As Zorlu Yapı Yatırım Anonim Şirketi (“the Company“), we make use of certain technologies such as cookies, pixels, GIFs, etc. (“Cookies”) to improve your experience during your use or visit of our websites (“Website”), applications or all of our similar online or offline channels (all these channels will be collectively referred to as “Platform”). This text has been prepared within the scope of Article 10 of the Law No. 6698 on the Protection of Personal Data (Law) and the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Disclosure Obligation.
The use of these technologies is performed per the legislation we are subject to, especially the Law on the Protection of Personal Data No. 6698 (“Law”).
With this Cookie Disclosure Policy, it is explained to you for what purposes the Cookies collected during the use of the Platforms are used and how you can control these Cookies, concerning the processing of personal data obtained automatically through the placement of cookies used on our website on your device.
We may stop using the Cookies on our website and applications, change their types or functions, or add new Cookies to our website and applications. Therefore, we reserve the right to change the provisions of this Cookie Policy at any time. Any changes made on the current Cookie Policy will become effective after being published on the website, applications or any public channels. You may find the last update date at the end of the text.
Methods and Legal Reasons of, Collecting Cookies; Transfer of Personal Data
Mandatory cookies are used to fulfill an information society service (logging in, filling out forms and remembering privacy preferences, counting visitors on our website, and measuring traffic) you have requested. Your personal data collected through these cookies are processed within the scope of Article 5(2)(c) “The processing of personal data belonging to the parties to the contract is necessary, provided that it is directly related to the establishment or performance of a contract” or (f) clause “Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject” of the Law.
Advertising and Marketing cookies are used by our business partners to profile your interests and to show you relevant advertisements. Your personal data collected through these cookies are processed by obtaining your explicit consent within the scope of paragraph 5(1) of the Law.
İnternet sitemizde kullandığımız, zorunlu çerezler haricindeki çerezler için, kullanıcıların açık rızaları alınmakta ve istedikleri zaman rızalarını değiştirebilme olanağı sağlanmaktadır. Kullanıcılar çerezleri yönet bölümünden, internet sitemizde kullanılan çerez çeşitlerini görebilmekte ve Zorunlu Çerezler dışında kalan tüm çerezler için “açık” veya “kapalı” seçenekleri ile tercihlerini belirleyebilmektedirler. Yine bu panel üzerinden kullanıcılar tercihlerini her zaman değiştirebilmektedirler.
For cookies other than mandatory cookies that we use on our website, the explicit consent of the users is obtained and the opportunity to change their consent at any time is provided. From the manage cookies section, users can see the types of cookies used on our website and can set their preferences with the “on” or “off” options for all cookies other than Mandatory Cookies. Again, users can change their preferences at any time through this panel.
You can always manage the use of Cookies in the Manage Cookies section.
Your collected personal data may be shared with our suppliers per the legislation and limited to the realization of the purposes specified in this Cookie Policy.
Types of Cookies by Duration
1. Session Cookies; These Cookies are temporary cookies that disappear with the closing of the browser or the termination of the session.
2. Persistent Cookies;These Cookies remain on your hard drive until you delete them or until your browser automatically deletes them depending on the day of disappearance. The expiration dates of persistent cookies are predetermined even if they vary.
Types of Cookies by Provenance
1. First-Party Cookies; as the name suggests, first-party Cookies are Cookies placed on your device by our Platforms. First-party cookies are placed directly by the website the user is visiting, i.e. the URL (ornek.com.tr) shown in the address bar of the browser.
2. Third-Party Cookies; These Cookies are the Cookies that are placed on your device by third parties that advertise or perform analytical systems, not by our Platforms you visit. Third-party cookies are placed by a domain other than the one the user is visiting.
