POLICY FOR CONFIDENTIALITY, PROTECTION OF PERSONAL DATA AND COOKIES

Purpose of the Policy for Confidentiality, Protection of Personal Data and Cookies

This Policy for Confidentiality and Protection of Personal Data is intended to describe:

1. What kind of personal data that our Company collects by means of this web site whose content provider (“Company”) we are (“Web Site”) and by other means;
2. For what purpose and how these personal data shall be used;
3. To whom our Company may disclose these personal data, and
4. Which rights the users have in connection with their personal data collected by our Company via the Web Site and other means and how they may use them.

Information about the Protection of Personal Data
Pursuant to the Personal Data Protection Law no. 6698 (“PDPL”), we hereby inform that the personal data of users and the Web Site members (“User/ Member”) referred to in this Confidentiality and Personal Data Protection Policy shall be recorded, stored, kept, edited, modified and disclosed to those authorities that are statutorily authorized to demand these data in a manner limited to and to the extent with the purpose of processing as described below, and also these data may be transferred to third parties in Turkey or abroad, in such circumstances and subject to such terms and conditions defined in the PDPL, or may be or materialized, categorized or may be otherwise processed as set out in the PDPL.

Processed Personal Data, Purpose and Basis of Processing Personal Data

A User’s/ Member’s name, surname, e-mail address, mobile phone number, page’s traffic data (“Personal Data”) may be processed in order to enter into contracts with the User/ Member, to present, sell and market the Web Site contents, to communicate with the User/ Member about the sales, marketing and trade and to conduct/ proceed with aftermarket services and related operational activities and to do statistical works and marketing research.

Other purposes of processing said Personal Data are, inter alia, to process the Personal Data of the User/ Member and to comply with the obligations to issue all records and documents in line with the purpose of processing them electronically or on paper and to store, report, notify and disclose such information as required by the applicable regulatory agents and other authorities pursuant to the Law no. 5651 on the Regulation of Internet Broadcasts and Combat against the Crimes committed via these Broadcasts and related secondary legislation, and the Law no. 6563 on Regulation of Electronic Committee and related secondary legislation and the Supreme Council of Radio and Television legislation, including mainly the Law no. 6112 on the Organization and Broadcast Services of Radios and Televisions, the Intellectual and Artistic Works Law no. 5846 and Turkish Criminal Code no. 5237 and other applicable statutory regulations.

Personal data may be transferred to third parties in Turkey or abroad with whom we are cooperating with or getting services from under the applicable contracts in order to carry out our Company’s operations or to our subsidiaries and/ or our direct/ indirect affiliates in a manner limited to the purposes of data processing and legal grounds pursuant to applicable regulations and subject to the explicit consent of the Members/ Users whenever required in order to offer better services to the User / Member, and they may be processed in the way described in the PDPL by adopting measures about the data security as required by the PDPL, provided that they shall not be used beyond the purposes and scope defined in this Policy for Confidentiality, Protection of Personal Data and Cookies.

Personal Data of the User/ Member and his browsing and traffic data may be disclosed to such bodies and authorities statutorily authorized to demand such data in order for us to perform our obligations under the applicable law and related to the security purposes (including obligations of disclosure and reporting of information statutorily or administratively, including but not limited to, fighting against the crime and threats to state and public security purposes).

Rights related to Personal Data

A User/ Member may learn about what kind of his personal data are processed and whether or not they are processed and are used in line with the purpose of such processing. He may ask information if his data are processed, and may inquire about the third parties in Turkey or abroad to whom his Personal Data are processed, and if his Personal Data are processed incompletely or incorrectly, or in case of any change to his processed Personal Data, he may request that this data should be corrected, modified, updated, or erased/ destroyed or anonymized in line with conditions set out in Article 7 of the PDPL ; that such procedures (if there are data processed incompletely or incorrectly, the correction of such data, or erasure/ destruction or anonymization subject to terms and conditions set out in Article 7 of the PDPL) should be notified to third parties to whom his Personal Data are transferred. He may object to consequences that are detrimental to him upon an analysis of his Personal Data done by means of solely automated systems, and he may request that in case he sustains a damage due to the unlawful processing of his personal data, he may ask that he should be compensated against such losses. The User/ Member may exercise his rights in this respect by sending his requests to us as follows pursuant to Article 13/f.1 of the PDPL:

1. To send an e-mail that is signed with secure electronic signature of the Member/ User to kisiselveri@stardrama.com.tr (also he may send a file in “word or pdf” form addressed to our Company, provided that it should be signed with secure electronic signature).
2. To send an e-mail which shall be signed by the User’s/ Member’s secure electronic signature to our Company’s registered e-mail address; or
3. To apply to our Company by sending a petition originally signed by him via cargo.

Storage Time for Personal Data

Our Company shall store Personal Data processed by it under the PDPL for such time only as set out in the applicable legislation, or where no time period has been defined there, as long as it is necessitated by the purpose of processing personal data. Any stored data shall be erased, destroyed or anonymized when reasons for processing them are no longer applicable. For illustrative purposes, where the User/ Member withdraws his consent for the use of his Personal Data for marketing or promotional purposes under the Law no. 6563 on Regulation of Electronic Commerce and regulations adopted thereunder, his Personal Data records shall be kept for 1 year from that date. Contents of commercial electronic message and all other records related to that message shall be stored for three years to be submitted to the relevant Ministry if required. Traffic data processed by us shall be kept for 2 years and anonymized thereafter pursuant to the Law no. 5651 on the Regulation of Internet Broadcasts and Combat against the Crimes committed via these Broadcasts.

