Privacy Policy

Effective Date: October 15^th, 2019.

Introduction

This Privacy Policy describes how BORDA TEKNOLOJI BILISIM A.S., (“Borda,” “we,” “our” or “us”) collects, uses, and shares information about you through websites or mobile apps operated by us from which you are accessing this Privacy Policy (the “Websites”), through our social media pages (our “Social Media Pages”) as well as through email messages that we may send to you that link to this Privacy Policy (collectively, including the Websites and our Social Media Pages, the “Services”).

This Privacy Policy does not apply to our data collection activities offline or otherwise outside of our Services (unless otherwise stated below or at the time of collection). By using our Services, you agree to our Terms of Use. By consenting to this Privacy Policy you consent to our collection, use and disclosure practices, and other activities described in this Privacy Policy. If you do not agree and consent, discontinue use of the Services, and uninstall Service downloads and applications.

“Personal Information” is information, whether true or not, that can be used to identify you (whether alone or in combination), which may include:

Name
E-mail address
Postal Address
Geolocation information
Telephone number
Fax number
Industry
Your request/suggestion/complaint you have sent to Borda by means of the communication form
Your IP address
Your curriculum vitae information you have communicated through Websites

CHANGES TO THIS PRIVACY POLICY
We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Subject to applicable law, your continued use of our Services indicates your consent to the privacy policy posted. If the changes are material, we may provide you additional notice, to your e-mail address.
HOW WE COLLECT INFORMATION
1. Information You Give Us
  We may collect Personal Information you provide directly to us via the Services. For example, Personal Information may be collected when you use or register for our Services, subscribe to our notifications, post on our Services, participate in promotional activities, apply for a job, communicate with us through the Services, or use an app installed on a device. You may choose to voluntarily submit certain other information to us through the Services, including Personal Information, but you are solely responsible for your own Personal Information in instances where we have not collected such information or requested that you submit such information to us. De-Identified Data Personal Information once “de-identified” may not be subject to this Privacy Policy and we and our Service Providers (defined below) may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.
2. Information We Collect Automatically From Your Use of Our Services
  We and our Service Providers collect information about the Services that you use and how you use them. Certain information is collected automatically through your device, such as your IP address; device identifier, Ad ID, browser type; operating system characteristics; information about your use of our Services; and data regarding network connected hardware (e.g., computer or mobile device) (“Usage Information”). To the extent that Usage Information is Personal Information under applicable law or is combined with Personal Information, we will treat that information as Personal Information under this Privacy Policy.
  The methods that we and our Service Providers may use to collect Usage Information include:

Log Information: We collect information about your use of our Services, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, cookies that may uniquely identify your browser or your account, and related data, and store it in log files.
Information Collected by Cookies and Other Tracking Technologies: We and our Service Providers may use cookies or other tracking technologies (“Tracking Technologies”) to collect and store information about interactions with our Services, including information about your browsing behavior. Further information about how we use cookies and tracking technologies, and how you can refuse them, is set out in our Cookie Policy.

1. Personal Information Collected from Other Sources
  We may receive your Personal Information from other sources, such as public databases, joint marketing partners, and social media platforms, and combine that with information we collect about you. To the extent we combine such third party sourced information with Personal Information we collect directly from you, we will treat the combined information as Personal Information. We are not responsible for the accuracy of the information obtained from third parties or third party practices.
HOW WE USE INFORMATION WE COLLECT
We and our Service Providers may use information about you for the following purposes:

To provide, maintain, protect and improve our Services, develop new services, and protect Borda and our users;
To facilitate, manage, personalize and improve your online experience;
To respond to your inquiries and fulfill your requests, such as to send you newsletters, brochures, catalogs and e-mails;
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, enhancing, improving, or modifying our Services, identifying usage trends, and operating and expanding our business activities; and
For our marketing purposes such as to send you advertisements and communicate with you about products, services, offers, promotions, rewards and events we believe may be of interest to you.