Cookies and Purposes of Use
1. Mandatory Cookies: Mandatory Cookies are the Cookies that are necessary for the performance of the main functions of our website, and are the Cookies that provide security, network management and access to our website. Mandatory cookies are first-party cookies and process personal data during the session (excluding cookies about your privacy preferences, as these cookies last longer than the session duration), and are automatically deleted when the session ends. These cookies are used as mandatory to fulfill an information society service (remembering log-in, form-filling, and privacy preferences) that you have requested. In addition, the cookie for performance and analytical purposes allows the counting of visitors to our website and the measurement of traffic and is the first party. In this way, we can measure and improve the performance of our site. These cookies help us to understand which pages on our website are the most popular and which are the least popular.
2. Functional/Preference Cookies; Preference Cookies, also known as functionality Cookies, are the Cookies that allow your past preferences to be remembered, such as the language used or preferred region of the website, or an automatic login user name and password. Such cookies are used to make our website more functional and personalized (to ensure that your other preferences, except for your privacy preferences, are remembered when you re-enter the site).
3.Performance/Analytics Cookies; these cookies are often used to improve the site, including measuring the impact of advertising on the people concerned. They are used by website owners to estimate the number of unique visitors, identify the most important search engine keywords that lead to a web page, or track website navigation.
4. Advertising/Marketing Cookies; these Cookies are Cookies that enable personalized advertisements by tracking the online behavior of users. These Cookies may also share the information they collect with other third-party advertisers. These cookies are cookies placed by our advertising partners through our website and are third-party cookies. These cookies are used by our business partners to profile your interests and to show you relevant advertisements.
Cookies Used on Our Platforms
Functionality and Preference Cookies
These Cookies remember your preferences and choices on the site and application and enable the services offered on our site to personalize for you. For example, it allows us to remember your language selection on our site or the font size you have selected when reading a text.
| Cookies | Explanation | Party Information | Duraton |
| pll_language | Language selection cookies. | 1. Aspect | 1 year |
| SIDDCC | Security cookie to verify the authenticity of the visitor, prevent fraudulent use of login data, and protect visitor data from unauthorized access. | 1. Aspect | 1 year |
| SID | Security cookie to verify the authenticity of the visitor, prevent fraudulent use of login data, and protect visitor data from unauthorized access. | 1. Aspect | 2 years |
| HSID | Security cookie to verify the authenticity of the visitor, prevent fraudulent use of login data, and protect visitor data from unauthorized access. | 1. Aspect | 2 years |
Performance and Analytics Cookies
Thanks to these Cookies, we can improve your use of our website and application and the services we provide to you by analyzing performance. For example, thanks to these Cookies, we can identify which pages our visitors view the most, whether our website is working properly, and any possible problems.
| Cookie | Explanation | Party Information | Duraton |
| _gcl_au | This cookie is used by Google Analytics to understand user interaction with the website. | 1. Aspect | 3 months |
| NID | It stores visitors’ preferences and personalizes ads on Google websites based on: recent searches and interactions | 3. Aspect | 6 months |
| __Secure-
3PAPISID |
It creates a profile of website visitors’ interests through retargeting to show relevant and personalized ads. | 3. Aspect | 2 years |
| __Secure-
3PSID |
It creates a profile of website visitors’ interests through retargeting to show relevant and personalized ads. | 3. Aspect | 2 years |
| 1P_JAR | Based on recent searches and previous interactions, tailored ads will show on: Google sites | 3. Aspect | 1 weeks |
| NID | It stores visitors’ preferences and personalizes ads on Google websites based on: recent searches and interactions | 3. Aspect | 6 months |
| _ga | Analytics from Google | 3. Aspect | 2 years |
| SAPISID | Google collects visitor information for Youtube hosted videos | 3. Aspect | 2 years |
| SSID | Google collects visitor information for Youtube hosted videos in integrated maps – with Google map. | 3. Aspect | 2 years |
Targeting or advertising cookies
We use Cookies to promote products and services to you on our site or in channels other than our site. In addition, we may cooperate with some of our business partners to advertise and promote you within or outside of our site. For example, cookies can be used to track whether you click on an ad you see on our site, and if you benefit from the service on the site to which the ad is directed after the ad has attracted your attention.
