As Zorlu Holding Anonim Şirketi ("
Company"), we utilize certain technologies ("
Cookies") such as cookies, pixels, GIFs, etc. in order to improve your experience during your use of- or visit to our websites ("
Site"), applications or all similar online or offline media that we make available to you in the digital environment (all such media will be collectively referred to as the "
Platform"). This text has been prepared within the scope of Article 10 of the Law No. 6698 on the Protection of Personal Data (Law) and the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Obligation to Inform.
The use of these technologies is carried out in accordance with the legislation we are subject to, in particular the Law No. 6698 on the Protection of Personal Data ("
Law").
This Cookie Disclaimer Policy explains to you the purposes for which Cookies collected during the use of the Platforms are used and how you can control these Cookies regarding the processing of personal data obtained automatically through the placement of cookies used on our website on your device.
We may stop using the Cookies we use on our site and application, change their types or functions, or add new Cookies to our site and application. Therefore, we reserve the right to amend the provisions of this Cookie Policy at any time. Any amendments made to the current Cookie Policy will become effective upon publication on the site, application or any public medium. You can find the date of the last update at the end of the text.
Method of Personal Data Collection, Legal Reason and Transfer of Personal Data
Mandatory Cookies: They are used to fulfill an information society service you have requested (log-in, form filling and remembering privacy preferences, counting visitors on our website and measuring traffic). Your personal data collected electronically through Cookies regarding your visit to our website or due to your use of our application are processed as per Article 5(2)(c) of the Law "Provided that it is directly related to the establishment or performance of a contract, it is necessary to process personal data belonging to the parties to the contract" or Article (f) "Provided that it does not harm the fundamental rights and freedoms of the person concerned, it is mandatory to process data for the legitimate interests of the data controller".
Targeting and Marketing Cookies: They are used by our business partners to profile you based on your interests and to show you relevant advertisements. Your personal data collected through these cookies is processed by obtaining your explicit consent within the scope of paragraph 5(1) of the Law.
Functional Cookies: They are used to make our website more functional and to personalize it (to ensure that your other preferences, except for your privacy preferences, are remembered when you re-enter the site). Your personal data collected through these cookies is processed by obtaining your explicit consent within the scope of paragraph 5(1) of the Law.
For cookies other than mandatory cookies that we use on our website, users' explicit consent is obtained and they are given the opportunity to change their consent at any time. Users can see the types of cookies used on our website in the “Manage Cookies” section and can set their preferences with the "on" or "off" options for all cookies other than Mandatory Cookies. Similarly, users can always change their preferences through this panel.
You can always manage the use of cookies from the
Manage Cookies section.
Your personal data collected through Cookies subject to explicit consent will be transferred to third parties from which we receive services domestically, limited to the fulfillment of the purposes specified in this Cookie Policy and with your explicit consent. If the parties from which we receive services are abroad, this data will be transferred limited to the fulfillment of the purposes specified in this Cookie Policy based on the appropriate safeguards in Article 9 of the Law.
Types of Cookies by Duration
- Session Cookies: These Cookies are temporary Cookies that disappear when the browser is closed or the session is terminated.
- Permanent Cookies: These Cookies are Cookies that remain on your hard drive until you delete them or until your browser automatically deletes them, depending on the day of disappearance. The disappearance dates of Permanent Cookies are predetermined, even if they vary.
Types of Cookies by Party
- First Party Cookies: As the name suggests, first party Cookies are Cookies placed on your device by our Platforms. . First party cookies are placed directly by the website that the user visits, i.e. the URL (example.com.tr) shown in the address bar of the browser.
- Third Party Cookies: These Cookies are not placed on your device by our Platforms that you visit, but by advertisers or third parties that perform analytics. Third party cookies are placed by a domain different from the domain the user is visiting.
