
The Company transfers the personal data processed through cookies abroad only with the explicit consent of the Data Subject.
The Company may also transfer the personal data of the Data Subjects abroad without explicit consent. In cases where the country or countries to which the personal data will be transferred (a) is one of the countries declared by the Board to have adequate protection or (b) if it is not one of the countries declared by the Board, permission has been obtained from the Board by obtaining a written commitment from the data controllers in the relevant foreign country providing adequate protection, personal data may be transferred abroad without explicit consent if one or more of the following conditions are present.
Method and Legal Grounds for Collecting Personal Data
During the use of cookies, the Company acts in accordance with the basic principles and the Law, as in its approach to personal data processing in general. The method and purposes of data collection with cookie technology are detailed in the light of the above articles.
Personal data collected for these purposes and legal reasons may also be processed and transferred for the purposes specified in Articles 3.5, 4 and 6 of the Clarification Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law.
Rights of the Data Subject and Application to the Company
- If there is a clear regulation in the legislation regarding the transfer of personal data, it can be transferred abroad.
- If it is mandatory for the protection of the life or physical integrity of the personal data owner or someone else and if the personal data owner is unable to disclose his consent due to actual impossibility or if his consent is not legally valid, it may be transferred abroad.
- Personal data may be transferred abroad if it is necessary to transfer the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract without the explicit consent of the Data Subject.
- If personal data transfer is mandatory for the Company to fulfill its legal obligation, personal data may be transferred abroad.
- If personal data is publicized by the owner, it may be transferred abroad limited to the purpose of publicization.
- Personal data may be transferred abroad if personal data transfer is mandatory for the establishment, exercise or protection of a right.
- Personal data may be transferred to third parties without the explicit consent of the Data Subject, provided that it does not harm the fundamental rights and freedoms of the Data Subject, if personal data transfer is mandatory for the legitimate interests of the Company.
- Sensitive Personal Data; The Company may transfer the Personal Data abroad by taking the Explicit Consent of the Data Subject by applying administrative and technical measures and by complying with the special measures taken by the Board. In order for the Company to transfer Special Categories of Personal Data abroad even without obtaining the Explicit Consent of the Data Subject, the country or countries to which the personal data will be transferred (a) must be one of the countries declared by the Board to have adequate protection or (b) if it is not one of the countries declared by the Board, permission must be obtained from the Board by obtaining a written commitment from the data controllers in the relevant foreign country providing adequate protection, and (c) one or more of the following conditions must be present.
- Sensitive Personal Data other than health and sexual life: The Company will be able to process Sensitive Personal Data other than health and sexual life without obtaining the explicit consent of the data subject if explicitly stipulated in the legislation.
- Sensitive Personal Data relating to health and sexual life: For the purposes of protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, persons under the obligation of confidentiality or authorized institutions and organizations can be processed without seeking explicit consent.
7.Method and Legal Grounds for Collecting Personal Data
During the use of cookies, the Company acts in accordance with the basic principles and the Law, as in its approach to personal data processing in general. The method and purposes of data collection with cookie technology are detailed in the light of the above articles.
Personal data collected for these purposes and legal reasons may also be processed and transferred for the purposes specified in Articles 3.5, 4 and 6 of the Clarification Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law.
8.Rights of the Data Subject and Application to the Company
Rights of the Relevant Person
The Data Subject has the right to apply to the Company regarding his/her personal data in the following matters;
- Learn whether personal data is being processed,
- Request information if their personal data has been processed,
- To learn the purpose of processing personal data and whether they are used for their intended purpose,
- To know the third parties to whom personal data are transferred domestically or abroad,
- To request correction of personal data in case of incomplete or incorrect processing,
- Request deletion or destruction of personal data,
- In the event that personal data is incomplete or incorrectly processed, to request that third parties to whom personal data is transferred be notified of the transactions regarding the correction and/or deletion or destruction of personal data,
- 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,
- In case of damage due to unlawful processing of personal data, to demand compensation for the damage.
Application to the Company
The Company has prepared a Procedure in order to protect the rights of the Data Subject regulated in the Law and this Clarification Text and to fulfill its own obligations in this regard. In accordance with this Procedure, the Company makes maximum effort to provide the information requested by the Data Subject by applying to the Company regarding the personal data of the Data Subject free of charge as soon as possible, within thirty days at the latest. If the transaction requires an additional cost, the fee in the tariff determined by the Board may be charged to the Data Subject. As a result of the examination of the request, the Company accepts the request or rejects it by explaining its reasoning and notifies its response to the Relevant Person in writing or electronically. If the request in the application is accepted, the Company shall fulfill the requirements of the request. In case the application is caused by the Company’s error, the fee received shall be returned to the Relevant Person.
Relevant Persons may exercise their rights specified in Article 8.1. by filling in the attached application form at the address https://kailogistics.com and sending it with wet signature to info@kailogistics.com via notary public, KEP or electronic mail or delivering it to the same address in person or by proxy or sending it to info@kailogistics.com electronic mail address.
Documents proving his/her identity, documents supporting the request, if any, and if the Relevant Person wishes to exercise this right through his/her proxy, a copy of the power of attorney containing the special authorization in this regard must be attached to the form.
