Data Controller


www.livioferri.com.tr


We value the protection of your personal data. In accordance with the Personal Data Protection Law ("KVKK"), we would like to inform you about the collection, storage, processing, and transfer of data obtained in connection with the use of the "Company Website" and the purpose of such processing.


Processing and Transfer of Personal Data


The COMPANY requests certain personal data from customers who use the Company Website during the membership process or while using the Company Website. Personal data is any information that identifies or can identify a person. Such information may include your name, address, email address, or phone number. Information collected through cookies, which does not directly allow identification of your identity, such as how you use the Company Website, may also be considered personal data if it is collected, stored, and evaluated on an individualized basis and therefore personalized. Non-personal data is information that has been aggregated, summarized, collected, evaluated, and anonymized and cannot be associated with a real person.


Our company collects the aforementioned personal data of individuals, which are filled out by the Data Subject in the demo request form, contact form, e-newsletter form, support system, call center, and membership form, by the nature of the job. To identify system-related issues and rapidly resolve any problems or disputes that may arise regarding the service provided, our company records and uses the IP addresses of its members. IP addresses may be used to identify users in general and to collect comprehensive demographic information.


Our company may use the requested information for purposes other than those specified in the Membership Agreement, including direct marketing by itself or by persons with whom it cooperates. Personal information may also be used to contact the user if necessary. Information requested by our company or provided by the user or information related to transactions made through the Company Website may be used by our company and persons with whom it cooperates for various statistical evaluations, database creation, and market research purposes, without disclosing the identity of our members.


At certain times, our company may send campaign information, information about new packages, promotional offers, and similar notifications to its customers and members. Our members can choose whether to receive such information when they sign up, can change this choice from the management panel after logging in, or can notify via the link in the notification message received.


Purposes of Processing Personal Data


Our company processes Personal Data for specific, explicit, and legitimate purposes. In this context, Personal Data may be processed for the following purposes:


• Provision and modification of services provided through the website,

• Customization of offered products and services according to requests; updating, developing, and improving products and services according to customer needs, legal, and technical developments,

• Making user identifications for the systems offered within the scope of offered products and services,

• Announcing new or existing products, services, and campaigns, conducting sales and marketing activities,

• Conducting market research,

• Creating statistics and analyzing usage,

• Payment and collection of product, service, and service fees, selecting the collection method,

• Fulfillment of the obligation to inform arising from the Law No. 6563 on the Regulation of Electronic Commerce and other relevant legislation,

• Transmission of advertisements of products and services in line with the purpose of processing Personal Data, informing about products, services, promotions, and campaigns,

• Resolution of problems encountered during website usage,

• Improving website usage, interactions, transitions between pages, and purchasing experiences, providing better quality service,

• Establishing contact/communication,

• Conducting commercial relationships with companies, suppliers, resellers, and service providers,

• Reporting within the scope of cooperation,

• Developing the company's commercial strategies and plans,

• Contacting for satisfaction measurement surveys organized by the COMPANY,

• Creating participant records, preparing certificates/participation documents, determining prize/winners, and delivering prizes/gifts at events/training/competitions organized by the COMPANY,

• Management of judicial/administrative processes, responding to requests from public institutions,

• Fulfillment of legal obligations in accordance with legal regulations, resolution of legal disputes,

• Conducting investor relations,

• Ensuring the consequences of legal transactions resulting from the merger, division, or transfer of all or part of the COMPANY,

• Introduction of COMPANY employees, Real Person Customers, and Stakeholders in social media shares,

• Conducting job interviews, evaluating job applications,

• Establishment, execution, and termination of the business relationship/contract,

• Enabling COMPANY employees to benefit from the main and ancillary rights arising from the employment contracts, evaluating their performance and work,

• Opening a user account for employees,

• Creating participant records for participation in an organization on behalf of the company,

• Creating participation and certificate records for employees,

• Ensuring the security of the Company Website and Applications,

• Website usage analysis,

• Creation of a personal data inventory,

• Evaluation and response to all questions, requests, suggestions, complaints, and applications conveyed in written, verbal, or electronic form regarding personal data, including personal data, which is transmitted in writing, verbally, or electronically.


Method of Collecting Personal Data and Legal Basis


Data on current and potential Company Website users are collected, partially or completely, through automatic or non-automatic means in accordance with contractual or other reasons determined by legislation as part of our business.


Açık Rıza Olmaksızın İşlenen Kişisel Veriler


In accordance with the Personal Data Protection Law ("KVKK"), we inform you that we may process and share your personal information publicly shared by you without your explicit consent under certain circumstances:


If there are provisions in the legislation explicitly allowing the processing of your personal data without explicit consent, we may process and share your personal data with third parties.

If there is a legal obligation to disclose information, including personal data, arising from current laws or regulations or a court order or administrative order, we may process your personal data without your explicit consent.

If processing of data is necessary for the establishment, exercise, or protection of a right, we may process your personal data without your explicit consent.


Data Transferred to Third Parties


In the scope of commercial activities on the Company Website, we may share your personal data with Company employees, company officials, legal, financial, and tax advisors, auditors, cloud companies located abroad, primarily in the United States and European countries, such as IBM Softlayer Data Center, Amazon Web Services, Inc. (AWS), consultants and contracted organizations, educational institutions, advertising and marketing agencies the Company works with, and individuals or legal entities for presenting advertisements that may interest the Data Subject. By agreeing to this sharing, you consent to the Data Controller.