HOW WE SHARE INFORMATION
Our agents, vendors, consultants, marketing service providers, and other service providers (collectively “Service Providers”) may receive, or be given access to your information, including Personal Information and Usage Information, in connection with their work on our behalf. These Service Providers may be located in countries other than your country of residence. These Service Providers are prohibited from using your Personal Information for any purpose other than to provide this assistance, although we may permit them to use de-identified data or aggregate information which does not personally identify you or any other user of the Services (for example, we may aggregated Personal Information to calculate the percentage of our users who have a particular telephone area code).We may also share information about you as follows:

As necessary, for the following purposes: (a) to comply with legal process; (b) to respond to requests from public and government authorities, including public and government authorities outside your country of residence to meet national security or law enforcement requirements; (c) to enforce our terms and conditions; (d) to protect our operations and protect our rights, privacy, safety or property, and/or that of you or others; and (e) to allow us to pursue available remedies or limit the damages that we may sustain;
With our affiliates for internal business purposes. For example, processing your orders, fulfilling your requests, providing customer service, and improving our products;
With our subsidiaries, affiliates, business partners, and other third parties for their own business purposes. For example, improving their products and services; and
To a third party in connection with or during negotiations of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

When Borda engages third-party service providers and when disclosure of Personal Information to such providers is necessary for the provision of such service, Borda ensures that such providers protect Personal Information in a manner consistent with this Privacy Policy.

Aggregated Information
Without limiting the forgoing, in our sole discretion, we may share aggregated information which does not identify you or de-identified information about you with third parties or affiliates for any purpose.

Sharing for Marketing Purposes
We will not share your Personal Information with third parties for direct marketing purposes unless we have received your express consent. You have the right to opt-out from direct marketing and can require us to cease to use the data at any time for direct marketing purpose at no cost to you.

Please note that by using our Services you agree to share your Personal Information and Usage Information, as described in this section.