In any event, where Personal Data are processed for multiple reasons, whenever all reasons necessitating the processing of said data are no longer applicable, these data are erased, destroyed or anonymized.

Use of Cookies

Our Company may process browsing data of Users/Members subject to its statutory obligations and to offer better services to Web Site visitors, provided that such date shall not be used beyond such purposes and scope defined in the “Policy for Confidentiality, Protection of Personal Data and Cookies”.
Cookies are text files with tiny data fragments which are downloaded by the Internet browser of the User/ Member and embedded in his computer, mobile phone or tablet PC whenever the User/ Member visits the said Web Site.

Our Company shall store disclose such data that it collects by means of cookies and log files and empty GIF files and/ or third parties available at the said Web Site in order to create a summary about the preferences of the User/ Member, and may disclose such data to third parties in line with that purpose. Our Company may track the User’s/ Member’s browsing data in the said channels and/ or his usage history there in order to send customized promotional messages and to offer promotions and marketing offers to the said User/ Member over the said Web Site and to improve the contents of the said channel according to, and/ or know about, the User/ Member preferences. In addition, we may match such data collected from the User/ Member over these channels by means of different methods or at different times, including the data collected online and offline, and we may use such data in conjunction with data from other sources, including third parties. The said matching and use shall be strictly subject to such purposes and scope defined herein, and may be disclosed third parties in line with these purposes.

Cookie Types

Our Company uses session cookies and permanent cookies at its Web Site. Session cookies shall expire when the User/ Member logs out his browser. A permanent cookie shall remain at the User’s/ Member’s hard disc for a long time. The User/ Member may remove permanent cookies and may reject both session cookies and permanent cookies by following up instructions set out in the “help” files of his Internet browser or by visiting “www.allaboutcookies.org” or “www.youronlinechoices.eu“. In the case that the User/ Member rejects permanent cookies or session cookies, he may continue to use the web site in question but he may not have access, or may have limited access to, all functions of these channels.

1. In what way are cookies used?

1.1. Cookies shall be used to remember the User/ Member preferences and to customize the use of the web site. Such usage shall be applicable for:
1.1.1. cookies that record the User’s/ Member’s password and this way allows the permanent log-in with the Web Site so that the User/ Member will be saved from typing his password in his every single visit to the Site;
1.1.2. Cookies that remember and recognize the User/ Member in his next visit to the web site.
1.2. They are used to identify how the Member/ User uses the Wes Site, including tracking his use of the Web site, such as the location from where the User/ Member is connected to the said Web Site, the contents that he views on the Web Site, and the duration of his visit.
1.3. They are used to offer such contents and advertisements that better suit the User/ Member and his areas of interest; in other words, they are used for targeted advertisement/ promotion purposes. This way, when the User/ Member uses the Web Site, he will be offered such contents and customized special campaigns and products that are more suitable for him, and he shall be spared of such contents and advantages that he does not wish to see as per his previous preferences. The Web Site will match data that we collect via cookies with the Personal Data.

2. In what way does the said Web Site use third party cookies for advertising and re-targeting purposes?

The said Web Site may also use cookies in order to trigger the “advertising technology” in order to offer to the User/ Member such advertisements that the Web Site considers to be of interest to the User/ Member whenever such User/ Member visits the web sites on which the said Web Site places ads. Advertising technology shall use data about the past visits of the User/ Member to the said Web Site and such web sites on which it places ads in order to offer customized ads for the User/ Member. While these ads are offered, a unique third party cookie may be embedded in the User’s/ Member’s browsers to allow the Web Site to identify the User/ Member. The User/ Member may remove permanent cookies and reject both session cookies and permanent cookies by following the instructions given in the Web Browser’s “Help” file or by visiting “www.allaboutcookies.org” or “www.youronlinechoices.eu“. In the case that the User/ Member rejects permanent cookies or session cookies, he may continue to use the web site in question but he may not have access, or may have limited access to, all functions of these channels.

Measures for the Protection of Personal Data

Protection of personal data matters for our Company. We adopt all kinds of necessary technical and administrative measures to protect the User/ Member against the unauthorized access to Personal Data or the loss, incorrect use, disclosure, modification or destruction of these Data. We employ generally accepted security technology standards when we process Personal Data.

We hereby undertake to take all kinds of necessary technical and administrative measures and to show utmost care and diligence to keep Personal Data confidential, to maintain such confidentiality and to ensure their security. Where Personal Data are damaged or intercepted by third parties as a result of attacks to our Company’s web site and system, we shall promptly take necessary measures and report this attack to you and Personal Data Protection Committee.

Amendments to the Confidentiality and Personal Data Protection Policy as well as the Cookies Policy

This Policy for Confidentiality and Personal Data Protection and Cookies may be amended from time to time. These amendments shall be immediately valid and applicable upon the publication of the new and amended Policy for Confidentiality and Personal Data Protection and Cookies at the Web Site.

Therefore we recommend that the User/ Member should check this document periodically. The User/ Member may send his membership details and communication data containing his Personal Data, if any, to our Company by using the contact details at the Web Site at all times. Requests shall be considered and processed as soon as possible.