Network Server Data Logs


When you access the Company Website, your web browser is technically configured to automatically transmit the following data ("data logs") to our internet server, and we record the following information in data logs even if you do not give your consent:

Date of access

Time of access

URL of the requesting website

Files accessed

Amount of data transmitted

Type and version of browser

Operating system

IP address

Domain name of your internet access provider

This information is necessary for delivering the content requested by you correctly and is collected as an inevitable aspect of using internet websites. Data logs are only analyzed for statistical purposes for the improvement of our website and underlying technology and are subsequently deleted.

Data logs are stored separately from other data collected as part of your use of the Company Website.


Cookies


Like many other websites, we also use "cookies". Cookies are small text files transmitted by a web page server to your hard drive. In this way, we automatically obtain certain data such as IP address, browser used, operating system on your computer, and internet connection. The technical communication file mentioned stores information about the status and preferences of the site to facilitate the use of the Internet. The technical communication file is not designed to receive data or personal information from your main memory or email. Additionally, cookies cannot be used to run programs or send viruses to your computer.


We use cookies and similar technologies to recognize you in different services, obtain information about your interests within and outside our services, improve your experience, enhance security, measure the usage and effectiveness of our services, obtain statistical information about how many people visit the site and how long they stay on the site, and help generate dynamic advertising and content from user-specific pages. We may track your browsing on the Company Website and your transactions in your membership account through cookies to offer different discounts and campaign offers, advertise and promote, personalize the Company Website for you, and provide a personalized Company.com experience. We may also analyze the personal data collected through various methods on the Company Website or third-party sites and mobile applications together.


Under no circumstances will the data we collect be shared with third parties without your consent. Of course, you can always view our website without cookies. Internet browsers are always set to accept cookies. You can control and stop cookies through browser settings and other tools. Please note that certain features of our website may not work properly when you disable the use of cookies.


Use of Social Plugins in the Context of Social Media


The COMPANY uses social plugins ("plugins") from social networks operated by Facebook Inc., Palo Alto, CA, USA, YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066 USA, Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 USA, Instagram, LLC, Arbitration Opt-out 1601 Willow Rd. Menlo Park, CA 94025 USA.


If you visit a page on our website containing such plugins, they are initially inactive. Plugins cannot become active until you click the specified button. By activating the plugins, you establish a connection with these social networks and consent to data transfer. If your sessions are open in these social networks, they can associate this visit with your account on the respective social network. When you click the relevant button, the corresponding information is transferred directly to the relevant social network by your browser and stored there.


For information on the scope and purpose of data collection, processing, and use by the relevant social networks, and the rights you can exercise to protect your rights and privacy, please refer to the Data Protection Notices of the respective social networks. If you do not want these social networks to collect data about you through our website, you must close your sessions on the relevant social networks before visiting our site.


Kişisel Verilerinize İlişkin Haklarınız


According to the legislation regarding your processed personal data, you have the following rights:


1. Learning whether your personal data is being processed,

2. Requesting information if your personal data has been processed,

3. Learning the purpose of processing personal data and whether they are used for their purpose,

4. Knowing the third parties to whom personal data are transferred, domestically or abroad,

5. Requesting correction of personal data if it is incomplete or incorrect,

6. Requesting the deletion or destruction of personal data,

7. Requesting notification to third parties to whom personal data have been transferred regarding correction or deletion of personal data, if personal data are processed incompletely or incorrectly,

8. Objecting to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems,

9. Demanding compensation for damages in case of suffering damage due to the unlawful processing of personal data.


Use of Rights, Application, and Contact


You can submit your requests regarding the aforementioned rights under the KVKK to the COMPANY in writing, personally or in compliance with the legislation (e.g., via a notary) with the requirement of verifying your identity, to the address specified above.


Data Security


To the extent possible, the COMPANY has taken technical and administrative measures for data security within the scope of the KVKK. Information about the measures taken is detailed under the heading Personal Data Protection, Storage, Processing, and Destruction Policy.


Data Belonging to Minors


Personal data of minors should not be sent without the permission of their parent or legal guardian.


Links to Other Internet Sites


The Company Website contains links to other internet sites. We have no influence on whether the operators of these sites act in compliance with data protection provisions. The COMPANY is not responsible for the contents of the sites to which it provides links (and the contents of other sites linked to those sites), and we do not have the authority to intervene in the contents of the sites to which we provide links.


Changes in the Data Privacy Statement and Information on the Protection and Processing of Personal Data Policy


This "Data Privacy Statement and Information on the Protection and Processing of Personal Data Policy" will be amended as necessary to announce changes in our data protection-related services, such as the provision of new services and compliance with current legal requirements.


User Access


No one is granted access to your account unless invited by you. Only authorized COMPANY personnel, upon your permission, may access your data for support purposes in case of technical or systemic malfunctions.


Data Sharing


Data transfer is not shared with our business partners without your consent and without adequate security measures.


Data Backup


Your data is backed up daily against possible technical problems.


Intervention in Security Breaches


Despite our best efforts, no transmission method over the Internet and no electronic storage method is entirely secure. We cannot guarantee absolute security. However, if the COMPANY becomes aware of a security breach, we will notify affected users so that they can take appropriate protective measures. Our breach notification procedures are consistent with our obligations under legislation regulations and all industry rules or standards to which we comply. The notification procedures include providing email notifications or publishing notifications on our website if a breach occurs on our website.


Your Responsibilities


Keeping your data safe also depends on you ensuring the security of your account by using sufficiently complex passwords and storing them securely. You must ensure that the computer, tablet, or phone you use to access the COMPANY service is secure enough.