Kuzey Güney VIP Transfer Cookie Usage Clarification Text 

Article – Introduction

6698 numbered Personal Data Protection Law (“Law”) imposes significant obligations on those who process personal data to protect individuals’ fundamental rights and freedoms, particularly the privacy of private life.

Kuzey Güney VIP Transfer (“Company”) located in Ramadan Cemil Square, Girne / CYPRUS, demonstrates a careful and meticulous approach as the Data Controller in order to fulfill these obligations and ensure that all data processing activities comply with the relevant laws.

In line with this approach, the Company aims to clarify and inform the Data Subjects about the cookie technology used on the mobile application and the website of {kuzeyguneyviptransfer.com.tr} (“Online Platform”) and the personal data processing activities related to it.

Scope

This Clarification Text will inform Data Subjects about the following questions related to the personal data processing activity carried out via cookies used on the Company’s Online Platform:

1. What is the identity of the Company?
2. What types and characteristics of cookies are used on the Online Platform?
3. For what purposes are the personal data obtained through cookies processed?
4. To whom and for what purposes are the personal data transferred by the Company?
5. What are the methods and legal grounds for collecting personal data through cookies?
6. What are the ways to change cookie preferences?
7. What rights do Data Subjects have regarding the Company’s personal data processing activities?

Article – Definitions

• “Recipient Group” refers to real or legal persons to whom personal data is transferred by the data controller.
• “Online Platform” refers to the mobile application and website with the domain name {kuzeyguneyviptransfer.com.tr}.
• “Data Subject” refers to the real person whose personal data is processed through cookies.
• “Personal Data” refers to any information related to an identified or identifiable real person.
• “Processing of Personal Data” refers to any operation performed on personal data, including collection, recording, storing, altering, organizing, disclosing, transferring, making available, and erasing.
• “Special Categories of Personal Data” include sensitive data such as race, ethnicity, political opinions, religious beliefs, health data, etc.
• “Cookie” refers to small text files placed on a user’s device when visiting the Online Platform, used to recognize the user and improve their experience.

Cookies Used on the Online Platform

What are Cookies?

Cookies are text files placed on the device or server of the Data Subject when visiting the Online Platform. They allow the device to be recognized, and usually consist of letters and numbers. Cookie preferences can be changed as described in Article 5. However, changes to cookie preferences may impact the user experience of the Online Platform.

Types of Cookies Used

The Company uses cookies for various purposes, primarily to improve the user experience. These cookies can be session cookies, which are deleted when the browser is closed, or persistent cookies, which remain on the device for a longer period.

1. Session Cookies: These are temporary cookies that are deleted when the browser is closed. They allow the online platform to function during a session.

2. Persistent Cookies: These cookies are saved to the device’s hard drive and are used to remember preferences or other information when the user revisits the Online Platform.

3. Third-Party Cookies: The Company also uses third-party cookies, which are placed by third parties when the Online Platform is visited.

Cookie Types and Descriptions

Below are the types of cookies used by the Company on the Online Platform and their purposes:

List of Cookies Used

Technical Cookies

• Cookie Name: [Description]
• Type: [Session/Persistent, First/Third Party]
• Storage Duration: [Duration]

Analytical/Performance Cookies

• _ga (Google): This cookie is used to differentiate users for data collection on visits and user journey via Google Analytics.
  Type: Third Party
  Duration: 2 years

Targeting/Advertising Cookies

• 1P_JAR (Google): Used to collect data on site statistics and previous ads seen by the visitor.
  Type: Third Party
  Duration: 1 month

Personalization Cookies

• Lang: Stores the user’s language preference.
  Type: Persistent
  Duration: 2 months

Flash Cookies

• [Details of flash cookies used].

Purposes of Cookie Use

The Company processes personal data via cookies for the following legitimate purposes:

• Ensuring the proper functioning of the Online Platform
• Analyzing user behavior to enhance user experience
• Personalizing content and advertising
• Marketing and promotional activities
• Conducting market analysis and advertising campaigns

Changing Cookie Settings

Users can modify their cookie preferences at any time by adjusting their browser settings. Detailed instructions for different browsers can be found at the following links:

• Google Chrome: Support link
• Internet Explorer: Support link
• Mozilla Firefox: Support link
• Safari: Support link
• Opera: Support link

For more details, you can visit All About Cookies or Your Online Choices or use the “Privacy Badger” app (EFF Privacy Badger).

Third-Party Transfers

Personal data collected through cookies may be shared with third parties under the following circumstances:

• Recipient Group: Includes external entities such as the company’s lawyers, advertising agencies, business partners, and authorized public institutions (e.g., courts).
• Domestic Transfers: Personal data may be transferred domestically with the explicit consent of the Data Subject or when required by law.

