Cookie Policy and Privacy Notice

This policy has been prepared by Figo Ticari Bilgi ve Uygulama Platformu A.Ş. (“Figo” or the “Company”) in its capacity as data controller, in order to inform you in your capacity as data subject in a manner compliant with the legislation, within the scope of Article 10 of the Personal Data Protection Law No. 6698 (Kişisel Verilerin Korunması Kanunu, “KVKK”, the “Law”), the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform (Aydınlatma Yükümlülüğünün Yerine Getirilmesinde Uyulacak Usul ve Esaslar Hakkında Tebliğ), and the Guidelines on Cookie Practices. As the Company, we use first-party and third-party cookies in some of the areas contained in our website at https://figopara.com/ (the “Site”). First-party cookies are placed directly by the web page visited by the user, that is, by the URL shown in the address bar of the browser (ornek.com.tr). Third-party cookies, on the other hand, are placed by a third party different from the website (or the domain) visited by the user.

The purpose of this Privacy Notice is to give you information about which types of cookies we use for which purposes, and about how you can manage these cookies, in relation to the processing of personal data obtained by automated means through the placement on your device of the cookies used on our website. For the cookies other than the mandatory cookies we use on our website, the explicit consent of users is obtained, and users are given the opportunity to change their preferences regarding explicit consent whenever they wish.

By visiting our Site, you accept the placement on your device of the cookies that are necessary for the use of this site. This Cookie Privacy Notice (Çerez Aydınlatma Metni, the “Notice”) is valid for the Site managed by the Company, and cookies will be used in line with the Privacy Policy (Gizlilik Politikası) and in the manner explained in the Notice. If you do not want the Company to place cookies on your device, you may refuse the use of cookies through the settings or options of your browser. In that case, you may not be able to use some areas of our site properly.

Data Controller

Pursuant to the Personal Data Protection Law No. 6698 (the “Law No. 6698”), your personal data is collected and processed within the scope explained below by Figo Ticari Bilgi ve Uygulama Platformu A.Ş. (“Figo” or the “Company”) as data controller.

The purpose of this Cookie Policy (Çerez Politikası) of ours is to give you information about the types of cookies we use in relation to the processing of your personal data in order to improve your experience during your visits to our website and our applications, about the purposes for which those cookies are used, and about the control and management of those cookies.

While we reserve the right to change the provisions of the Cookie Policy at any time, we may also cease using the cookies we use on our Site, change their types or functions, or add new cookies to our Site.

Any change made to the current Cookie Policy will enter into force on the date it is published on our Site. For more detailed information about the processing of your personal data by our Company, we kindly ask you to review, and to inform yourself of, the policies and procedures at the link https://figopara.com/kisisel-verilerin-korunmasi on our website at certain times.

What is a cookie?

A cookie is a type of small-sized text file placed in your browser by the site you visit with your computer or your mobile device. Besides allowing a site to work more efficiently and faster, cookies make it possible to present personalized pages so that you have a visit experience suited to your personal needs. Thanks to cookies, you have a better and personalized customer experience on your next visit. For example, cookies can help remember information about your visit, such as your preferred language and other settings. The use of cookies on our Site is carried out in a manner compliant with the relevant legislation, primarily the Personal Data Protection Law No. 6698 (the “Law”).

In addition, alongside the cookies designed by us, cookies may also be used within the scope of the services obtained from third parties. Whether a cookie is a first-party or a third-party cookie varies according to the cookie placed by the website or by the domain. First-party cookies are placed directly by the website visited by the user, that is, by the internet address shown in the address bar of the browser. Third-party cookies, on the other hand, are placed by a domain different from the domain visited by the user.

For Which Purposes Personal Data Will Be Processed and the Legal Grounds

Temporary cookies, also called Session cookies, are created while you are visiting our site; they are used in order to ensure the continuity of the session and are valid only until you close your browser.

Your personal data collected through these cookies is processed within the scope of subparagraph (f) of paragraph (2) of Article 5 of the Law, “provided that it does not harm the fundamental rights and freedoms of the data subject, data processing being mandatory for the legitimate interests of the data controller”.

Persistent cookies are created when you visit our Site and remain until you delete them or until they expire. Through persistent cookies, the data processed each time you visit our site is transmitted to our servers. For example, they may be used so that you do not have to enter your login details again on every visit when logging in to our Site.

Non-mandatory persistent cookies are used only if your explicit consent is obtained. Where a mandatory persistent cookie is present, your personal data collected is processed within the scope of subparagraph (f) of paragraph (2) of Article 5 of the Law, “provided that it does not harm the fundamental rights and freedoms of the data subject, data processing being mandatory for the legitimate interests of the data controller”.