SWEEPSTAKES, CONTESTS, AND PROMOTIONS
We may offer sweepstakes, contests, and other promotions (each, a “Promotion”) jointly sponsored or offered by third parties that may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your Personal Information may be disclosed to third parties for administrative purposes and as required by law (e.g., on a winners list). By entering a Promotion, you are agreeing to the official rules that govern that particular Promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.
INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS
The Services may permit you to post or submit written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personal Information (collectively, “User Content”). If you choose to submit User Content to any public area of our Services, your User Content will be considered “public” and will be accessible by anyone, including us, not subject to this Privacy Policy and may be used to the fullest extent permitted by applicable law. We encourage you to exercise caution when making decisions about what you disclose in such public areas.
THIRD PARTY SERVICES AND SOCIAL FEATURES
Our Services may include hyperlinks to websites, locations, platforms, or services operated by third parties (“Third Party Service(s)“). These Third Party Services may use their own cookies, web beacons and other Tracking Technology to independently collect information about you and may solicit Personal Information from you. Certain functionalities on the Services permit interactions that you initiate between the Services and certain Third Party Services, such as third party social networks (“Social Features”). Examples of Social Features include “liking” or “sharing” our content and otherwise connecting our Service to a Third Party Service. If you use Social Features, and potentially other Third Party Services, information you post or provide access to may be publicly displayed on our Services or by the Third Party Service that you use. Similarly, if you post information on a Third Party Service that references our Services (for example, by using a hashtag associated with Borda in a tweet or status update), your post may be used on or in connection with our Services. Also, both Borda and the third party may have access to certain information about you and your use of our Services and the Third Party Service. To the extent we combine information from Third Party Services with Personal Information we collect directly from you on the Services, we will treat the combined information as Personal Information under this Privacy Policy.Third Party Responsibility
The information collected and stored by third parties remains subject to their privacy practices, including whether they continue to share information with us, the types of information shared, and your choices on what is visible to others on Third Party Services. We are not responsible for the collection, usage, and disclosure policies and practices (including the data security practices) of any other organization, including any Personal Information you disclose to other organizations through or in connection with our Social Media Pages. We make no representations regarding the policies or business practices of any third parties or Third Party Services and encourage you to familiarize yourself with and consult their privacy policies and terms of use.
ADVERTISING, ANALYTICS SERVICES, AND ONLINE TRACKING
We may use third party advertising companies to serve advertisements on our behalf on the Services and/or on Third Party Services and to provide analytics services about the use of our Services and the performance of our ads and content on Third Party Services. In addition, we may participate in online advertising networks and exchanges that display relevant advertisements to our Service visitors, on our Services and on Third Party Services and off of our Services, based on your interests as reflected in your browsing of the Services and certain Third Party Services. These entities may use cookies and other Tracking Technologies to automatically collect information about you and your activities, such as registering a unique identifier for your device and tying that to your online activities on and off of our Services. We may use this information to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Services and Third Party Services and better understand your online activity.Online Behavioral Advertising
Some information about your browsing of the Services and certain Third Party Services may be collected across time and services and shared with third parties to deliver ads and/or other content to you on the Services and certain Third Party Services. Borda may receive information about Third Party Services that you have visited and use it for marketing purposes—a practice sometimes termed “(re)-targeting,” “interest-based advertising,” and “online behavioral advertising.”Third Parties
We are not responsible for third parties or Third Party Services associated with advertising and analytics services, and related tracking activities.
DATA SECURITY
We seek to use reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. In addition, Borda will not keep your Personal Information for longer than necessary for the purposes set out in this policy. Unfortunately, no data transmission or storage system is completely secure and we cannot guarantee the security of your information collected through our Services. Your Personal Information is stored on servers maintained with the assistance of a third party data storage provider.
CHILDREN’S PRIVACY
Our Services are not intended for children and are not targeted to children under the age of thirteen (13). If you are a child under the age of thirteen (13), you are not permitted to use the Services and should not send any information about yourself to us through the Services. We do not knowingly collect any personal information from children under the age of 13 and, if we learn that we have received information from a user under the age of 13, we will delete this information
PRIVACY RIGHTS
You are entitled to apply to Borda for the below-given purposes:

to inquire whether your personal data have been processed, or not; and
to ask for information regarding any such processed personal data; and
to be informed about the purpose of processing of any such data, and also about the fact that whether such data have been used as appropriate to the purpose thereto; and
to be informed about the 3rd parties to which any such data has been transmitted either domestically or internationally; and
to ask for correction of any imperfect or inaccurate data of you in case of any imperfect or inaccurate processing thereof; and
to ask for deletion or disposal of any such personal data in accordance with the terms and conditions prescribed under the applicable regulations thereto; and
to ask for providing information regarding correction, deletion and disposal processes, performed in accordance with the applicable regulations, to the third parties to which any such personal data has been transmitted; and
to raise an objection against such outcome in case of emergence of an outcome that is to the detriment of you upon the analysis of any such processed personal data solely by any automatic system; and also
to claim for compensation of any and all damage and/or loss you might have incurred in case any such personal data have been processed in breach of the law.

We will make good faith efforts to make requested changes in our then-active databases as soon as practicable (but may retain prior information for records to the extent not prohibited by applicable law). Please note that it is not always possible to completely remove or delete all of your information or public postings from our databases and that residual data may remain on backup media or for other reasons. We also may retain cached or archived copies of information about you for a certain period of time.

You hereby represent in the capacity of Data Owner that your personal data hereunder are perfect, accurate and up-to-date, and you may update such data in case of any change thereto. Otherwise, Borda may not be held liability with respect thereto.

CONTACT US
For any requests relating to your Personal Information, or if you have any questions about this Privacy Policy, please contact us at:

Borda Teknoloji Bilisim A.S.,
Resitpasa Mah. Katar Cad. Teknokent
Teknokent ARI-3 Sit No:/504
Sarıyer/İstanbul, TURKEY
data.security@bordatech.com