Cookkie Policy

PURPOSE AND SCOPE

This Cookie Notice aims to set out the procedures and principles concerning the general definitions and types of cookie data relating to visitors and the processing and management of cookie data on the website of KURTSAN İLAÇLARI ANONİM ŞİRKETİ (hereinafter referred to as KURTSAN or the “Company”), taking into consideration the provisions of Personal Data Protection Law No. 6698 and the “GUIDELINES ON COOKIE PRACTICES” published by the Personal Data Protection Board.

This notice covers the processing of personal data through cookies; cookies that are not used in the processing of personal data fall outside its scope. It shall apply to desktop and mobile websites or web applications operated by the Company.

We may update this notice when necessary; therefore, please ensure that you access the current notice on the date on which you use our web and mobile services.

DEFINITION OF COOKIES

A cookie is a type of text file placed on a user’s device by website operators and transmitted as part of an HTTP(S)3 (Hypertext Transfer Protocol) request; cookies are small, rich-text-format text files that allow certain information concerning users to be stored on users’ terminal devices when an internet page is visited.

TYPES OF COOKIES

Cookies are classified by duration, purpose of use, and party. The types of cookies and their descriptions are as follows.

Cookies by Duration

Session Cookies

A session cookie, also called a temporary cookie, is used to maintain continuity of the session. Session cookies are deleted when the user closes the internet browser.

Persistent Cookies

A persistent cookie, which is not deleted when the internet browser is closed, is automatically deleted on a specified date or after a specified period. Through this cookie, the user’s processed data are transmitted to the server each time the user visits a website. For this reason, persistent cookies are sometimes also called tracking cookies. For example, advertisers may record and use information about a user’s internet browsing habits over a long period. They may also be used so that users do not have to re-enter their login details each time they sign in to their accounts on websites.

Cookies by Purpose of Use

Strictly Necessary Cookies (Essential Cookies)

These cookies are necessary for the website to operate. Such cookies are used because they are essential for providing an information society service requested by the user (such as logging in, completing a form, or remembering privacy preferences).

Cookies used for the purposes covered by Criteria A and B addressed in Article 5 of this notice may be cited as examples of strictly necessary cookies. They may generally be regarded as types of cookies for which processing conditions other than explicit consent are relied upon. If essential cookies are blocked, certain parts of the website will not function, and these cookies must not be used for marketing purposes.

Functional Cookies

These are cookies used on websites or in applications (including applications on desktop, mobile, or IoT devices) for personalization and for remembering preferences. These cookies are used to provide functionalities other than those provided by essential cookies. Where it is not evident that the data subject has expressly requested an information society service, explicit consent will be required.

Performance and Analytics Cookies

These are cookies that enable statistical measurement for the purpose of analyzing users’ behavior on websites. These cookies are frequently used to improve the website, including to measure the effect of advertisements on data subjects. Website owners use them to estimate the number of unique visitors, identify the most important search-engine keywords leading to a webpage, or monitor navigation on the website.

Advertising and Marketing Cookies

Advertising and marketing cookies are intended to track users’ online activities, identify their personal interests, and display online advertisements to users based on those interests. Although many types of online advertising exist, the principal reason why online behavioral advertising is the most commonly preferred type is that advertisements can be tailored to individuals’ tendencies and preferences and that time and financial resources can be used more efficiently by the advertiser. Online behavioral advertising practices consist of monitoring individuals’ online activities, analyzing and profiling those activities, matching the profiled person with appropriate advertisements, and displaying those advertisements to the relevant person.

Cookies by Party

Whether a cookie is a first-party or third-party cookie varies according to the website or domain that places the cookie.

First-party cookies are placed directly by the webpage visited by the user, namely the URL displayed in the browser’s address bar (example.com.tr).

Third-party cookies are placed by a third party other than the website (or domain) visited by the user.

Conditions for Processing Personal Data Through Cookies

As a result of either “the existence of explicit consent” or “the assessment to be made by the data controller specifically in relation to the personal-data processing activity conducted through cookies,” the Company also takes into consideration the other data-processing conditions listed in Articles 5 and/or 6 of the Law.

In applying the processing conditions under Articles 5 and/or 6, where the processing of personal data is based on one of the conditions in the Law other than explicit consent, there is no need to obtain the data subject’s explicit consent. The Company first assesses whether the purpose of the personal-data processing activity may be based on any other processing condition besides explicit consent; if that purpose does not satisfy any of the other conditions set out in the Law, the data-processing activity is then based on the data subject’s explicit consent.

For cookies used on our website other than essential cookies, users’ explicit consent is obtained and users are given the opportunity to change their consent at any time. Through the cookie management panel, users can view the types of cookies used on our website and set their preferences to “on” or “off” for all cookies other than Essential Cookies. If you do not approve the use of cookies through this panel, we ask that you save your preferences using the cookie preferences available on the website or change your cookie preferences through your browser. We would like to remind you that certain features of the website may lose functionality if cookies are not permitted.

For essential cookies, data are processed on the legal grounds set out in Article 5/2 of the Personal Data Protection Law, namely that “processing is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not prejudiced,” and that “processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract.”

