www.trakyanet.com ("SITE") has adopted the principle of ensuring the confidentiality of information shared by visitors to the website. Therefore, this "Privacy Policy" has been created to inform you by explaining which information of individuals is processed, in what ways, with which third parties this information is shared in accordance with the law and within the scope of the permission you have given, and how it is protected by the SITE. In addition, within the framework of this Privacy Policy, it is stated how you can check the accuracy of this information and how you can have this information deleted by applying to the SITE when requested. All services provided to individuals by the SITE through all channels will be referred to as the "Service".
Scope of the Privacy Policy
This Privacy Policy explains the general principles governing the processing of personal data relating to persons who visit the www.trakyanet.com website or communicate with Trakyanet through the communication channels available on the SITE.
Trakyanet aims to process personal data in accordance with applicable personal data protection legislation, primarily the Turkish Personal Data Protection Law No. 6698 (KVKK). For data processing activities relating to persons located in the European Union or European Economic Area, the European Union General Data Protection Regulation (GDPR) and relevant national regulations are also taken into consideration to the extent applicable.
Data Controller Responsibility
Responsibility for personal data processing activities carried out in connection with the operation of the SITE is exercised by the person operating the www.trakyanet.com website.
For certain activities in which personal data is collected directly, specific information relating to the relevant processing activity may also be provided to data subjects where required by applicable legislation.
Personal Data That May Be Processed
As Trakyanet does not operate a membership or user account system, visitors are not directly requested to provide identity, address or telephone information during general use of the SITE.
However, the following limited categories of data may be processed during use of the SITE:
- Technical access and security data: Information that may technically arise during operation of the website, such as IP address, date and time of access, requested page or address, technical browser and device information, operating system information, referring page information, error records and security logs.
- Contact data: Name, email address or other contact information voluntarily provided by the user through the communication channels, where such information is submitted.
- Request and message content: Questions, suggestions, correction requests, complaints, copyright or rights infringement notices sent by the user to Trakyanet, together with any information voluntarily provided by the user in connection with such requests.
- Preference and technical settings information: Limited technical records required for operation of the SITE or remembering the user's preferences, such as privacy and cookie preferences.
Due to the nature of its activities, Trakyanet does not request special categories of personal data from visitors. Users are advised not to submit health information, biometric data, political opinions, religious beliefs or similar sensitive information unless necessary. If such information is voluntarily submitted by a user, it may only be considered to the extent permitted by applicable legislation and as required by the relevant request.
Methods of Collecting Personal Data
Personal data may be collected electronically through technical records automatically generated by server and security systems when accessing the SITE, information voluntarily provided by users through communication channels and technical systems used for operation of the SITE.
Trakyanet does not seek to collect visitors' personal data for the purpose of secretly identifying them during ordinary internet use or creating detailed personal profiles about them.
Purposes of Processing Personal Data
Depending on the nature of the data, collected personal data may be processed for purposes including ensuring operation of the SITE, protecting information and system security, detecting and resolving technical problems, preventing misuse and unauthorised access attempts, evaluating and responding to user requests, reviewing error or content reports, assessing applications concerning intellectual property and other rights, complying with legal obligations and, where necessary, establishing, exercising or protecting a right.
Technical data may also be used to evaluate the SITE's general performance, usability and visitor structure in a manner not intended to directly identify individuals.
Legal Grounds for Processing Personal Data
Personal data is processed on the basis of the appropriate legal condition set out in Articles 5 and, where necessary, 6 of the KVKK, depending on the nature of the relevant processing activity. Such legal grounds may include processing being necessary for the data controller to fulfil a legal obligation, processing being necessary for the establishment, exercise or protection of a right, and processing being necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed.
Where explicit consent is required for a data processing activity, personal data is processed on the basis of the data subject's freely given explicit consent after the necessary information has been provided. Explicit consent is not unnecessarily made mandatory where other lawful processing conditions are available.
Where the GDPR applies, personal data is processed on an appropriate lawful basis corresponding to the nature of the relevant processing activity.
Sharing of Personal Data
Trakyanet does not sell or rent personal data to third parties for the purpose of creating any commercial database.
Personal data may be shared with service providers only to the extent necessary for services such as hosting, technical operation and security of the SITE, communication services or similar essential technical services.
Personal data may also be transferred to authorised institutions, organisations and authorities for the purpose of fulfilling legal obligations, responding to lawful requests from competent public authorities or establishing, exercising or protecting a right.
Any transfer to third parties is carried out in accordance with applicable data protection legislation and based on the principle that only data necessary for the relevant purpose should be shared.
International Transfer of Personal Data
If certain technical services used in operation of the SITE or the infrastructure of service providers are located abroad, personal data may be transferred internationally.
Where such a transfer occurs, personal data is transferred in accordance with the conditions applicable to international data transfers under current legislation and with the required safeguard mechanisms.
Data Retention Period
Personal data is retained only for the period required by the purpose of processing and for any mandatory retention periods prescribed by applicable legislation.
Where the purpose of processing no longer exists and there is no other legal ground requiring retention of the data, personal data is deleted, destroyed or anonymised in accordance with applicable legislation.
The retention period of security and server logs is limited by taking into account security requirements, technical needs and any applicable legal obligations. Information submitted through communication channels may be retained for the period necessary to resolve the relevant request and, where required, protect legal rights.
