Cookie Confidentiality Policy

This Confidentiality Policy ("Confidentiality Policy") establishes the terms and conditions for the use of personal data which is shared with the Company by the users/members/visitors ("Data Owner") of the website, bootrain.com ("Site") and its mobile application operated by Datajarlabs (“Company”) (together will be referred to as "Platform") or which is generated by the Company during the use of the Platform by the Data Owner.

With this Confidentiality Policy, the Data Owner declares that he/she is provided information about processing of personal data and consents to the use of his/her personal data as described here. Which data is processed?

This title lists what is considered as personal data pursuant to the Turkish Law no 6698 on Protection of Personal Data, which is processed by the Company. Unless otherwise stated, "personal data " shall mean the following information under the terms and conditions of this Confidentiality Policy :

  • Customer Information
  • Equipment Information
  • Behaviour
  • Demographic Information
  • Marketing Information
  • Behavioural Advertising

Pursuant to the articles 3 and 7 of the Law on Protection of Personal Data; data that has been transformed irreversibly into anonymous data shall not be considered as personal data and processing of such data shall be conducted without applying the provisions of this ConfidentialityPolicy.

For what purposes is data used?

The Company may process personal data to customize and recommend products and services of the Company to people according to their likes, habits of use and needs; to use the data in direct and indirect marketing activities and to transfer such data to the Company's representatives, solution partners and third party service providers for such purposes.

The Company may process personal data and share it with third parties without obtaining the consent of the Data owner pursuant to the articles5 and 8 of the Law on Protection of Personal Data and/or in case of any exceptions in the relevant legislations. These are described below:

  • Explicitly stipulated in law,
  • Data processing must be done to protect the life or bodily integrity of someone who cannot give his/her consent due to a physical impossibilityor whose content is not considered legally valid or to protect the life or bodily integrity of somebody else,
  • Data processing is required provided that this is directly related with the establishment or execution of an agreement between the Data Ownerand the Company,
  • Data processing must be done in order for the company to fulfil its legal obligations,
  • Data has been made anonymous by the Data Owner,
  • Data processing must be done in order to establish, exercise or protect a right,
  • Data processing must be done for the legitimate interests of the Company provided that no harm is inflicted on the basic rights and freedom ofthe Data Owner.
Who has access to Data?

The Company may transfer personal data and the new data it generates using this personal data to third parties from which the Company outsources services for the purposes set in this Confidentiality Policy provided that this is limited to the provision of such services.

The Company may transfer personal data and the new data it generates using this personal data to third parties from which the Company outsources services for the purposes set in this Confidentiality Policy provided that this is limited to the provision of such services.

Additionally the Company may transfer data to Company's business partners and suppliers and legally authorized organizations in accordance with the purposes described in this Confidentiality Policy. The Company may share personal data with third parties such as outsourcing service providers including those that provide SMS services, hosting services, law firms, research companies, call centers in order to improve data owner experience (including enhancement and customization), ensure data owner security, detect unauthorized or fraudulent use, conduct operational evaluations, eliminate mistakes in Platform services and any other purposes included in this Confidentiality Policy.

The Data Owner agrees and accepts in advance that the above mentioned third parties may store the data owner's personal data in any of theirservers all around the world provided that this is limited to the above mentioned purposes.

Data Access Rights and Correction Requests

Pursuant to the article 11 of the law data owners are entitled to;

  • Learn whether their personal data has been processed,
  • If processes, request information about how their personal data is processed,
  • Learn the purpose of processing their personal data and whether it is used for the intended purpose,
  • Have information about third parties in the country and abroad to whom their personal data has been transferred,
  • Request correction/amendment if their personal data is processed incorrectly or incompletely and that such correction/amendment is informedto the third parties to whom their personal data has been transferred,
  • Request that their personal data is deleted or destroyed despite being processed in accordance with the Law and other applicable regulations if the reasons for their data to be processed no longer exist and that these actions are informed to the third parties to whom their personal data has been transferred,
  • Object to any unfavourable outcome for them based on the analysis of their processed data by automatic systems exclusively,
  • Claim damages in the event that they incur losses due to the reason that their personal data is processed illegally.

