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Cookie Policy

Policy version: v1.0  |  Effective date: To be updated on the go-live date  |  Review period: At least every 3 months

1. PURPOSE

This Policy explains how personal data obtained through cookies is processed when users, members and visitors (data subjects) use the PhillipCapital Menkul Değerler A.Ş. website (the Site), operated by PHILLIPCAPITAL MENKUL DEĞERLER A.Ş. (the Company).

2. SCOPE

It covers personal data at all Company premises and on its websites.

3. RESPONSIBLE PARTIES

Company employees and suppliers who come into contact with personal data are responsible.

4. IMPLEMENTATION

The information below is published on the Company's website.

About the Cookie Disclosure Text

To improve your experience when visiting our online channels, the Company uses technologies such as cookies, pixels and GIFs (collectively, cookies). These technologies are used in accordance with applicable legislation, particularly Personal Data Protection Law No. 6698.

Cookie Policy

The purpose of the Cookie Disclosure text is to inform you about the processing of personal data obtained through the use of cookies by the users/members/visitors (data subjects) of our website, which is operated by us. In this text, we want to explain to you which types of cookies we use on our site and for what purposes, and how you can control these cookies.

We may stop using cookies on our website, change their types or functions, or add new cookies to our website and mobile applications. We therefore reserve the right to amend this Privacy Notice at any time. Any amendment becomes effective upon publication on the website or another publicly accessible medium. The date of the latest update appears at the beginning of the notice.

For further information about the processing of your personal data by the Company, we recommend reading the Privacy Notice under Personal Data Protection Law No. 6698 available on our website.

You may change your cookie preferences or withdraw your consent at any time. You can open the preferences panel by clicking the cookie icon in the bottom-right corner of the page or by using the button below.

Which Cookies Are Used for Which Purposes?

As PHILLIPCAPITAL MENKUL DEĞERLER A.Ş., we use cookies on our website for various purposes and process your personal data through these cookies. The principal purposes are as follows:

  • Performing the basic functions necessary for the site to work. For example, so that logged-in members do not need to re-enter their password while visiting different pages on the site.
  • Analyzing the site and improving its performance. For example, integrating the different servers on which the site runs, determining the number of visitors to the site and adjusting performance accordingly, or making it easier for visitors to find what they are looking for.
  • Increasing the functionality of the site and providing ease of use. For example, sharing content from the Site to third-party social media channels, or remembering a visitor's username or search queries during their subsequent visit to the site.
  • Carrying out personalization, targeting and advertising activities. For example, displaying advertisements related to visitors' interests based on the pages and products they view. Carrying out device-based targeting in our mobile applications.

As the Company, we process your personal data by automated means on the legal grounds set out below pursuant to Article 5 of the Personal Data Protection Law.

  • With the explicit consent of the data subject,
  • Processing is necessary for the Company to comply with a legal obligation;
  • Where data processing is mandatory for the establishment, exercise or protection of a right,
  • Where data processing is mandatory for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.

In accordance with applicable legislation and solely to achieve the purposes stated above, the Company may share personal data covered by this Privacy Notice with third-party service providers, business partners, public institutions and authorities, and our affiliates.

Cookies Used on Our Site and Mobile Applications

Below you can find the different types of cookies we use on our site. Both first-party cookies (placed by the site you visit) and third-party cookies (placed by servers other than the site you visit and our mobile applications) are used on our site and mobile applications.

1. Necessary Cookies
These cookies are necessary to enable the user to navigate and use specific sections of the site, such as accessing secure areas of a page. Without these cookies, important parts of the website cannot be used.

2. Functionality and Preference Cookies
These cookies collect information about user behavior. All information is collected anonymously, and functionality cookies cannot track the user's activities on other websites. This information is used to compile reports for the improvement of the website. Functionality cookies may also include those that provide the service requested by the user.

3. Social Media Cookies
These cookies enable the collection of information about your social media usage. For example, cookies may be used to utilize information from your social media accounts, such as Facebook/Twitter, in order to create personalized advertisements or conduct market research.

4. Performance and Analytics Cookies
These cookies allow the website to remember user preferences, such as language settings, providing the user with an improved, more personalized experience.