Data Security
Trakyanet seeks to implement appropriate technical and administrative measures to prevent unlawful access to, alteration, disclosure or loss of processed personal data.
However, no method of data transmission or storage over the internet can be guaranteed to provide absolute security. Users are also advised to take appropriate measures to protect their own devices, internet connections and accounts.
Google reCAPTCHA
Trakyanet uses the reCAPTCHA verification service provided by Google in order to prevent the contact form from being misused by automated software, to reduce unwanted messages and to protect against similar security threats.
The reCAPTCHA service is activated when a visitor opens the contact form. During the verification process, the reCAPTCHA response and the IP address may be transmitted to Google's verification service. As part of the operation of the service, certain technical data relating to user interactions, sessions and connections may also be processed for the purposes of detecting and preventing security threats, fraud and misuse.
Google acts as a data processor with regard to customer data processed on behalf of Trakyanet within the scope of reCAPTCHA. Data processing carried out through reCAPTCHA is limited to ensuring the security of the contact form and preventing automated or malicious submissions.
During the operation of the reCAPTCHA service, a cookie named _grecaptcha or similar technical storage methods may be used. Detailed information about the cookies used within the scope of reCAPTCHA and related preferences is provided in the separate Cookie Policy published on the SITE.
Cookies
The SITE may use technically necessary cookies as well as other cookies and similar technologies that operate according to user preferences.
Detailed information about the types, purposes and duration of cookies used, third parties and how users can manage their preferences is provided in the separately published Cookie Policy.
Third-Party Websites
The SITE may contain links to public institutions, organisations, businesses, sources, social media platforms, mapping services, reservation systems and other third-party websites.
If a user follows a third-party link and leaves Trakyanet for another website, the data processing and privacy practices of that website are governed by its own policies. Trakyanet is not responsible for the personal data processing practices of websites outside its control.
Analytics, Advertising and External Services
Trakyanet uses Google Analytics and Yandex.Metrica analytics services to measure and improve use of the SITE. These services may process information such as visit and session data, pages visited, traffic sources, IP address, approximate location and technical information relating to the device and browser.
Google AdSense is used to display advertisements on the SITE. Google and third parties involved in advertising services may use cookies, online identifiers and similar technologies for purposes including displaying advertisements, measuring advertising performance, limiting display frequency and, depending on user settings, personalising advertisements. In this context, information relating to the user's visits to the SITE and other websites may be processed by Google.
The SITE uses a site search service provided by Google. When a user performs a search through this service, the search query is transmitted to Google, processed by Google and used to generate the search results. During operation of the service, certain technical information relating to the IP address, browser, device and connection may also be processed by the relevant service provider.
Some pages of the SITE use external content such as third-party online mapping services including Google Maps, Yandex Maps, Bing Maps and OpenStreetMap, as well as videos hosted on YouTube. When such content is loaded through an iframe or similar method, the user's browser may connect directly to the servers of the relevant third-party service provider. In this context, the relevant provider may process certain technical information such as the IP address, device and browser information, the address of the page visited, connection information and interactions with the service.
As the SITE develops, similar third-party map, video or content services may also be used. Personal data processing activities carried out through such services are assessed according to the nature of the service and applicable data protection legislation. Detailed information about cookies and similar technologies used is available in the SITE's Cookie Policy.
Details regarding the Google reCAPTCHA service used to protect the contact form are separately explained in the relevant section of this Privacy Policy.
Where use of these third-party services results in international transfers of personal data, the transfer conditions and required safeguard mechanisms prescribed by applicable personal data protection legislation are taken into consideration. Detailed information regarding cookies and similar technologies is available in the SITE's Cookie Policy.
Children's Privacy
Trakyanet is a general informational website and does not specifically seek to collect personal data from children.
Children are advised to be guided by their parents or legal representatives when sharing personal information online. Trakyanet may be contacted if it is believed that personal data relating to a child has been processed unlawfully or unnecessarily.
Rights of the Data Subject
Under the KVKK, data subjects may, subject to the conditions specified in Article 11 of the Law, exercise rights including learning whether personal data concerning them has been processed, requesting information if it has been processed, learning the purpose of processing and whether the data is used in accordance with that purpose, knowing the third parties to whom the data has been transferred, requesting correction of incomplete or inaccurate data, requesting deletion or destruction where the relevant conditions are met, and exercising other rights specified in the Law.
Where the GDPR applies, data subjects may also, where the relevant conditions are met, have rights to access, rectification, erasure, restriction of processing, objection to processing, data portability and lodging a complaint with the competent data protection authority.
Where a data processing activity is based on consent, the data subject may withdraw that consent at any time with future effect. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
Applications and Contact
You may submit your questions and requests concerning the processing of your personal data through our contact section, together with sufficient information to enable your request to be evaluated.
Depending on the nature of the request, additional information may be requested in order to verify that the applicant is the relevant data subject. Applications are evaluated taking into account the procedures and time limits prescribed by applicable legislation.
Changes to the Privacy Policy
Trakyanet may update this Privacy Policy due to changes in the operation of the SITE, services used or applicable legislation.
The current Privacy Policy becomes effective from the date on which it is published on the SITE. Where significant changes are made, additional notice may be provided through the SITE where appropriate.