Promena Platform

Cookie Notice

This text has been prepared under Article 10 of the Personal Data Protection Law No. 6698 (the “Law”) and the Communiqué on the Procedures and Principles to be Followed in Fulfilment of the Disclosure Obligation, by Zer Merkezi Hizmetler ve Ticaret Anonim Şirketi, acting as “Data Controller” (“Koçzer”).

As Koçzer, cookies and certain other similar technologies (collectively referred to as "Cookies") are used within the scope of the Promena digital platform (www.promena.net, the "Website",the"Site"or"Promena").This text provides information on the types of Cookies used and the purposes for which they are used when you visit the site.

For cookies used on the Site other than mandatory cookies, the consent (explicit consent) of users is obtained, and users are given the opportunity to change their consent at any time. Through the cookie management panel/the table at the end of this text, users can view the types of cookies used on the Site and set their preferences to “on” or “off” for all cookies other than Necessary Cookies. Users may also change their preferences at any time through this panel

You can access the disclosure text regarding your other personal data processed by Koçzer under the Law, other than Cookies, via the Privacy Notice link on the Site.

1. What Are Cookies and Other Similar Technologies?

A cookie is a small text file saved to your computer or mobile device by your browser when you visit a website. In addition to helping a website run more efficiently, cookies make it possible to offer customized pages for a visiting experience that is faster and better suited to your personal needs. Cookies contain only information relating to your browsing history on the internet and do not collect any information about files stored on your computer or mobile device.

In addition, there are certain other technologies used for purposes similar to Cookies (“Cookie-Like Technologies”) as follows.

• Pixel tags (transparent graphic images placed on a website that indicate that a page has been viewed),

• Mobile device identifiers (storage, in third-party environments, of information relating to the use of a mobile device through IDFA, advertising ID, etc.),

• Segmentation/reporting products (programs/products that operate through certain ready-made codes added to a website’s or mobile device’s code by various methods, and that report/interpret/store users’ actions on the website or mobile device through these codes)

The term “Cookie” used in this text shall be understood to also cover Cookie-Like Technologies.

1. Types of Cookies and Purposes of Use

Cookies by validity period:

• Temporary Cookies: Session Cookies are temporary cookies used during visitors’ visits to the website and deleted once the browser is closed. The main purpose of using such cookies is to ensure that the website functions properly during your visit. For example, these cookies make it possible for you to fill out multi-page online forms.

• Persistent Cookies: Persistent cookies are a type of cookie used to increase the functionality of the website and to provide a faster and better service. Such cookies are used to remember visitors’ preferences and are stored on visitors’ devices via the browser. Certain types of persistent cookies may be used to offer visitors personalized recommendations, considering factors such as their purpose in using the website. Thanks to persistent cookies, when the website is visited again from the same device, it is checked whether a cookie created by the website already exists on the visitor’s device; if so, it is understood that the website has been visited before, and the content delivered to the visitor is determined accordingly. Cookie-Like Technologies also fall within this scope.

Cookies by source:

• First-party cookies: Placed directly on visitors’ devices by the website itself. First-party cookies are set by the website you are browsing and can only be read by that site.

• Third-party cookies: Third-party cookies are set up by other organizations providing different services. For example, the external data analytics services we make use of, and the providers of those services, set cookies on our behalf to report on what is popular and what is not.

Cookies by purpose of use:

• Necessary Cookies: Necessary cookies are cookies required for you to browse our website and use its features, such as access to secure areas of the site (logging in, filling out forms, remembering privacy preferences). These cookies are used for purposes such as security and verification, are not used for any marketing purpose, and do not identify you. Remembering previous actions when you return to a page within the same session is an example of this.

• Functionality Cookies: Functionality cookies allow our website to remember choices you have made in the past (such as your username, the region you are in, or the language you use) for a more personalized online experience. The information collected by these cookies may include confidential data that could identify you, such as your username or profile picture. Not permitting the use of such cookies may result in a feature specific to you being unavailable and may prevent your preferences from being remembered.

• Performance-Analytics Cookies: These cookies help us understand how visitors interact with our website by collecting information such as how you use our website, which pages you visit and which links you click. These cookies are used to improve the site. Website owners use them to estimate the number of unique visitors, identify the most important search-engine keywords leading to a web page, or track navigation on the website. These cookies do not identify you. All data is collected and compiled anonymously.

