GLOKEY PRIVACY & COOKIE POLICY

As APG Investment Danışmanlık Anonim Şirketi (“Şirket”), we highly value the protection of your personal data and the privacy of your private life. The purpose of this Privacy and Cookie Policy is to inform you about the personal data collected from you during your visit to the website www.glokey.com.tr and the cookies we use on our site.

1. What is a Cookie?

Cookies are small text files, typically consisting of letters and numbers, that are stored on users’ browsers, devices, or network servers by the website they visit.

As Şirket, we utilize cookies, pixels, and similar technologies on our website www.glokey.com.tr to enhance our visitors’ experience during their visit and when submitting forms through this website. In this regard, our use of cookies complies with the Personal Data Protection Law No. 6698 (“Law”), the European Union General Data Protection Regulation (“GDPR”) and all relevant regulations, communiqués, and decisions issued by the Personal Data Protection Authority from time to time.

As Şirket, we reserve the right to modify, amend, add to, or remove any provisions of this Privacy and Cookie Policy at any time.

For detailed information regarding the processing, transfer, protection, storage, and deletion of your personal data, you may always refer to the privacy notices and policies published by Şirket at www.glokey.com.tr.

2. Purpose of Cookie Usage

We use the data obtained through cookies from users visiting our website for the following purposes:

• Ensuring the execution of the essential functions and functionalities of the website,
• Ensuring the proper operation of the website,
• Ensuring the legal security of both you and Şirket.

3. Method of Collecting and Legal Basis for Processing Personal Data

Personal data may be collected through various methods, including digital forms, cookies, and communication channels, in order to provide services, facilitate communication, and improve user experience. Specifically, when visitors and potential clients fill out contact and appointment request forms on our website, they may be required to provide identity information (name, surname), contact details (email address, phone number, country), transaction data (preferred program information, message content, questions, and comments), and other relevant details (communication preferences, preferred start date, budget information, preferred communication day and time).

Additionally, during your visit to our website, the Company may collect and process personal data such as IP address, user traffic information, login and logout details, port number, MAC address, log records, connection request date, and traffic information through cookies. These data are processed in compliance with Articles 5 and 6 of the relevant law and and relevant articles of the GDPR, ensuring that all legal obligations and data protection principles are upheld.

4. Transfer of Personal Data

Within the scope of this Privacy and Cookie Policy, we may share your personal data with business partners, our suppliers, authorized public ınstitutions and foreign representations and legal advisors and financial consultants located either domestically or internationally, strictly for the purposes specified below and in compliance with the applicable regulations:

• Business Partners: Personal data may be shared with business partners solely for the purpose of carrying out joint activities and providing consultancy services.
• Suppliers: Personal data may be shared with suppliers providing hosting, cloud services, archiving, online communication, and similar services, limited to the purpose of service procurement.
• Authorized Public Institutions and Foreign Representations: Personal data may be shared with relevant public institutions and organizations only within the scope of their requests and in line with the purpose of the consultancy service.
• Legal Advisors and Financial Consultants: Personal data may be shared with legal advisors and financial consultants solely for the purpose of protecting, exercising, and establishing the company’s legal and financial rights.

5. Cookies Used on Our Website

Cookies may be used to perform the essential functions required for the operation of the website, ensure its proper functioning, and enable users to benefit from the services offered on the website. The cookies used on our website are listed below:

6. Use and Control of Cookies

You have the right to personalize your preferences by changing your browser settings while viewing our website. If your browser provides this option, you can modify your cookie preferences through your browser settings. Depending on the capabilities of your browser, data subjects may have the ability to block cookies, receive a warning before cookies are used, or disable or delete only certain cookies. These preferences vary depending on the browser you use, and general information on this topic can be found at https://www.aboutcookies.org/.

Your cookie preferences may need to be set separately for each device you use to access our website.

Our website contains links to other sites. www.glokey.com.tr is not responsible for the privacy policies and content of other websites.

7. YOUR RIGHTS UNDER THE LAW AND GDPR

As personal data owners, you may submit your requests regarding your rights by filling out the Data Subject Application Form published on the website www.glokey.com.tr or by submitting it in writing with another document that includes the mandatory information as specified in the application form. Alternatively, you may also send it by using registered electronic mail (KEP), secure electronic signature, mobile signature, or the electronic mail address that the relevant person has previously provided to the Company and is recorded in the Company’s system, in a way that allows your identity to be verified. The Company will respond to your request as soon as possible and no later than thirty days, free of charge, based on the nature of the request.

In this context, personal data owners have the following rights:

• To learn whether personal data is processed or not,
• If personal data has been processed, to request information about it,
• To learn the purpose of processing personal data and whether it is used in accordance with its purpose,
• To know the third parties to whom personal data has been transferred, whether within the country or abroad,
• To request the correction of personal data if it is inaccurate or incomplete, and to request that the correction be communicated to third parties to whom the personal data has been transferred,
• To request the deletion or destruction of personal data if the reasons for processing no longer exist, and to request that the process be communicated to third parties to whom the personal data has been transferred,
• To object to a result arising from the exclusively automated processing of personal data, which leads to negative consequences for the person,
• To request the compensation of damages in case of damage caused by the unlawful processing of personal data.

The Company ensures that the provisions of the applicable legislation will be implemented in case of any inconsistency between the changes in the legislation and this Privacy and Cookie Policy, and reserves the right to update the Clarification Text in accordance with any amendments in the applicable legislation or developments in personal data processing activities.