Cookies and Purposes of Use
- Mandatory Cookies: Mandatory Cookies are Cookies necessary for the realization of the main functions of our website and are Cookies that provide security, network management and access to our website. Mandatory cookies are first party cookies that process personal data for the duration of the session (except for cookies related to your privacy preferences, as these cookies last longer than the session duration) and are automatically deleted when the session ends. These cookies are mandatorily used to fulfill an information society service you have requested (logging in, filling in forms and remembering privacy preferences).
- Functional/Preference Cookies: Preference Cookies, also known as functionality Cookies, are Cookies that enable the website to remember your past preferences, such as the language used or preferred region or the username and password that automatically log you in. Such cookies are used to make our website more functional and personalized (to ensure that your preferences, except for your privacy preferences, are remembered when you re-enter the site).
- Performance/Analytics Cookies: These cookies are often used to improve the site, including by measuring the impact of advertisements on the people concerned. They are used by website owners to estimate the number of unique visitors, to identify the most important search engine keywords that lead to a web page or to track website navigation.
- Advertising/Marketing Cookies: Advertising/Marketing Cookies are Cookies that enable the delivery of personalized advertisements by tracking users' online behavior. These Cookies may also share the information it collects with other third party advertisers.
Cookies Used on Our Platforms
Mandatory Cookies
The use of certain Cookies is mandatory for the correct functioning of our website and application. For example, authentication cookies, which are activated when you log in to our site, ensure that your active session continues when you move from one page to another on our site.
| Cookie |
Description |
Party Information |
Duration |
| 1.gif |
It is used to count the number of sessions on the website, which is necessary to optimize CMP product distribution. |
Third party |
During the session |
| CookieConsent |
It stores the user's cookie consent status for the current domain. |
Third party |
1 year |
| sync_cookie_csrf [x3] |
It is used in connection with the synchronization between the Website and the third party Data Management Platform. The cookie serves to monitor this process for security reasons. |
Third party
|
1 day |
| uw-icon-locales |
It is used to keep settings in the accessibility parts of the website. |
Third party |
During the session |
| i [x3] |
It maintains user states between page requests. |
Third party |
400 days |
Functionality and Preference Cookies
These Cookies ensure that the services offered on our site are personalized for you by remembering your preferences and choices on the site and application. For example, they allow us to remember your choice of language on our site or the font size you have selected when reading a text. If you consent to the use of functionality and preference Cookies, your personal data will be transferred to third parties from which we receive services.
| Cookie |
Description |
Party Information |
Duration |
| _ga [x2] |
It registers a unique ID that is used to generate statistical data about how the visitor uses the website. |
Third party |
2 years |
| _ga_# [x2] |
It is used by Google Analytics to collect data about the number of times a user visits the website and the dates of the first and last visit. |
Third party |
2 years |
| collect |
It is used to send data about the visitor's device and behavior to Google Analytics. It tracks the visitor across devices and marketing channels. |
Third party |
During the session |
| _gat |
It is used by Google Analytics to reduce the request rate. |
Third party |
1 day |
| _gid |
It registers a unique ID that is used to generate statistical data about how the visitor uses the website. |
Third party |
1 day |
| sentryReplaySession |
It records data on the website behavior of visitors. This is used for internal analysis and website optimization. |
Third party |
During the session |
| _ym_retryReqs |
It records statistical data on the behavior of users on the website. It is used by the website operator for internal analysis. |
Third party |
During the session |
| _ym3:0_reqNum |
It records statistical data on the behavior of users on the website. It is used by the website operator for internal analysis. |
Third party |
During the session |
| yandexuid [x3] |
It records data on the website behavior of visitors. This is used for internal analysis and website optimization. |
Third party |
400 days |
| ymex [x2] |
It records data on the website behavior of visitors. This is used for internal analysis and website optimization. |
Third party |
1 year |
| yp [x2] |
It sets a unique ID for the session. This enables the website to obtain data about visitor behavior for statistical purposes. |
Third party |
400 days |
Targeting or advertising cookies
We use Cookies to promote products and services to you on our website or in media other than our website. We may also cooperate with some of our business partners to provide you with advertising and promotion within or outside our site. For example, Cookies may be used to track whether you click on an advertisement you saw on our site, and if the advertisement attracts your attention, whether you benefit from the service on the site to which that advertisement directs you. If you consent to the use of targeting or advertising Cookies, your personal data will be transferred to third parties from which we receive services.