| Cookie | Explanation | Party Information | Duration |
| OTZ | It links the activities of website visitors to other devices that have previously logged into their Google account. This way, ads are tailored to different devices. | 3. Aspect | 6 months |
| DSID | This cookie is set by http://doubleclick.net/. The purpose of the cookie is to determine whether the user’s browser supports cookies or not. | 3. Aspect | 6 months |
| IDE | This cookie is set by http://doubleclick.net/. The purpose of the cookie is to determine whether the user’s browser supports cookies or not. | 3. Aspect | 2 years |
| RUL | This cookie is set by http://doubleclick.net/. The purpose of the cookie is to determine whether the user’s browser supports cookies or not. | 3. Aspect | 1 year |
| __Secure-1PAPISID | It creates a profile of website visitors’ interests through retargeting to show relevant and personalized ads. | 3. Aspect | 2 years |
| __Secure-
1PSID |
It creates a profile of website visitors’ interests through retargeting to show relevant and personalized ads. | 3. Aspect | 2 years |
| __Secure-3PSIDCC | It creates a profile of website visitors’ interests through retargeting to show relevant and personalized ads. | 3. Aspect | 1 year |
| APISID | It personalizes Google ads on websites based on recent searches and interactions. | 3. Aspect | 2 years |
How Can I Control the Use of Cookies?
The preferences of our visitors and users regarding the use of cookies and similar technologies are essential for us. However, certain Cookies, which are mandatory for the Platform to work, must be used. In addition, we would like to remind you that some functions of the Platform may not work partially or completely if some Cookies are turned off.
Information on how you can manage your preferences for cookies used on the Platform is as follows:
- Visitors have the opportunity to customize their preferences regarding Cookies by changing the browser settings in which they view the Platform. If the browser in use offers this possibility, it is possible to change the preferences for Cookies through the browser settings. Thus, although it may differ according to the possibilities offered by the browser, data subjects have the opportunity to prevent the use of Cookies, to choose to receive a warning before the use of Cookies, or to disable or delete only some Cookies.
- Although the preferences on this subject vary according to the browser used, it is possible to reach a general explanation at https://www.aboutcookies.org/. Preferences for cookies may need to be made separately for each device from which the visitor accesses the Platform.
- Click to turn off Cookies managed by Google Analytics.
- Click to manage the personalized advertising experience provided by Google.
- Preferences in terms of cookies used by many companies for advertising activities can be managed through Your Online Choice.
- To manage cookies on mobile devices, the settings menu of the mobile device can be used.
- You have the opportunity to customize your preferences regarding cookies by changing the settings of your browser.
What Are Your Rights as a Data Subject?
According to Article 11 of the KVK Law, data subjects are entitled to,
- know whether his/her personal data is processed;
- request information if his/her personal data has been processed;
- know the purpose of processing his/her personal data and whether such data have been used appropriately for their purpose;
- know the third parties to whom his/her personal data have been transferred domestically or abroad,
- request rectification in case his/her personal data have been processed incompletely or inaccurately, to request notification of such activities to any third parties to whom the personal data has been transferred,
- request the deletion or destruction of personal data in the event that the reasons requiring processing thereof have disappeared, although it has been processed in accordance with the provisions of the KVK Law and other relevant laws, and to request notification of such activities to any third parties to whom the personal data has been transferred;
- object to the occurrence of any results against himself / herself through analysis of the processed data exclusively through automated systems;
- demand the compensation of damages and losses suffered due to the unlawful processing of personal data.
You may submit your requests regarding the said rights in writing to the address Levazım Mah. Koru Sok. No:2 PSM/70 34340 Beşiktaş/İstanbul in accordance with the provisions of the Communiqué on Procedures and Principles for Filing Applications to Data Controllers, or to zorluholding@hs03.kep.tr with your secure electronic signature, mobile signature, or via the e-mail address you have previously notified to our Company and registered in our Company’s systems, if any, to kvk@zorlu.com Your applications will be finalized free of charge within thirty days at the latest; however, if the transaction requires an additional cost, you may be charged a fee according to the tariff to be determined by the Personal Data Protection Board.
Date last updated: 17.05.2022
