Policy and Privacy Notice on Cookie Usage

This website uses cookies and similar technologies (collectively referred to as “Cookies“) to improve the user experience and ensure its effective operation. The use of these technologies and the personal data processing activity within this scope are carried out in accordance with the legislation we are subject to, especially the Personal Data Protection Law No. 6698 (“KVKK”) and the European Union 2016/679 General Data Protection Regulation (“GDPR”).

Gözen Digital Aviation (“Company“) has prepared this Policy and Privacy Notice on Cookie Usage (“Policy“) in order to provide information about cookies that may be used during your visit to the company’s website (“Website“) and personal data processing activities related to these cookies.

Cookies and personal data processing activities used on our website may change over time; the types or functions of existing cookies may be changed, as well as new cookies or processing methods may be added. Therefore, we reserve the right to make changes to this Policy at any time. In addition, before the text is updated, we may request your consent for new or changing data processing processes or cookies within the framework of the applicable legislation.

Any changes made to this Policy take effect as soon as they are published on our website or other public platforms. Information on when the text was last updated is available at the top of this document/page.

For more detailed information about the purposes of processing your personal data by the Company, we recommend reviewing other policies and notices under the “Protection of Personal Data” tab on our website.

1. Definitions and Abbreviations

Cookies

Cookies are small text files that are transferred locally from websites to the hard disk of your computer or mobile device and stored there when you visit websites. This will save your actions and preferred settings during your browser session or for your next visit to the websites. Websites use cookies to recognize you when a connection is established between your browser and the server. A cookie is designed to make a website easier to use by its visitors.

We may use similar techniques such as pixels, conversion tracking, etc. on our websites. For the sake of consistency, all these techniques together are hereinafter referred to as “Cookies”.

Personal Data

Any information relating to an identified or identifiable natural person

Data Processing

All kinds of operations performed on personal data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic means or by non-automatic means provided that they are part of any data recording system.

Data Subject

Natural person whose personal data is processed

Policy

This Cookie Policy

Company

Gözen Digital Aviation

Data Controller

The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system

Data Processor

A natural or legal person who processes personal data on behalf of the data controller based on the authorization granted by the data controller

2. Types of Cookies

In Terms of Purpose of Use

• Mandatory / Necessary Cookies: It refers to cookies that are necessary to ensure the effective operation of the website, to provide various services to the user through websites, and to fulfill some functions, such as access to secure areas. These cookies are necessary for the website to function. These cookies are used compulsorily in order to fulfill an information society service (such as log-in, form filling, remembering privacy preferences) requested by the user.

If mandatory cookies are blocked, some parts of the website will not work, and these cookies are not used for marketing purposes.

In general, they can be considered as the types of cookies that go to processing conditions other than explicit consent. Your personal data collected through these cookies is processed based on the legitimate interest of our Company.

• Functional Cookies: It refers to cookies used for personalization and remembering preferences on websites or applications (including applications on desktop, mobile or IOT devices), aiming to provide users with an improved and personalized experience.

Your personal data collected through these cookies is processed based on your consent. Please note that without these cookies, the website cannot remember your previous preferences and provide you with a personalized experience.

• Analytical/Performance Cookies: These are cookies used by internet analytical tools that allow statistical measurement in order to analyze the behavior of users on websites to collect statistical information such as time spent on the website, pages used, click information, and time spent on a page. These cookies are frequently used to improve the site, including the measurement of the impact of advertisements on the people concerned.

They are used by website owners to estimate the number of unique visitors, to identify the most important search engine keywords that lead to a web page, or to track website navigation

Your personal data collected through these cookies is processed based on your consent.

• Advertising/Marketing Cookies: Cookies that collect information about users and their interests and browsing habits. With cookies for advertising and marketing purposes, it is aimed to track the online movements of users on the internet, to determine their personal interests and to show advertisements to users on the internet for these interests.

They enable the implementation of functions such as preventing the repetition of the same advertisements, displaying advertisements properly and, in some cases, displaying advertisements according to their interests.

Your personal data collected through these cookies is processed based on your consent.