| Cookie |
Description |
Party Information |
Duration |
| sp_landing |
It is used to implement audio content from Spotify on the website. It can also be used to record user interaction and preferences in the context of audio content - This can serve statistical and marketing purposes. |
Third party |
1 day |
| sp_t |
It is used to implement audio content from Spotify on the website. It can also be used to record user interaction and preferences in the context of audio content - This can serve statistical and marketing purposes. |
Third party |
1 year |
| metrika_enabled [x3] |
It is used to track visitors across multiple websites in order to deliver relevant advertisements based on the visitor's preferences. |
Third party |
During the session |
| sync_cookie_csrf_secondary [x3] |
It is used for data synchronization with ad networks. |
Third party |
1 day |
| sync_cookie_image_decide [x2] |
It is used for data synchronization with ad networks. |
Third party |
During the session |
| sync_cookie_ok [x2] |
It is used for data synchronization with ad networks. |
Third party |
1 day |
| yabs-sid |
It records data about visitors from multiple visits and multiple websites. This information is used to measure the effectiveness of advertisements on websites. |
Third party |
During the session |
| _ym_synced |
It monitors the user's interaction with the website's search bar functionality. This data may be used to provide the user with relevant products or services. |
Third party |
During the session |
| _ym_uid |
It collects data about the user's navigation and behavior on the website. This is used to compile statistical reports and heat maps for the website owner. |
Third party |
1 year |
| _ym_d |
It includes the date of the visitor's first visit to the website. |
Third party |
1 year |
| _ym_isad |
This cookie is used to determine if the visitor has any ad blocking software in their browser - this information may be used to make website content inaccessible to visitors if the website is funded by third party advertising. |
Third party |
1 day |
| _ym_visorc |
It records information of the actions performed by the user during the current visit to the website, including searches by keywords. |
Third party |
1 day |
| #-# |
It is used to track the user's interaction with embedded content. |
Third party |
During the session |
| iU5q-!O9@$ |
It registers a unique ID to keep statistics on which videos the user has watched on YouTube. |
Third party |
During the session |
| LAST_RESULT_ENTRY_KEY |
It is used to track the user's interaction with embedded content. |
Third party |
During the session |
LogsDatabaseV2:V#||
LogsRequestsStore |
It is used to track the user's interaction with embedded content. |
Third party |
During the session |
| nextId |
It is used to track the user's interaction with embedded content. |
Third party |
During the session |
| remote_sid |
It is required for the implementation and functionality of YouTube video content on the website. |
Third party |
During the session |
| requests |
It is used to track the user's interaction with embedded content. |
Third party |
During the session |
ServiceWorkerLogsDatabase
#SWHealthLog |
It is required for the implementation and functionality of YouTube video content on the website. |
Third party |
During the session |
| TESTCOOKIESENABLED |
It is used to track the user's interaction with embedded content. |
Third party |
1 day |
| VISITOR_INFO1_LIVE |
It tries to estimate the bandwidth of users on pages with integrated YouTube videos. |
Third party |
180 days |
| YSC |
It registers a unique ID to keep statistics on which videos the user has watched on YouTube. |
Third party |
During the session |
| yt.innertube::nextId |
It registers a unique ID to keep statistics on which videos the user has watched on YouTube. |
Third party |
During the session |
| ytidb::LAST_RESULT_ENTRY_KEY |
It stores the user's video player preferences by using embedded YouTube video. |
Third party |
During the session |
| YtIdbMeta#databases |
It is used to track the user's interaction with embedded content. |
Third party |
During the session |
yt-remote-cast-available
yt-remote-connected-devices
yt-remote-device-id
yt-remote-fast-check-period
yt-remote-session-app
yt-remote-session-name
|
It stores the user's video player preferences by using embedded YouTube video. |
Third party |
During the session |
| receive-cookie-deprecation |
It collects information about user behavior across multiple websites. This information is used to optimize the relevance of advertising on the website. |
Third party |
1 year |
| _yasc [x3] |
It collects user-related data through websites - This data is used to make the ad more relevant. |
Third party |
2 years |
| bh [x3] |
It collects data about user behavior and interaction in order to optimize the website and make the advertisements on the website more relevant. |
Third party |
400 days |
| yuidss [x3] |
It collects data on visitor behavior from multiple websites to provide more relevant ads - This also allows the website to limit the number of times it shows the same ad. |
Third party |
400 days |
How Can I Control the Use of Cookies?
