PRIVACY POLICY

This Personal Data Privacy Policy (hereinafter referred to as the Privacy Policy) applies to all information that the Cybor Holding Company, located on the domain name www.cyborhoding.com (hereinafter referred to as the Site), can receive about the User while using the Company's Site, programs, and products of the Company.

1. DEFINITION OF TERMS

1.1 The following terms are used in this Privacy Policy:

1.1.1. “Administration of the Company's Website (hereinafter referred to as the Website Administration)” - authorized employees to manage the Website, acting on behalf of the Cybor Holding Company, who organize and (or) carry out the processing of personal data, and also determine the purposes of processing personal data, the composition of personal data, subject to processing, actions (operations) performed with personal data.

1.1.2 “Personal data” - any information relating directly or indirectly to a specific individual (subject of personal data).

1.1.3. “Processing of personal data” - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.1.4. “Confidentiality of personal data” - a mandatory requirement for the operator (or other people who have gained access to personal data) to prevent their distribution without the consent of the subject of personal data or other legal grounds.

1.1.5. “User of the Company's Website (hereinafter referred to as the User)” is a person who has access to the Website via the Internet and uses the Company's Website.

1.1.6. “Cookies” - a small piece of data sent by a web server and stored on the User's computer, which the web client or web browser sends to the webserver in an HTTP request each time it tries to open the page of the corresponding site.

1.1.7. “IP address” is a unique network address of a node in a computer network built using the IP protocol.

2. DEFINITION OF TERMS

2.1. The use by the User of the Company's Website means acceptance of this Privacy Policy and the terms of processing of the User's personal data.

2.2. In case of disagreement with the terms of the Privacy Policy, the User must stop using the Company's Website.

2.3. This Privacy Policy applies only to the Cybor Holding Website. The Company does not control and is not responsible for the websites of third parties, to which the User can follow the links available on the Company's website.

2.4. The Site Administration does not verify the accuracy of personal data provided by the User of the Company's Site.

3. SUBJECT OF THE PRIVACY POLICY

3.1. This Privacy Policy establishes the obligations of the Company's Website Administration to not disclose and ensure the confidentiality of personal data that the User provides at the request of the Website Administration when registering on the Company's Website or when placing an order for the purchase of IT products.

3.2. Personal data authorized for processing under this Privacy Policy is provided by the User by filling out the registration form on the Website of the Cybor Holding Company and includes the following information:

• Name and Surname of the User;
• Contact phone number of the User;
• E-mail address;

3.3. The Company protects Data that is automatically transmitted while viewing ad units and when visiting pages on which the system's statistical script ('pixel') is installed:

• IP address;
• information from cookies;
• information about the browser (or other program that accesses the display of advertising);
• access time;
• the address of the page on which the ad block is located;
• referrer (address of the previous page).

3.3.1. Disabling cookies may result in the inability to access parts of the Company's Site that require authorization.

3.3.2. The company collects statistics about the IP addresses of its visitors. This information is used to identify and solve technical problems, to control the legality of financial payments.

3.4. Any other personal information not specified above (purchase history, browsers and operating systems used, etc.) is subject to secure storage and non-distribution, except as provided in clause 5.2. of this Privacy Policy.

4. PURPOSE OF COLLECTING USER'S PERSONAL INFORMATION

4.1. The User's personal data may be used by the Administration of the Company's Website for the following purposes:

4.1.1. Identification of the User registered on the Company's Website for placing an order and (or) concluding an IT Products Purchase and Sale Agreement remotely.

4.1.2. Providing the User with access to personalized resources of the Company's Website.

4.1.3. Establishing feedback with the User, including sending notifications, requests regarding the use of the Company's Website, the provision of services, processing requests and applications from the User.

4.1.4. Determining the location of the User to ensure security, and prevent fraud.

4.1.5. Confirmation of the accuracy and completeness of personal data provided by the User.

4.1.6. Creating an account for making purchases, if the User has agreed to create an account.

4.1.7. Notifications to the User of the Company's Website about the status of the order.

4.1.8. Processing and receiving payments, confirming tax or tax benefits, contesting a payment, determining the right to receive a credit line by the User.

4.1.9. Providing the User with effective client and technical support in case of problems related to the use of the Company's Website.

4.1.10. Providing the User with his consent, product updates, special offers, pricing information, newsletters, and other information on behalf of the Company or on behalf of the Company's partners.

4.1.11. Implementation of advertising activities with the consent of the User.

4.1.12. Providing the User with access to the websites or services of the Company's partners in order to obtain products, updates, and services.

5. METHODS AND TERMS OF PROCESSING PERSONAL INFORMATION

5.1. The processing of the User's personal data is carried out without time limit, in any legal way, including in personal data information systems using automation tools or without using such tools.

5.2. The User agrees that the Site Administration has the right to transfer personal data to third parties, in particular, courier services, postal organizations, telecommunications operators, solely for the purpose of fulfilling the User's order placed with Cybor Holding, including the delivery of IT products.

5.3. In case of loss or disclosure of personal data, the Site Administration informs the User about the loss or disclosure of personal data.

5.4. The Site Administration takes the necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.

5.5. The Site Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

6. OBLIGATIONS OF THE PARTIES

6.1. The user is obliged to:

6.1.1. Provide information about personal data necessary to use the Company's Website.

6.1.2. Update, complete the provided information about personal data in case of changes in this information.

6.2. The Site Administration is obliged to:

6.2.1. Use the information received solely for the purposes specified in clause 4 of this Privacy Policy.

6.2.2. Ensure that confidential information is kept secret, not disclosed without the prior written permission of the User, and also not to sell, exchange, publish, or disclose in other possible ways the transferred personal data of the User, with the exception of clause 5.2. of this Privacy Policy.

6.2.3. Take precautions to protect the confidentiality of the User's personal data in accordance with the procedure usually used to protect this kind of information in existing business transactions.

6.2.4. Block personal data relating to the relevant User from the moment the User’s request or his legal representative or the authorized body for the protection of the rights of personal data subjects for the period of verification is contacted or requested, in case of revealing false personal data or illegal actions.

7. RESPONSIBILITIES OF THE PARTIES

7.1. The Site Administration, which has not fulfilled its obligations, is liable for losses incurred by the User in connection with the misuse of personal data, in accordance with Turkish law, except as provided in clauses 5.2. and 7.2. of this Privacy Policy.

7.2. In case of loss or disclosure of Confidential Information, the Site Administration is not responsible if this confidential information:

7.2.1. Became public property before its loss or disclosure.

7.2.2. It was received from a third party until it was received by the Site Administration.

7.2.3. Was disclosed with the consent of the User.

8. DISPUTES RESOLUTION

8.1. Before going to court with a claim for disputes arising from the relationship between the User of the Company's website and the Website Administration, it is mandatory to file a claim (a written proposal for a voluntary settlement of the dispute).

8.2. The recipient of the claim, within 30 calendar days from the date of receipt of the claim, notifies the claimant in writing of the results of the consideration of the claim.

8.3. If an agreement is not reached, the dispute will be referred to the judicial authority in accordance with the current legislation of Turkey.

8.4. The current legislation of Turkey applies to this Privacy Policy and the relationship between the User and the Site Administration.

9. ADDITIONAL PROVISIONS

9.1. The Site Administration has the right to make changes to this Privacy Policy without the consent of the User.

9.2. The new Privacy Policy comes into force from the moment it is posted on the Company's Website, unless otherwise provided by the new version of the Privacy Policy.

9.3. The current Privacy Policy is posted on the page at www.cyborhoding.com