Kıran Holding

1. Purpose and Scope

This Cookie Information Text (hereinafter referred to as "the Company" or “Kıran Holding”) aims to clarify the general definitions of cookie data related to visitors on the Company’s website, to specify the types of cookies used, and to establish the procedures and principles regarding the processing and management of cookie data in compliance with the Law No. 6698 on the Protection of Personal Data and the “GUIDE ON COOKIE APPLICATIONS” published by the Authority.
This disclosure covers the processing of personal data via cookies; cookies that do not involve the processing of personal data are excluded. It applies to both desktop and mobile websites or web applications maintained by the Company.
We may update this disclosure when necessary; therefore, please ensure you access the most current version of the disclosure whenever you use our web and mobile services.

2. Definition of Cookie

A cookie is a type of text file placed on the user’s device by website operators, transmitted as part of an HTTP(S) request, and it allows the storage of certain information about users on their terminal devices in a compact, rich-text formatted file when a webpage is visited.

3. Types of Cookies

Cookies are classified according to their duration, purpose, and parties involved. The types of cookies and their descriptions are as follows:

3.1. According to Duration

Session Cookies
Also known as temporary cookies, session cookies are used to maintain continuity of the session. They are deleted when the user closes the web browser.

Persistent Cookies
Persistent cookies are not deleted when the browser is closed. They are deleted on a specified date or after a specified time. Persistent cookies, sometimes known as tracking cookies, can be used by advertisers to record a user’s browsing habits over a long period or to keep users logged in so they don’t need to re-enter login credentials every time they visit a website.

3.2. According to Purpose

Strictly Necessary Cookies (Essential Cookies)
These are cookies necessary for the operation of the website and are required to provide an information society service explicitly requested by the user (such as logging in, form submission, remembering privacy preferences). Cookies used for purposes defined under Criteria A and B in Section 5 are considered essential. Blocking these cookies may cause parts of the site to stop functioning correctly and they should not be used for marketing purposes.

Functional Cookies
These cookies are used for personalization and remembering user preferences on the site or application (including desktop, mobile, or IoT applications). Since they do not fall under essential cookies, obtaining explicit consent is required when the user has not clearly requested the information society service enabled by these cookies.

Performance/Analytical Cookies
These cookies are used to collect statistical measurements to analyze user behavior, helping with site improvement and tracking the effect of advertisements. They enable the estimation of unique visitors, identification of key search keywords driving traffic, and monitoring of site navigation.

Advertising/Marketing Cookies
These cookies track users’ online activities to determine their interests and display targeted advertisements. Behavioral advertising is widely used because it allows more effective and resource-efficient ad targeting based on users’ preferences and trends. This includes tracking, profiling, and delivering relevant advertisements to users based on their analyzed online behavior.

3.3. According to Parties

First-Party Cookies
Cookies set by the website or domain that the user visits directly (i.e., the URL shown in the browser’s address bar).

Third-Party Cookies
Cookies set by a domain different from the one the user visits.

4. Legal Grounds for Processing Personal Data via Cookies

The Company considers whether the processing of personal data via cookies is based on "explicit consent" or another legal ground under Articles 5 and 6 of the Law. If processing is based on a legal ground other than explicit consent, then obtaining user consent is not required. The Company first determines whether the processing purpose falls under any of the non-consent legal grounds; if not, processing is based on explicit consent.

For non-essential cookies, we obtain explicit consent from users and allow them to modify their preferences at any time through a cookie management panel. Users can view cookie categories and toggle all except strictly necessary cookies on or off. If consent is not granted, we encourage saving your preferences or changing browser settings—but note that disabling cookies may affect site functionality. Essential cookies are processed based on legal grounds under Article 5/2 of the Personal Data Protection Law (such as legitimate interest or necessity for the performance of a contract).

4.1. Use of Cookies Requiring Explicit Consent

Social Plugin Tracking Cookies
Many social networks offer plugins that can be embedded by site owners to provide functionalities that could be considered explicitly requested by the user. However, if these are used for behavioral advertising, analytics, or market research, they do not fall under essential cookies. Without consent, social networks cannot legally collect data on non-members using such plugins.

Online Behavioral Advertising Cookies
These cookies require explicit consent, including those used for frequency capping, keeping financial records, ad partnerships, click fraud detection, research, product development, and debugging, as such purposes do not fit under strictly necessary service requirements.

4.2. Use of Cookies Under Legal Grounds Other Than Consent

The Company explains certain use cases where cookies can be used based on legal grounds other than explicit consent:

Load Balancing Session Cookies (Criterion A)
For load balancing, session continuity is maintained by directing user requests to the same server in a pool. These session cookies serve merely to identify communication endpoints and do not require consent since they are necessary for the process.

Security Cookies for Website Protection (Criterion B)
Cookies used for security purposes—such as limiting requests per session for traffic shaping or protection against threats—are considered essential and fall under legal grounds such as protecting individual fundamental rights or necessity for service delivery.

Which Cookies We Use
If you provide consent, performance cookies may be used to analyze user behavior for site performance enhancements and to measure the impact of advertisements.

6. COOKIE WALLS

Cookie walls block access to site content unless cookies are accepted. Our Company avoids using cookie walls that impede lawful, explicit consent.

7. Parties’ Responsibilities

Whenever third-party cookies are placed on the site, both our Company (as data controller) and the third party are responsible for clearly informing users and seeking their consent.

Transfer of Personal Data

Your personal data may be transferred to domestic service providers in accordance with Article 8 of Law No. 6698, for purposes such as commercial security, secure storage, electronic or physical data backup, and these service providers may be located within the country.

Changing Cookie Preferences via Browser Settings

You can change your cookie preferences at any time through the settings on our website by toggling options in the cookie management panel and clicking “Save Settings,” then refreshing the page. Note that essential cookies are required for site functionality.

You can also manage cookies in commonly used browsers via the following links:

Google Chrome

Google Analytics

Mozilla Firefox

Safari

Opera

Internet Explorer

Facebook

10. Your Rights & Contact Information

As a data subject, you have the right to:

Learn whether your personal data is processed

Request information regarding processed data

Be informed about the purpose and usage of your processed data

Know domestic or international third-party recipients

Request correction of inaccurate data and notification to third parties

Request deletion or destruction of your personal data (and notification to third parties) when grounds requiring processing cease to exist

Object to outcomes arising solely from automated processing

Demand redress for damages if your rights are violated

Submit your requests in accordance with the procedures outlined in the “Communiqué on Procedures and Principles for Applying to the Data Controller.” The Company will respond free of charge within no more than 30 (thirty) days. If a fee is legally permitted for additional services, it may apply as specified by the Personal Data Protection Board’s tariff.

KIRAN HOLDING INC.
Address: Altunizade Neighborhood, Ord. Prof. F. K. Gökay Cad. No: 18/2 B Block, Üsküdar, İstanbul, Türkiye
Phone: +90 216 554 14 00
Email: kvk@kiran.com.tr