In terms of Cookie Management

• First Party Cookies: It is placed directly by the website visited by the user, i.e. the URL (ornek.com.tr) shown in the address bar of the browser. It refers to cookies created by the Company and placed on the website and under the control of the Company.
• Third Party Cookies: It refers to cookies created and managed by third-party companies that the Company cooperates with

In Terms of the Storing Period

• Session Cookies: Session cookies, also called temporary cookies, are used to ensure the continuity of the session. Session cookies are also deleted when the user closes the internet browser
• Persistent Cookies: A persistent cookie that is not deleted when the internet browser is closed and is automatically deleted on a certain date or after a certain period of time. Through this cookie, the processed data of the user is transmitted to the server every time the user visits a website. For this reason, persistent cookies are sometimes also referred to as tracking cookies. For example, advertisers can save and use information about a user’s web browsing habits over a long period of time.

They can also be used to ensure that users do not re-enter their login details each time they log into their accounts on websites.

3. Which Cookies Do We Use?

4. For what purposes do we use cookies?

Our main purposes in the use of cookies are as follows:

• Ensuring basic functionality: For example, maintaining basic functionality such as the fact that logged-in users do not need to log in again when switching between pages within the site.
• Measuring and improving site performance: For example, ensuring compatibility between different servers, making performance optimizations by analyzing the number of visitors, or enabling users to access the information they are looking for faster.
• Improving the user experience: For example, sharing content on social media platforms, re-presenting information such as usernames or search history remembered from visitors’ previous logins
• Personalized content and advertising: For example, displaying interest-oriented advertisements by taking into account the products or pages viewed by visitors.

5. How can you control the use of cookies?

When you visit our website, you will see a warning screen with information about cookies. On this screen;

• When you choose the “Accept All Cookies” option, you are deemed to have given your consent to the use of all cookies used on our site.
• If you click on the “Accept Only Mandatory/Necessary Cookies” option, you only allow the use of cookies that are mandatory/necessary for basic functions. We would like to state that the use of these cookies is not subject to your explicit consent and, as mentioned above, your personal data collected through these cookies is processed based on the legitimate interest of our Company.
• You can also determine which types of cookies you will allow according to your personal preference by going to the “Manage Preferences” section. If you wish, you can withdraw this consent at any time and rearrange your preferences via the cookie settings link at the top of the page

You can also control cookies using your browser settings. Below are the cookie management steps for some common browsers:

• Google Chrome: You can edit permissions by clicking on the “lock” icon or the letter “i” on the left of the address bar and selecting “Cookies” from the drop-down menu.
• Internet Explorer: You can enable or disable cookies by switching to the “Security” tab from the “Tools” menu in the upper right corner.
• Mozilla Firefox: You can go to the “Settings” section from the menu in the upper right corner and make your cookie preferences in the “Privacy and Security” tab.
• Safari: You can enter the “Safari” section from the “Settings” menu on your device and manage cookies through the “Privacy and Security” settings.
• Other Browsers (Opera, Microsoft Edge, etc.): You can find detailed information on the help or support pages of these browsers.

In addition, you can use the following resources to learn more about cookies and general management:

• www.allaboutcookies.org
• www.youronlinechoices.eu
• Privacy Badger

For mobile devices, you can control your cookie or SDK (Software Development Kit) preferences by following the instructions in the “Settings” or “Privacy” sections of your device, or you can download the Lumen Privacy Monitor application.

Finally, we would like to point out that you can continue to use our websites even if you disable cookies. However, disabling some cookies may cause you not to fully utilize all the functions of the site.

6. What are the Legal Basis, Purposes of Processing, and Collection Methods of Your Personal Data under this Policy?

Your personal data is processed automatically through cookies when you visit our website or use our mobile application, based on the data processing conditions specified in the second paragraph of Article 5 of the KVKK and the first paragraph of Article 6 of the GDPR. These conditions include;

• Data processing is mandatory in line with the legitimate interests of our Company, provided that it does not harm the fundamental rights and freedoms of the data subject. For example, purposes such as meeting the functional and security requirements for the operation of the website, performing performance analysis and improving the products and services offered on the website are within this scope. These situations are clearly stated for the relevant cookies under the heading “2. Types of Cookies” in accordance with the types of cookies.
• In addition, your personal data is processed without explicit consent in cases where data processing is mandatory for our company to fulfill its legal obligations or data processing activities directly related to the establishment or performance of a contract are required. These purposes are clearly stated for the relevant cookies under the heading “2. Cookie Types” in accordance with the cookie types.
• Unless specified in this policy and except for all other cases listed, your personal data will only be processed on the basis of your explicit consent.