Mandatory cookies are used in order to perform an information society service you have requested (logging in, filling in forms and remembering privacy preferences). Your personal data collected through these cookies is processed within the scope of subparagraph (c) of paragraph 2 of Article 5 of the Law, “provided that it is directly related to the establishment or performance of a contract, it being necessary to process the personal data of the parties to the contract”, or of subparagraph (f), “provided that it does not harm the fundamental rights and freedoms of the data subject, data processing being mandatory for the legitimate interests of the data controller”.

The information collected by these cookies, which make it possible for you to benefit from our Site, cannot be used for marketing purposes. If the use of the said mandatory cookies is not permitted, visitors will not be able to use our Site fully and effectively.

Advertising and Marketing cookies are used to promote products and services on our Site or on channels outside our Site. They are also used, together with the partners with whom we cooperate, to show you relevant and personalized advertisements and to measure the effectiveness of our advertisements.

Your personal data collected through these cookies is processed by obtaining your explicit consent within the scope of paragraph 1 of Article 5 of the Law.

Statistics (Performance Analysis) cookies are cookies that allow statistical measurement in order to analyze the behavior of users on websites. These cookies are frequently used for the improvement of the site, and this also includes the measurement of the effect of advertisements on data subjects. They are used by website owners to estimate the number of unique visitors, to identify the most important search engine keywords leading to a web page or to monitor browsing activity on the website, to collect information about how visitors use our Site, to provide control and audit of whether our Site is working as it should, and to detect the errors received and the possible problems.

Your personal data collected through these cookies is processed either by obtaining your explicit consent within the scope of paragraph 1 of Article 5 of the Law, or by relying on legal grounds other than explicit consent within the scope of Criterion B stated in the Guidelines on Cookie Practices (Çerez Uygulamaları Hakkında Rehber) published by the Authority.

Functional cookies are the cookies we use in order to make your visits to our Site easier and to realize your personal experiences. They are used for the purposes of making our web page more functional and personalizing it (ensuring that your preferences other than your privacy preferences are remembered when you enter the site again). Your personal data collected through these cookies is processed either by obtaining your explicit consent within the scope of paragraph 1 of Article 5 of the Law, or by relying on legal grounds other than explicit consent within the scope of Criterion B stated in the Guidelines on Cookie Practices published by the Authority.

Explicit Consent and Processing Rules

The processing conditions set out in Articles 5 and 6 of the Personal Data Protection Law also find an area of application for this cookie policy. In this framework, where personal data processing relies on one of the conditions other than explicit consent contained in the Personal Data Protection Law, there is no need to obtain explicit consent from the data subject.

In addition to these conditions, the following criteria are also taken into consideration while personal data is processed through cookies:

Criterion A: Criterion A covers the cookies that are technically mandatory solely for enabling electronic communication. The use of these cookies is essential for the service to work technically.

These are cookies of a technical nature that are indispensable for carrying out communication in the background of the website, for the operation of the site infrastructure, and for security and session management.

Criterion B: These are the cookies whose use is mandatory for the information society services that the subscriber or the user has expressly requested in order to receive a service.

They are used when the user directly performs a transaction (for instance, logging in, filling in a form, creating a basket, account transactions) and a cookie is technically mandatory for the provision of the service itself. Cookies that do not fall within these two criteria are not mandatory cookies and are subject to the explicit consent of the data subject.
Explicit consent is not presented to the data subject as a precondition. If consent is not given to non-mandatory cookies, access to the service is not restricted; these cookies are optional.

Within the scope of explicit consent, advertising cookies are not pre-ticked; a separate consent checkbox is provided for each cookie type, so that there is a separate one for advertising cookies, a separate one for statistics cookies and a separate one for functional cookies; no one can be obliged to give block consent to all cookies by pressing a single button.

After giving explicit consent, the data subject may return to the cookie panel at any time by clicking the cookie icon, and may change or switch off their cookie type preferences at any moment.

Data to Be Transferred to the Firm Supplying the Cookie Management Panel

Our Company works with the firm CookieSuite within the scope of the cookie management panel service. Within the scope of the panel service, your IP address, the time and date of your preference, and the approval/rejection status of the preferences you have given for the cookie categories are recorded by the firm with the necessary administrative and technical measures taken. Apart from this information, no information that would identify you is shared with the firm in any way. The firm uses servers whose infrastructure is located in Türkiye. Since proving the status of your cookie consent is the responsibility of our Company, the said information is transferred within the scope of our legal obligation and our legitimate interest pursuant to Article 5/2 (ç) and (f) of the Law.

