The website with the domain name https://www.truguard.com.tr/ (the “Website”) is operated by “Desi Kimya ve Maden Sanayi Tic. A.Ş.” (hereinafter referred to as “Desi Kimya”), located at “Acısu Mh. Karaoğlan Sk. No:19/2 Kartepe – Kocaeli – Turkey.” Desi Kimya, as the data controller, is responsible for determining the purposes and means of processing personal data and for establishing and managing the data recording system..

In accordance with the Personal Data Protection Law No. 6698 (“Law”), we would like to inform you about the processing of your personal data^[1] obtained in connection with your use of the Website, including but not limited to the collection, storage, and transfer thereof, within the scope of Article 3 of the Law titled “Definitions”, and the procedures and principles of such processing.

1. For What Purpose the Personal Data is to be Processed

According to Article 3 of the Law titled “Definitions”, personal data refers to “any information related to an identified or identifiable natural person”. This data may include your name, address, e-mail address or telephone number, etc. In addition, information/data collected by using cookies that does not directly allow you to be identified (for example, information such as how you use the Website, which parts of the site you visit) can be considered personal data if they are based on an identity allocated to the user/visitor and therefore collected, stored and evaluated by individualization.

We process the personal data of internet users and visitors who use the Website through cookies for the purposes of facilitating the use of the Website and customizing it in accordance with the interests and needs of users and visitors. Furthermore, we process such data in order to compile anonymous and aggregated statistical information that enables us to understand how users and visitors utilize the Website and to assist us in improving the structures and contents of the Website. Such data does not contain information that would enable us to identify your identity.

2. To Whom and for What Purpose the Processed Personal Data May be Transferred

Your collected personal data may be shared with these authorities to the extent necessary upon the request of the legally authorized authorities in order to fulfill our legal obligation as Desi Kimya in accordance with Articles 8 and 9 of the Law.

3. Method and Legal Reason of Collecting Personal Data:

Personal data related to current and potential internet users and visitors are collected by Desi Kimya by positioning cookies on the Website based on the legitimate interest legal reason of Desi Kimya, provided that Desi Kimya can carry out its activities and provide the products subject to its activities and do not harm the fundamental rights and freedoms of the data owners.

4. Network Server Data Log:

When you log in to the Website, your web browser is set to automatically transfer the following data to our web server, which then saves the following information/data in the data logs.

• Date of entry,
• Time of entry,
• URL of the application website,
• Received files,
• The amount of data transmitted,
• Browser type and version,
• Operation System,
• IP address,
• The domain name of your internet access provider.

5. Cookies

Cookies are small text files placed on your hard drive by the web page server. In this way, we automatically obtain certain data, such as the IP address, the browser used, the operating system on your computer, and your internet connection.

This Website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses cookies to help the website analyze how users use the site. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to Google, which will store it on servers in the USA. Google will use this information to evaluate your use of the Website, compile reports on Website activity, and provide other services relating to Website activity and internet usage.

Mandatory, functional and analytical cookies used by our site:

• It is mandatory for the website interface and its features to be used as desired.
• It allows you to accelerate activities during future visits.
• By enabling us to understand how the website is used by visitors, it helps us combine statistical data and develop content in line with this data.
• Under no circumstances do we collect, store or process data that can identify you, and it does not qualify as personal data.

6. Cookie Settings Management

We recommend that you accept cookies so that you can use the Website in the most efficient way possible. You can view the Website without cookies. Internet browsers are set up to accept cookies at any time. You can always stop the use of cookies through your browser settings. Please use your browser’s help function to learn how to change the settings for managing your cookies. Please note that when you stop using cookies or change cookie settings, some functions of our website may not work properly.

7. Right of Data Subject

Pursuant to Article 11 of the Law titled “Rights of the Data Subject”; as a data subject, you have the right to apply to Desi Kimya in writing or by other methods^[2] determined by the Personal Data Protection Board, to learn whether your personal data has been processed, to request information about it if your personal data has been processed, to learn the purpose of processing your personal data and whether it has been used in accordance with its purpose, if your personal data is transferred to third parties in the country or abroad, to know the third parties to whom your personal data has been transferred, to request their correction if your personal data is incomplete or incorrectly processed, and to request that the personal data be notified to the third parties to whom your personal data has been processed in accordance with the provisions of the Law and other relevant laws, to request the deletion or destruction of your personal data if the reasons requiring the processing of your personal data have been eliminated, and to request the notification of the transaction made in this context to the third parties to whom your personal data has been transferred, to object to the emergence of a result against you by analyzing the processed data exclusively through automated systems, to request compensation of the damage if you suffer damage due to the unlawful processing of your personal data.

Depending on the nature of your request, your requests will be processed by Desi Kimya free of charge as soon as possible and within thirty days at the latest. However, if the process requires additional costs for Desi Kimya, a fee may be charged as per the tariff determined by the Personal Data Protection Board. ^[3]

8. Exercise of Rights, Application and Communication

Your requests regarding your above-mentioned rights within the scope of the Law, by filling out the Application Form prepared for the Data Controller in full and completely and signing with a wet signature “Acısu Mh. KARAOĞLAN No :19/2 Kartepe-Kocaeli-Turkey ”in person, through a notary public and by other methods specified in the Law.

9. Link to Other Websites

The Website contains links to other websites. We have no influence on whether the administrators of these sites act in accordance with the data protection provisions. Desi Kimya is not responsible for the contents of the sites it links to (and the contents of other sites that those sites link to) and does not have the authority to interfere with the contents of the sites it links to.

10. Amendments

Since the Website changes and develops depending on technological and legal developments, this Cookie Policy will also be updated from time to time in this direction, and the current version of the Cookie Policy will be published at “https://www.truguard.com.tr//“ and will always be available for you to access.

[1]According to Article 3.1.(e) of the Law titled “Definitions”, “Processing of Personal Data”: It refers to any operation performed on data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, either fully or partially by automatic means or non-automatic means provided that it is part of any data recording system.

[2]In accordance with the “Communiqué on the Procedures and Principles of Application to the Data Controller” dated 10.03.2018 and numbered 30356; data owners submit their requests to Desi Kimya in writing or by using the registered electronic mail (REM) address, secure electronic signature, mobile signature or the electronic mail address previously notified to Desi Kimya by the data owners and registered in the Desi Kimya system or through a software or application developed for the purpose of application.

[3]According to the “Communiqué on the Procedures and Principles for Applications to the Data Controller” dated March 10, 2018 and numbered 30356, if a data subject’s application is to be responded to in writing, no fee will be charged for up to ten pages. A processing fee of 1 TL can be charged for each page beyond ten pages. If the response to the application is provided on a recording medium such as a CD or flash drive, the fee Desi Kimya may charge cannot exceed the cost of the recording medium.