7. To whom is your personal data transferred under this Policy, and what are the purposes of transfer?

Your personal data processed under this Policy may be transferred to third parties in accordance with the provisions of the KVKK and GDPR regarding the transfer of personal data, limited, related and proportionate to the purposes of processing, only in the following cases.

Recepients	Purposes
Authorized persons, institutions, or organizations	Fulfilling our legal obligations, providing information to authorized persons, institutions or organizations in this context, carrying out legal processes, and carrying out our activities in accordance with the legislation.
Suppliers, Business Partners, and Group Companies	We may share your personal data with third parties, our subsidiaries, business partners, and group companies, limited to the purposes of receiving support from third parties within the scope of service procurement and ensuring business continuity.

8. If your personal data is transferred abroad within the scope of this Policy, what are the purposes of the transfer abroad?

We may transfer your personal data abroad for data storage and messaging services. Please be informed that your personal data may be transferred abroad since digital services such as cloud applications and storage, hosting, and messaging systems used by the Company are obtained from service providers located abroad.

We also emphasize that third parties to whom data is transferred may store your personal data on their servers at home or abroad.

9. What are your rights as a data subject under this Policy?

If you allow us to process your personal data, please note that you can withdraw this consent at any time. Please contact us to withdraw your consent. Please note that your consent can only be withdrawn for future processing activities and such withdrawal has no impact on the lawfulness of past processing activities. In some cases, we may be entitled to continue processing your personal data on a different legal basis despite your withdrawal

In accordance with the Article 11 of the KVKK, you have the following rights regarding your personal data;

• Right to be Informed: To learn whether personal data is processed, To request information if personal data is processed, To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
• Right of Access: To know the third parties to whom personal data are transferred domestically or abroad,
• Right to Rectification: To request correction of personal data in case of incomplete or incorrect processing,
• Right to Erasure: Request deletion or destruction of personal data,
• Right to Notification: In case of correction, deletion or destruction of personal data, to request notification of these transactions to third parties to whom personal data are transferred,
• Right of Objection: To object to the occurrence of a result to the detriment of the person himself/herself by analysing the processed data exclusively through automated systems
• Right to Compensation: To demand compensation for damages in case of loss due to unlawful processing of personal data.

In accordance with the articles within Chapter 3 of the GDPR, you have the following rights regarding your personal data;

• Right to be Informed: Organisations must tell individuals what data is collected, how it is used, how long it will be stored and whether it will be shared with third parties.
• Right of Access: Individuals have the right to request a copy of the information an organisation holds on them.
• Right to Rectification: Individuals have the right to correct inaccurate or incomplete data.
• Right to Erasure and to be Forgotten: In certain circumstances, individuals can ask organisations to erase personal data stored on them, including on the Internet.
• Right to Data Portability: Individuals can request organisations to transfer all data held on them to another company
• Right to Restriction of Data Processing: Individuals can request that an organisation limit the way it uses their personal data.
• Right to Object: Individuals have the right to object to certain types of processing, such as direct marketing.
• Rights relating to automated individual decision-making tools, including profiling: Individuals can ask organisations to provide a copy of their automated processing activities if they believe that data is being processed unlawfully. Organisations should also remind individuals that they are free to exercise their rights and explain how they can do so.

How Can You Exercise Your Legal Rights Under This Policy?

In order to exercise these rights granted to the data subjects under Article 11 of KVKK and Article 3 of the GDPR, certain procedures are set out in the Communiqué on the Procedures and Principles of Application to the Data Controller. To exercise your rights and to get information about your rights.

If you have any questions about our Cookie Policy, or if you wish to lodge a complaint about a possible personal data breach or exercise one of your data protection rights, please contact us as described below.

• You can send your requests to the following address of our company by hand upon identification in person or through a notary public,
• You can apply to our company’s dpo@gozendigital.com e-mail address or our company’s registered electronic mail (KEP) gozenteknoloji@hs03.kep.tr address with your secure electronic signature and mobile signature or your e-mail address previously notified to us by you and confirmed by us in our systems.