In this privacy policy document, COACHTECH BİLİŞİM HİZMETLERİ SANAYİ TİCARET LİMİTED ŞİRKETİ will be referred to as “Coachtech.”

Purpose and Scope

Through this “Policy,” we aim to:

• Inform you about the types of information we collect from visitors and customers, and the purposes for which it is used,
• Explain where, how, and by what methods we store the information obtained from visitors and customers,
• Describe the conditions under which the collected and stored data may or may not be shared with third parties,
• Provide information about the use of our website.

This policy also aims to reinforce the value and sensitivity we place on your personal data and raise awareness among our team about the importance of protecting your data.

Definitions

Within the framework of this policy, terms used in accordance with the Turkish Law on the Protection of Personal Data No. 6698 (KVKK) are defined as follows:

• Explicit Consent: Consent given freely with adequate information regarding a specific matter.
• Anonymization: Making personal data unidentifiable with any particular person, even by combining it with other data.
• President: President of the Personal Data Protection Authority.
• Data Subject: The real person whose personal data is processed.
• Personal Data: Any information relating to an identified or identifiable person.
• Processing of Personal Data: Any activity performed on personal data, such as collection, recording, storage, alteration, or transfer, whether by automated means or part of a data recording system.
• Board: The Personal Data Protection Board.
• Authority: The Personal Data Protection Authority.
• Data Processor: A real or legal person authorized by the data controller to process personal data on their behalf.
• Data Recording System: A system in which personal data is structured based on specific criteria.
• Data Controller: A real or legal person who determines the purposes and means of processing personal data, and is responsible for establishing and managing the data recording system.

Processing of Personal Data

Personal data refers to any information related to an identified or identifiable person. This includes information associated with your identity, such as your name, email address, or postal address. Information that cannot be associated with your identity (e.g., statistical information on the number of website users) is not considered personal data.

You can use our website without disclosing your identity or providing personal information. However, if you wish to request information or apply for a position, we may ask for your surname and other personal information. Providing this information is your personal choice. We will always indicate which information is required (mandatory information) for the relevant service.

No automated decision-making is conducted based on your personal data in connection with the use of our website. We store your data on servers specifically protected within the European Union to safeguard data privacy. These servers protect your information against loss, damage, unauthorized access, modification, or distribution through technical and organizational measures. Access to your information is restricted to a limited number of authorized individuals responsible for the technical, commercial, or editorial management of the website.

Personal data you share with us for our website’s services is encrypted and transferred online. We use SSL encryption (Secure Socket Layer) for secure data transmission.

Conditions for Processing Personal Data

Article 20 of the Turkish Constitution specifies that personal data can only be processed “in cases provided for by law or with the individual’s explicit consent.” Thus, the right to process personal data is recognized as a fundamental right, and any restriction on this right requires either explicit consent or exceptions specified by law.

Explicit Consent

According to the lawmaker’s definition, we must inform you as the data subject before we can process your data, and then obtain your explicit consent. However, there are situations where Turkish law permits the processing of data without explicit consent.

Generally, we use your personal information to fulfill the services you have requested (e.g., requesting information materials or subscribing to a newsletter). Additional details about our services are provided below. We do not share your information with third parties, especially for advertising purposes, without your explicit consent. Your personal information may only be disclosed to others with your consent or where legal regulations and/or official authorities or court orders require us to disclose it. In this context, information may be disclosed to comply with criminal investigations, prevent harm, or enforce intellectual property rights.

As noted above, processing personal data requires either explicit consent or the presence of an exception specified by law. Article 5 of KVKK Law No. 6098 outlines these exceptions. When these circumstances apply, there is no need to obtain the explicit consent of the data subjects.

According to KVKK Article 5, exceptions include:

• When processing is explicitly provided for by law.
• When it is mandatory to protect the life or physical integrity of the person who cannot express their consent due to actual impossibility or whose consent is not legally valid.
• When it is necessary to process personal data of the parties to a contract, provided that it is directly related to the conclusion or fulfillment of that contract.
• When processing is necessary for compliance with a legal obligation to which the data controller is subject.
• When the data has been made public by the data subject.
• When processing is necessary for the establishment, exercise, or protection of a right.
• When processing is necessary for the legitimate interests of the data controller, provided it does not violate the fundamental rights and freedoms of the data subject.

In this policy, we will always specify the legal basis on which we process your personal data.

