PRIVACY POLICY

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with CynetIQ and the Services, the choices you make, and the products and features you use. Click here to learn more.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Click here to learn more.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more.

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here: contact@cynetiqtech.com, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what CynetIQ does with any information we collect? Click here to review the notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO TURKISH RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. WHAT LAWFUL BASES DO WE RELY ON UNDER KVKK?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following: names, phone numbers, email addresses, job titles.

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

We process your personal data in accordance with the Turkish Law No. 6698 on the Protection of Personal Data (KVKK). The lawful conditions on which we rely are detailed in Section 12 below. In summary, we may rely on the following grounds:

Consent. We may process your information if you have given us explicit permission to use your personal information for a specific purpose. You can withdraw your consent at any time by contacting us as described in the section Withdrawing Your Consent below.

Performance of a Contract. We may process your personal information when it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract.

Legal Obligations. We may process your information where necessary to comply with our legal obligations, such as to cooperate with competent authorities, exercise or defend our legal rights, or disclose your information as evidence in legal proceedings.

Vital Interests. We may process your information where necessary to protect the vital interests of you or a third party, such as situations involving potential threats to the safety of any person.

Legitimate Interests. We may process your information where necessary for our legitimate business interests, provided that such processing does not override your fundamental rights and freedoms.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

Ad Networks

Communication & Collaboration Tools

Data Analytics Services

Sales & Marketing Tools

Social Networks

Affiliate Marketing Programs

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Turkey. If you are accessing our Services from outside Turkey, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in Turkey, and other countries.

Whenever we transfer your personal information to third parties in other countries, we take appropriate safeguards to ensure that your information is protected in accordance with this privacy notice and applicable law, including the requirements of KVKK (Law No. 6698) regarding cross-border data transfers.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at contact@cynetiqtech.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Under Turkish Law No. 6698 on the Protection of Personal Data (KVKK), you have rights that allow you access to and control over your personal information. Please see Section 11 for a full list of your rights under KVKK. You may review, change, or terminate your account at any time.

You have the right to: (i) request access to and obtain a copy of your personal information, (ii) request rectification of incomplete or inaccurate data, (iii) request deletion or destruction of your personal data under certain conditions, (iv) object to automated processing, and (v) request compensation for damages arising from unlawful processing. You can make such a request by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you believe we are unlawfully processing your personal information, you have the right to file a complaint with the Personal Data Protection Authority of Turkey (Kişisel Verileri Koruma Kurumu — KVKK Board) at www.kvkk.gov.tr.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices.

If you have questions or comments about your privacy rights, you may email us at contact@cynetiqtech.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO TURKISH RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes. Under Turkish Law No. 6698 on the Protection of Personal Data (KVKK — Kişisel Verilerin Korunması Kanunu), you have the following rights as a data subject.

Your rights under KVKK Article 11:

Right to learn whether your personal data is being processed.

Right to request information about the processing of your personal data, if it has been processed.

Right to learn the purpose of the processing of your personal data and whether it is used in accordance with its stated purpose.

Right to know the third parties to whom your personal data has been transferred domestically or abroad.

Right to request correction of your personal data if it is incomplete or inaccurate, and to request that relevant third parties be notified of such correction.

Right to request deletion or destruction of your personal data under the conditions set out in Article 7 of the KVKK, and to request that relevant third parties be notified of such action.

Right to object to a result that is detrimental to you arising exclusively from automated processing of your personal data.

Right to request compensation for damages arising from the unlawful processing of your personal data.

Exercising Your Rights

To exercise any of the above rights, please submit a written application to us at contact@cynetiqtech.com. We will respond to your request within thirty (30) calendar days of receipt, free of charge. You also have the right to file a complaint with the Kişisel Verileri Koruma Kurumu (Personal Data Protection Authority of Turkey — KVKK Board) at www.kvkk.gov.tr.

Verification

Upon receiving your request, we will need to verify your identity to confirm you are the person about whom we hold the relevant data. We may ask you to provide information to match against information you have previously provided us, or contact you through a communication method you have previously provided. We will only use information provided in your request for verification purposes and will delete any additional information collected for verification once the process is complete.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights.

If you have a complaint about how we handle your data, we would like to hear from you. Please contact us at contact@cynetiqtech.com.

12. WHAT LAWFUL BASES DO WE RELY ON UNDER KVKK?

In Short: We process your personal data based on the lawful conditions set out in Article 5 of the KVKK (Law No. 6698 on the Protection of Personal Data).

Under KVKK, personal data may be processed without the explicit consent of the data subject where one of the following conditions applies:

Processing is expressly permitted by law.

Processing is necessary to protect the vital interests of the data subject or another person who is physically or legally incapable of giving consent.

Processing is necessary for the performance of a contract to which the data subject is a party, or for pre-contractual steps taken at the request of the data subject.

Processing is mandatory for CynetIQ to fulfil its legal obligations.

The personal data has already been made public by the data subject.

Processing is necessary for the establishment, exercise, or protection of a legal right.

Processing is necessary for the legitimate interests of CynetIQ, provided that such processing does not override the fundamental rights and freedoms of the data subject.

Where none of the above conditions apply, we will seek your explicit consent before processing your personal data. You may withdraw your consent at any time by contacting us at contact@cynetiqtech.com.

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at contact@cynetiqtech.com.

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please email us at: contact@cynetiqtech.com.