Cookies Used on Our Site

Information regarding the cookies on our website is set out in detail in the table below:

Collection and Transfer of Cookies

Data is collected through your devices with which you access browsers. This collected information is specific to the devices; it can be deleted whenever desired and access to the information can be switched off.

You can change your preferences regarding cookies at any moment by clicking the Cookie (Cookies) icon located at the bottom part of our website. Set the buttons in the Cookie Management Panel to the on or off position according to your preference and click the relevant save/accept button. Refresh the page in order to activate your settings.

Besides this, partial control can also be provided through the browser settings. The method for changing the cookie use choice varies depending on the browser type and can be learned from the relevant service provider.

As a result of the cancellation of the use of cookies and of the changes to be made in the settings, it may be the case that a number of features on our Site cannot be benefited from.
The transferred data is protected within the framework of the Company Personal Data Protection and Processing Policy (Kişisel Verilerin Korunması ve İşlenmesi Politikası), the Personal Data Retention and Destruction Policy (Kişisel Veri Saklama ve İmha Politikası) and the relevant legislation and regulations, within the scope of encryption, access controls, the keeping of log records, the data minimization principle, secure storage, regular backup, the access authorization matrix, user definitions and the other measures and precautions set out in our policies. You can access more detailed information from our website at https://figopara.com/kisisel-verilerin-korunmasi.

Rights of the Personal Data Owner Listed in the Law

As a personal data owner, if you submit your requests regarding your rights by the methods set out below, Figo will conclude the request as soon as possible and within thirty days at the latest, depending on the nature of the request. No fee will be charged for up to ten pages of the response to be given. For each page above ten pages, the tariff determined by the Personal Data Protection Authority (Kişisel Verileri Koruma Kurumu) will be applied.

In this context, in relation to your personal data;

• To learn whether personal data is processed, and if personal data has been processed, to request information about it,
• To learn the purpose of the processing of personal data and whether it is used in accordance with its purpose,
• To know the third parties to whom personal data is transferred domestically or abroad,
• To request the correction of personal data in the event that it has been processed incompletely or incorrectly, and to request that the action carried out in this context be notified to the third parties to whom the personal data has been transferred,
• To request the deletion or destruction of personal data in the event that the reasons requiring its processing cease to exist, even though it has been processed in accordance with the Law No. 6698 and the provisions of other relevant laws, and to request that the action carried out in this context be notified to the third parties to whom the personal data has been transferred,
• To object to a result arising against the person themselves through the analysis of the processed data exclusively by automated systems,
• To request the remedy of the damage in the event of suffering damage due to the unlawful processing of personal data

are the rights you have.

You may convey your request regarding the exercise of the rights stated above, in Turkish; to us in our capacity as data controller,

a. in writing, together with documents verifying your identity, to the address Barbaros Mah. Kardelen Sk. Palladium Tower No:2 İç Kapı No:58 Ataşehir/İstanbul, or
b. as registered electronic mail to the address Figoticaribilgi@hs01.kep.tr,
c. in the event that you have an e-mail address registered in our system, to the address kisiselverilerikorumakomitesi@figotr.com, or
d. by the other methods determined by the Personal Data Protection Authority.

In the application that you will make in order to exercise the rights you have as Data Subjects and which are stated above, and that contains your explanations regarding the right you request to exercise; the matter you request must be clear and comprehensible, the subject you request must be related to you personally or, if you are acting on behalf of someone else, you must be specially authorized in this regard and your authority must be documented, and the application must meet the minimum application requirements set out in Article 13 of the Personal Data Protection Law and in the Communiqué on the Procedures and Principles of Application to the Data Controller (Veri Sorumlusuna Başvuru Usul ve Esasları Hakkında Tebliğ).

You can access the data owner application form (Veri sahibi başvuru formu) from our website.

Figo reserves the right to verify your identity before responding.

In your application;

• your name, your surname and, if the application is in writing, your signature,
• for citizens of the Republic of Türkiye, your Republic of Türkiye Identity Number (T.C. Kimlik Numarası); if you are a foreign national, your nationality, your passport number or, if any, your identity number,
• your place of residence or place of business address that forms the basis for notification,
• if any, your electronic mail address, telephone and fax number that form the basis for notification,
• the subject of your request,

must be present, and information and documents relating to the matter, if any, must also be attached to the application.

Among the petitions submitted to the Company; those that do not contain a specific subject, those relating to matters falling within the duty of the judicial authorities, and applications that do not bear your name-surname and signature and your business or residence address cannot be examined.