In accordance with applicable regulations, personal data may be transferred without explicit consent if it is necessary to protect the life or bodily integrity of the Data Subject, or when it is related to the execution or fulfillment of a contract, compliance with a legal obligation, or for other specified legal reasons.

This text aims to clearly outline the cookie use policies and data processing practices in compliance with Turkish data protection laws. The detailed explanations of cookie types, data processing purposes, and third-party transfers ensure transparency and informed consent from users.

Transfer of Personal Data Abroad

The Company will only transfer personal data processed through cookies abroad if the Data Subject gives explicit consent.

However, the Company may transfer the personal data of Data Subjects abroad without explicit consent. Personal data can be transferred abroad without explicit consent if:

• (a) The country or countries to which the data will be transferred are ones that have been declared by the Authority to provide adequate protection, or
• (b) If the country is not listed by the Authority, the Company obtains written assurance from the data controllers in the foreign country providing adequate protection, and obtains permission from the Authority.

Additionally, personal data may be transferred abroad without explicit consent if one or more of the following conditions are met:

• If there is a clear regulation in the legislation regarding the transfer of personal data abroad.
• If it is necessary to protect the life or bodily integrity of the data subject or someone else, and the data subject is unable to express consent due to practical impossibility, or if their consent is not legally valid.
• If the transfer is directly related to the establishment or performance of a contract with the data subject.
• If the transfer is necessary for the Company to fulfill its legal obligations.
• If the data subject has made the personal data public, it may be transferred abroad for the purpose of public disclosure.
• If the transfer is necessary for the establishment, use, or protection of a right.
• If the transfer is necessary for the legitimate interests of the Company, and provided that it does not harm the fundamental rights and freedoms of the Data Subject, it can be transferred to third parties.

Transfer of Sensitive Personal Data:
Sensitive personal data may be transferred abroad by the Company by obtaining the explicit consent of the Data Subject, while applying administrative and technical measures and complying with special measures taken by the Authority. The Company may transfer sensitive personal data abroad without the Data Subject’s explicit consent, under the following conditions:

• (a) If the country to which the data will be transferred is declared by the Authority to provide adequate protection, or

• (b) If it is not one of the countries listed by the Authority, the Company obtains written assurance from the foreign data controllers to provide adequate protection and permission from the Authority.

• (c) One or more of the following conditions must apply:

• Sensitive Personal Data (excluding health and sexual life): If provided by law, the Company can process sensitive personal data related to health and sexual life without the explicit consent of the data subject.

• Sensitive Personal Data related to health and sexual life: These may be processed without explicit consent if they are necessary for public health protection, preventive medicine, medical diagnosis, treatment, and healthcare services, or if performed by persons or institutions bound by confidentiality obligations.

Methods and Legal Grounds for Personal Data Collection
The Company acts in accordance with the fundamental principles and the Law during the collection of personal data through cookies, as it does with other data processing activities. The methods and purposes of data collection via cookies are detailed in accordance with the provisions mentioned above.

Personal data collected for these purposes and legal grounds may be processed and transferred within the scope of the data processing conditions and purposes specified in Articles 5 and 6 of the Law, as well as the purposes stated in Articles 3.5, 4, and 6 of the Information Text.

Rights of the Data Subject and Application to the Company

Rights of the Data Subject
The Data Subject has the right to request from the Company regarding their personal data:

• Learn whether their personal data is processed,
• Request information if their personal data has been processed,
• Learn the purpose of processing personal data and whether it is being used in accordance with that purpose,
• Know the third parties to whom their personal data is transferred, whether domestically or internationally,
• Request correction of their personal data if it is incomplete or incorrect,
• Request deletion or destruction of their personal data,
• Request that corrections, deletions, or destructions of their personal data be communicated to third parties to whom the data has been transferred,
• Object to any processing of personal data that is based solely on automated systems and leads to a result detrimental to the Data Subject,
• Request compensation for damages suffered due to unlawful processing of personal data.

Application to the Company
The Company has prepared procedures to protect the rights of Data Subjects as specified in the Law and this Information Text, and to fulfill its obligations in this regard. In accordance with these procedures, the Company will make every effort to provide the requested information within thirty days, free of charge. If there is a fee, it will be charged according to the tariff set by the Authority. The Company will either accept or reject the request after reviewing it, explaining the reason if the request is denied, and will inform the Data Subject in writing or electronically. If the request is accepted, the Company will fulfill the request. If the request is due to an error on the Company’s part, the fee will be refunded to the Data Subject.

Data Subjects can exercise their rights stated in Section 8.1 by filling out the application form attached to the website {kuzeyguneyviptransfer.com.tr}, signing it, and sending it by notarized mail, KEP, or email to {info@kuzeyguneyviptransfer.com}, or delivering it in person or through a representative. A copy of identity verification documents and, if applicable, supporting documents must be attached, and if the Data Subject wishes to use this right through a representative, a power of attorney containing special authorization must also be submitted with the form.