Use of Cookies Based on Explicit Consent

Examples of cookie-use scenarios that do not fall within the scope of the essential cookies described above include:

Social Plug-in Tracking Cookies

Many social networks offer social plug-in modules that website owners can integrate into their websites in order to provide certain services that may be regarded as having been “expressly requested” by their members. However, these modules may be used to track members and non-members with the aid of third-party cookies for additional purposes such as behavioral advertising, analytics, or market research. Because, for such purposes, these cookies cannot be regarded as “strictly necessary” to provide functionality expressly requested by the user, such tracking cookies do not fall within the scope of essential cookies. Without explicit consent, social networks are unlikely to have any legal basis for collecting data through social plug-ins about persons who are not members of their networks. By default, social plug-ins do not place third-party cookies on pages displayed to non-members.

Online Behavioral Advertising Cookies

Cookies used for behavioral advertising require explicit consent. In this case, the explicit-consent requirement naturally covers the relevant cookies used for advertising purposes, including cookies used for frequency capping, financial record-keeping, advertising partnerships, click-fraud detection, research and market analysis, product development, and debugging, because none of these purposes is clearly connected with a service or functionality within the scope of information society services expressly requested by the user, as required for essential cookies.

Use of Cookies Under Processing Conditions Other Than Explicit Consent

The Company explains below the purposes of example cookies that, within their use scenarios, may rely on personal-data processing conditions other than explicit consent.

Load-Balancing Session Cookies (Criterion A)

Load balancing is a technique that enables web-server requests to be distributed across a pool of machines instead of a single machine. Accordingly, web requests from users are directed to a load-balancing gateway, and the request is forwarded to an available internal server in the pool. In this case, that redirection must persist throughout the session, and all requests from a specific user are always directed to the same server in the pool in order to ensure consistency of the process. These are session cookies, and the sole purpose of the information held in the cookie is to identify the communication endpoint (one of the servers in the pool). The cookie is necessary for communication over the network and does not require explicit consent under Criterion A.

Cookies Used for Website Security (Criterion B)

Because the website’s inability to provide service or its being taken out of service due to a security vulnerability would prevent the user from accessing the requested service, cookies used for website security are also considered strictly necessary for the service requested by the user. For example, a cookie used by a web application firewall to identify the user and limit the number of user requests per session may be regarded as strictly necessary for site security, for ensuring the user’s access to the service, and therefore for a service requested by the user under Criterion B. For cookies serving this purpose, the Company may rely on other processing conditions besides explicit consent, for example, the condition that “processing is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not prejudiced.”

WHICH COOKIES DO WE USE

Detailed information on the types of cookies used on our website and how those cookies are used is provided below.

Essential Cookies

They are used because they are essential for our website to operate properly and to provide you with an information society service that you have requested. These cookies are processed on the basis of the processing condition under Article 5, paragraph 2(f), of Personal Data Protection Law No. 6698: “processing is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not prejudiced.”

Functional Cookies

If you give explicit consent, these cookies are used on websites or in applications (including applications on desktop, mobile, or IoT devices) for personalization and for remembering preferences. In addition, if you consent to the use and processing of functional cookies, your personal data will be transferred to our service providers located abroad.

Performance Cookies

If you give explicit consent, cookies that enable statistical measurement for the purpose of analyzing users’ behavior on the website may be processed. These cookies are frequently used to improve the website, including to measure the effect of advertisements on data subjects. In addition, if you consent to the use and processing of performance cookies, your personal data will be transferred to our service providers located abroad.

COOKIE WALLS

Cookie walls are practices that prevent a visitor from viewing website content unless the visitor consents to the use of all cookies on the website. Our Company avoids the use of cookie walls that impede compliance with the law and the legal conditions for explicit consent.

RESPONSIBILITY OF THE PARTIES

Where our Company places third-party cookies on the webpage, both the Company, as the data controller, and the third party are obliged to ensure that users are clearly informed about the cookies and that their consent is obtained.

TRANSFER OF PERSONAL DATA

Your personal data may be transferred, in accordance with the data-transfer conditions set out in Article 8 of Personal Data Protection Law No. 6698, to domestic suppliers from which services are obtained for the purposes of ensuring commercial security, securely storing your personal data, and providing electronic or physical data storage, backup services, or systems.

COOKIE SETTINGS THROUGH BROWSER SETTINGS

You may change your cookie preferences at any time through the cookie settings on our website. Set the buttons in the cookie management panel to on or off according to your preference and click the “Save settings” button. Refresh the page to activate your settings. However, essential cookies are cookies that must be processed for our website to operate.

In addition, you may access information on managing cookies in commonly used browsers through the links below:

OUR DETAILS AND CONTACT INFORMATION

If, as a data subject, you submit your requests concerning your rights to the Company in writing pursuant to Article 13(1) of the Personal Data Protection Law or by the methods specified in the Communiqué on the Procedures and Principles of Application to the Data Controller (https://www.resmigazete.gov.tr/eskiler/2018/03/20180310-6.htm), our Company will conclude the request free of charge as soon as possible and no later than thirty days, depending on the nature of the request. However, if the transaction entails an additional cost, the Company will charge the fee set out in the tariff determined by the Personal Data Protection Authority.

KURTSAN İLAÇLARI ANONİM ŞİRKETİ

Address: Merkez Mah. Bağlar Cad. No: 14c Interior Door No: 4 Kağıthane / Istanbul

Email: kurtsan@kurtsan.com