5. Targeting or Advertising Cookies
These cookies are used to display advertisements appropriate to the user and their interests. These cookies can also be used to measure the effectiveness of an advertising campaign that the user interacted with while visiting certain web pages, and to enable communication with potential advertisers.

Cookie Inventory

The table below lists the cookies and similar technologies used on our website. The table is kept consistent with cookie scans performed on the live site and is reviewed at least every three months.

Cookie / Technology Provider Category Objectives Duration Party Legal Basis Cross-Border Transfer
phc_consent PhillipCapital Strictly Necessary Stores your cookie preferences, the policy version and the time of your choice. 180 days First party Compliance with a legal obligation (keeping a record of consent) None
cf_clearance, __cf_bm Cloudflare (Turnstile) Strictly Necessary Bot protection and security verification for form submissions. 30 minutes – 1 year Third party Legitimate interest / application security Yes – Under review
_ga, _ga_* Google (Analytics 4) Analytics / Performance Distinguishing visitors and sessions and measuring site usage. 2 years Third party Explicit consent Yes – Under review
_gid Google (Analytics 4) Analytics / Performance Distinguishing visitors. 24 hours Third party Explicit consent Yes – Under review
Collate Labs tracking script Collate Labs Analytics / Performance Measuring site usage. Under review Third party Explicit consent Under review
_gcl_au Google (Ads) Marketing / Targeting Measuring advertising performance and tracking conversions. 90 days Third party Explicit consent Yes – Under review
_fbp Meta (Facebook Pixel) Marketing / Targeting Distinguishing the visitor, measuring ad conversions and remarketing. 90 days First party (transferred to Meta) Explicit consent Yes – Under review
_fbc Meta (Facebook Pixel) Marketing / Targeting Storing ad click information (fbclid) and matching it with conversions. 90 days First party (transferred to Meta) Explicit consent Yes – Under review
NID Google (Maps) Functional Displaying embedded map content and remembering preferences. 6 months Third party Explicit consent Yes – Under review

The third-party providers listed above are based outside Türkiye. These cookies are activated only if you give explicit consent to the relevant category. For rows where the transfer information is marked "Under review", the assessment of the provider and the legal basis for the transfer is ongoing.

Our website also uses static content delivery networks that do not use cookies or similar tracking technologies: cdnjs.cloudflare.com (icon and script libraries) and flagcdn.com (country flag images). These services do not place cookies on your device; however, your IP address and browser information are transmitted to providers based abroad when the content is loaded. These requests are necessary for the website to be displayed and are therefore not subject to consent.

What Are Your Rights as a Data Subject?

Data subjects have the following rights regarding their personal data under the relevant articles of the KVKK;

  • To learn whether personal data is being processed,
  • To request information if personal data has been processed,
  • To learn the purpose of processing personal data and whether it is used in accordance with that purpose,
  • To know the third parties to whom personal data is transferred, domestically or abroad,
  • To request correction if personal data has been processed incompletely or incorrectly, and to request that this correction be notified to the third parties to whom the personal data has been transferred,
  • To request the deletion or destruction of personal data if the reasons requiring its processing have ceased to exist, even though it was processed in accordance with the KVKK and other relevant legal provisions, and to request that this be notified to the third parties to whom the personal data has been transferred,
  • To object to the emergence of a result against the person themselves due to the exclusive analysis of processed data through automated systems,
  • To request compensation for damages in the event of harm resulting from the unlawful processing of personal data.

If you submit your requests regarding these rights to us through the methods available on our site, your applications will be evaluated and concluded as soon as possible and within 30 (thirty) days at the latest. While it is our principle not to charge any fee for requests, if the process requires an additional cost, a fee may be charged according to the tariff determined by the Personal Data Protection Board. However, if the application results from an error on the part of the company, the fee collected will be refunded to the data subject.

The data subject undertakes that the information covered by this Privacy Notice is complete, accurate and current, and will promptly update it if it changes. The Company accepts no liability where the data subject has failed to provide current information.

As the data subject, you acknowledge that if you make a request that prevents the Company from using any of your personal data, you may not be able to benefit fully from the Site's functionality, and you accept responsibility for any consequences arising in this regard.

5. RELATED DOCUMENTS

Personal Data Protection and Processing Policy

6. DISTRIBUTION

It is shared with Company employees, website visitors and relevant parties.

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