The preferences of our visitors and users regarding the use of cookies and similar technologies are essential for us. However, it is necessary to use Cookies, which are mandatory for the Platform to function. We would also like to remind you that some functions of the Platform may not work partially or completely if some Cookies are turned off.
Information on how you can manage your preferences regarding the cookies used on the Platform is as follows:
- Visitors have the possibility to customize their preferences regarding Cookies by changing the settings of the browser through which they view the Platform. If the browser used offers this possibility, it is possible to change the preferences regarding Cookies through the browser settings. Thus, although it may vary depending on the possibilities offered by the browser, data subjects have the possibility to prevent the use of Cookies, to prefer to receive a warning before Cookies are used, or to disable or delete only some Cookies.
- Although preferences in this regard vary depending on the browser used, the general explanation is available at https://www.aboutcookies.org/. Preferences regarding cookies may need to be made separately for each device that the visitor accesses the Platform.
- To turn off Cookies managed by Google Analytics, click here.
- To manage the personalized advertising experience provided by Google, click here.
- Preferences in terms of cookies used by many companies for advertising activities can be managed through Your Online Choices.
- The settings menu of the mobile device can be used to manage cookies on mobile devices.
- You have the possibility to customize your preferences regarding cookies by changing your browser settings.
What are Your Rights as a Data Subject?
Pursuant to Article 11 of the PDPL Law, data owners have the right to;
- learn whether their personal data is processed or not,
- request relevant information if their personal data is processed,
- learn the purpose of the processing of their personal data and whether or not it is used for the intended purposes,
- learn about the third persons inside or outside the country to which their personal data is transferred,
- request the rectification of the incomplete or inaccurate data, if any, and to request the notification of such transaction to third parties to whom their personal data have been transferred,
- request the deletion or destruction of personal data although it has been processed in accordance the PDPL Law and the provisions of other laws in the event that the reasons requiring their processing cease to exist, and to request the notification of such transaction to third parties to which your personal data has been transferred,
- object to any unfavorable outcomes against them as the data subject since the processed data was exclusively analyzed by automated systems,
- request compensation for their damages in case they incur damages due to the processing of their personal data in violation of the law.
As the Data Owner, you may submit your requests regarding these rights to Levazım Mah. Koru Sok. No:2 PSM/70 34340 Beşiktaş/İstanbul in writing, as registered electronic mail (REM), secure electronic signature or mobile signature to
zorluholding@hs03.kep.tr , or via the e-mail address you have previously notified our Company of and which is registered in the systems of our Company, to
kvk@zorlu.com . Your request will be evaluated and assessed within 30 (thirty days). In the requests submitted by you as the Data Owner, it is obligatory to include your name, surname, signature if the application is made in writing, your Republic of Türkiye identity number, or if you are a foreigner, your nationality, your passport number or identity number, if any, your place of residence or work address for notification, your e-mail address, if any, for notification, your telephone and fax numbers and the subject of the request. In case of a written response to the request, no fee will be charged for up to ten pages, and our Company reserves the right to charge a fee for responses over ten (10) pages, based on the fee schedule stipulated by the legislation. If the response to the application is provided in a recording medium such as CD or USB stick, our Company may charge you a fee equal to the cost of the recording medium.
Last updated on: September 1, 2024