Data Deletion and Retention Period

We will delete or block your personal data as soon as the purpose for which it was collected no longer applies. However, your data may be retained due to legal obligations. For example, this applies to statutory data retention and documentation requirements. In such cases, we will delete or block your personal data after the relevant obligations end.

Use of Our Website

Information About Your Computer

Each time you access our website, we collect the following data about your computer: your IP address, browser request, and request timestamp. We also gather status and the amount of data transferred for the request, along with information about the browser, operating system, and any website from which you accessed our site. Your IP address is stored only during the session, then deleted or anonymized. Other information is retained temporarily for service maintenance, error detection, and usage analysis, as permitted under Article 5 of the KVKK.

Use of Cookies

Our website uses cookies like most other sites. Cookies are small text files stored on your device that exchange specific information with our website. A cookie generally includes the domain from which it originates, its lifetime, and a unique identifier. Cookies enable us to recognize your computer, streamline settings, and improve the service quality we provide.

We primarily use “session cookies,” which are deleted after you end your browsing session, and some persistent cookies to improve user recognition and engagement. Third-party cookies, which are managed by service providers, may also be used. Most browsers automatically accept cookies; however, you can adjust your settings to disable or notify you about cookies. Please note that disabling cookies may limit your use of our website.

Cookie Consent

Our website enables you to manage your preferences regarding cookie settings.

Google Analytics

We use Google Analytics, a web analysis service from Google Inc. (“Google”). Google Analytics uses cookies to help analyze website usage. Information gathered is generally transferred to Google’s servers in the U.S. and stored there. However, when IP anonymization is enabled, Google will truncate your IP address within the EU or European Economic Area before transmission. Google uses this data to evaluate site usage, create reports, and provide other website and internet-related services. IP addresses from your browser are not combined with other Google data.

You can prevent cookies by adjusting your browser settings, although this may limit website functionality. Additionally, you can download a browser add-on to prevent Google from collecting data: Google Opt-Out.

Meta Pixel

We use Meta Pixel for statistical and market research purposes to measure ad effectiveness on Facebook and Instagram. When you click on one of our ads and perform an action on our website (such as completing a form), Meta can track this, allowing us to tailor our advertising. Information gathered includes IP address, browser details, browsing history, cookies, age, gender, and language settings. Data processing occurs only with your consent per GDPR Article 6(1)(a), and Meta retains data only as needed for its purposes. For more details, see Meta’s Privacy Framework.

Sharing Content

Our website allows you to share individual pages with third parties. Selecting this function opens a new window that is outside our website and managed by the respective social media site or server. This is subject to the respective platform’s privacy policy.

Application Portal

You may apply directly for a position at Coachtech via our website.

Use of Personal Information in Applications

We only use personal data provided in applications for candidate selection and internal statistical purposes. Your data is stored on Coachtech’s servers and is accessible only by authorized personnel. Personal data will not be shared with third parties.

Retention of Applications

Your personal information will be stored to answer future questions or for potential future openings. You may request data deletion, updating, restriction, or objection by emailing us at privatepolicy@coachtechis.com. Following an unsuccessful application, data is deleted after three months unless you consent to a longer retention period. Successful applicants’ data is retained per legal obligations for employment purposes.

Contacting Coachtech

You may contact us through our website’s contact form, social media, or newsletter.

Contact Form

When using our contact form, we request personal details such as your name and email. Data collected is used solely to respond to your inquiry per your consent under KVKK Article 5. Your data is retained temporarily for follow-up and deleted after handling, subject to legal retention requirements.

Social Media Channels

Our website may link to social networks. Clicking on these links will redirect you to the platform, and our privacy policy no longer applies. For more details, consult each platform’s privacy policies.

Newsletter

By subscribing to our newsletter, your email address will be used solely for sending newsletters until you unsubscribe. Information such as your name may be used for personalized greetings. To unsubscribe, use the unsubscribe link in each newsletter or contact us.

Information We Collect and Why

• Email Addresses: We use your email to communicate with you. If you no longer wish to receive emails, inform us, and we will remove your address.
• Event Orders and Registrations: Forms for event registrations may require payment details used only for that transaction.
• Online Surveys: Surveys may request demographic information. This data is used solely with your consent for survey purposes.

Rights and Further Inquiries

You have rights regarding your personal data, including access, correction, restriction, and deletion. For more details or to exercise your rights, contact our data protection officer.

For further inquiries, requests, or complaints, please reach out to:

COACHTECH BİLİŞİM HİZMETLERİ SANAYİ TİCARET LİMİTED ŞİRKETİ
Email: info@coachtechis.com
Last Update: March 2024