The above mentioned requests to exercise rights shall be evaluated in the shortest time possible and in any case maximum in 30 (thirty) days provided they are informed by the personal data owners using the methods specified in the Policy for Protection and Processing of Personal Data of Datajarlabs as included in the website bootrain.com. Although no fee is basically asked for such requests made, the Company reserves the right to ask for a fee according to the list of fees determined by the Personal Data Protection Committee of the Company.

In the event that a data owner makes a request which will cause the Company not use any of the data owner's data , the data owner accepts that he/she may not be able to benefit fully from the Platform offerings and declares that he/she takes all responsibilities arising from this.

Retention Period for Personal Data

The Company shall keep the personal data provided by the data owner for the period that is required by the above mentioned processing purposes.

In addition to this, in the event of a conflict between the Company and the data owner, personal data may be retained for the prescription periodspecified in the relevant laws provided that it is limited to the purpose of defence required during the resolution of the conflict.

Measures and Commitments on Data Security

The company warrants that the company will take necessary technical and administrative measures, and conduct necessary inspections in order to ensure that

  • personal data is not processed unlawfully,
  • personal data is not accessed unlawfully,
  • personal data is protected.

The Company may not disclose any personal data the Company acquires about the Data Owner to third parties and use it for any other purposes other than the processing purposes, in violation of the provisions of the Personal Data Protection Law.

If there are links to other applications on the platform, the Company shall not be held responsible for the confidentiality policies and contents of such applications.

Cookies

The Platform uses Cookies in order to allow users to have the optimum benefit from the Platform and enhance their experience. If you do not prefer the use of Cookies, you can delete or disable Cookies using browser settings. However this can affect the way you will use the Platform.

What are cookies and why are they used?

Cookies are small text files that are placed on your device or net server by the websites you visit. For more detailed information about cookies please visit www.aboutcookies.org and www.allaboutcookies.org The main purposes of cookies on our website are listed below:

  • To improve the service provided to you by increasing the functionality and performance of the website,
  • To improve the website and provide new features on the Website and customize such features according to your preferences;
  • To ensure legal and commercial security for the website, for you and our Company.
  • To use in direct and indirect marketing activities
Categories of the Cookies Used on the Website
Technical Cookies Technical Cookies
Authentication Cookies When a visitor visits the website using his/her password, these types of cookies identify the user on each web page he/she visits to eliminate the need for the user to enter his/her password on every page he/she visits.
Flash cookies Types of cookies that are used to enable video or audio content on the website.
Customization Cookies Customization Cookies
Analytical Cookies Analytical Cookies allow to have analytical results such as number of visitors of the website, pages viewed on the website, visiting times, website scroll moves .
Can the use of Cookies be Blocked by Data Owners?

Data owners can change their preferences about cookies by modifying browser settings. If the user's browser provides this option, cookie preferences can be modified using the browser settings. Therefore , although this might differ according to the options the browser offers, data owners have the options to block cookies, to have warnings before the use of any cookie or to disable or delete only certain cookies.

Cookie preferences may need to be made separately on each device with which the user has access to the Platform.

Adobe Analytics http://www.adobe.com/uk/privacy/opt-out.html
AOL https://help.aol.com/articles/restore-security-settings-and-enable-cookie-settings-on-browser
Google Adwords https://support.google.com/ads/answer/2662922?hl=en
Google Analytics https://tools.google.com/dlpage/gaoptout
Google Chrome http://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647
Internet Explorer https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
MozillaFirefox http://support.mozilla.com/en-US/kb/Cookies
Opera http://www.opera.com/browser/tutorials/security/privacy/
Safari https://support.apple.com/kb/ph19214?locale=tr_TR
Changes in the Confidentiality Policy

The Company may change the provisions of this Confidentiality Policy anytime. The Current Confidentiality Policy becomes effective when it is presented to the Data Owner using any method.