• Marketing/Advertising Cookies: These cookies are used to build a profile of you based on your interests, preferences, and behavior, to store your preferences, and, within this scope, to show you advertisements relevant to you and to present content close to your interests. They may also be used to deliver targeted advertisements or to limit the number of times an advertisement is displayed to you. Many types of these cookies may collect identifying information by tracking consumers.

1. What Happens If Cookies Are Not Accepted?

If you decide not to accept cookies, certain features of this website may not be displayed or may not function correctly. This will limit what you can do on our website and may affect its design and user experience.

Features that may be affected include the following:

• Use of the Favorites (My Content) function

• The website not being experienced in a personalized way

• Watching videos

• Liking or sharing this page on social networks

• Viewing embedded content

1. How Can You Change Your Cookie Settings?

While the use of cookies enables the website or mobile device to provide a better service, you may, if you wish, prevent the use of cookies (other than mandatory cookies). Please note, however, that in this case the website or mobile application may not be able to fully perform its function, and you may not be able to benefit from all of its features. To prevent the use of cookies, you need to change the settings of the internet browser you use. These changes vary depending on the device and internet browser you use. Below is information on the steps to prevent the use of cookies in different internet browsers:

• Internet Explorer

• Open the desktop and tap or click the Internet Explorer icon on the taskbar.

• Tap or click the Tools button, then Internet Options.

• Tap or click the Privacy tab, then move the slider under Settings upward to block all cookies and tap or click OK.

• Google Chrome

• Open Chrome on your computer.

• In the top right, click More, then Settings.

• Click Advanced at the bottom.

• Under “Privacy and security”, click Content settings.

• Click Cookies.

• Under “All cookies and site data”, search for the name of the Website.

• Click the Remove icon to the right of the site.

• For further information:

https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en

• Mozilla Firefox

• Click the Firefox Menu button and select Options.

• Select the Privacy & Security panel and go to the History section.

• Change the Firefox setting to “Use custom settings for history”.

• Click the “Show Cookies” button. The Cookies window will appear.

• In the Search field, type the name of the site whose cookies you want to delete. Cookies matching your search will be displayed.

• Select the cookie(s) you want to delete and click Remove Selected.

• Click Close to close the Cookies window, then close the about:preferences page.

• For further information: https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop?redirectslug=enable-and-disable-cookies-website-preferences&redirectlocale=en-US

• Safari

• Select Safari > Preferences.

• Click Privacy.

• Click Website Data.

• Select one or more websites, then click Remove or Remove All.

• For further information: https://help.apple.com/safari/mac/9.0/#/sfri40732

• Microsoft Edge

• Click the three-dot icon in the top right corner of your Microsoft Edge browser and go to Settings.

• In the window that appears, click Choose What to Clear, then select the items you want to clear from the window that appears.

• There are several categories here. You can select the ones you want and start the clearing process.

• Opera

• For further information: https://help.opera.com/en/latest/web-preferences/

In addition, you can change your cookie preferences at any time by clicking on the cookie icon on the Site. Save your settings by switching the buttons in the cookie management panel to on or off according to your preference. Refresh the page to activate your settings.

1. What Is the Method of Collection, Purpose of Use and Legal Basis of Personal Data Obtained Through Cookies?

Your personal data is obtained through automated means, by placing the cookies used on the Site on your device. Explanations regarding the purposes of the types of cookies used on the Site are provided above, and detailed information on the purpose of use, type, duration, and other particulars of each cookie used on the Site is set out in the table at the end of this text.

Legal bases of the cookies used:

• Your personal data collected through necessary cookies is processed under the Law on the grounds that “it is necessary to process personal data belonging to the parties to a contract, provided that this is directly related to the establishment or performance of the contract” or that “it is mandatory for the data controller to process the data for its legitimate interests, provided that this does not harm the fundamental rights and freedoms of the data subject”.

• Your personal data collected through Functionality Cookies, Performance-Analytics Cookies, and Advertising and Marketing Cookies is processed on the basis of obtaining your explicit consent, under Article 5(1) of the Law.

1. What Are Your Rights?

You may submit your requests under Article 11 of the Law regarding your processed personal data to Koçzer, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, by completing the Data Subject Application Form available at https://www.koczer.com/uploads/Veri_Sahibi_Basvuru_Formu_4726cf3b20.pdf , and submitting it to Koçzer. Depending on the nature of your request, your application will be concluded free of charge as soon as possible and within thirty days at the latest; however, if the transaction requires an additional cost, a fee may be charged to you in accordance with the tariff set by the Personal Data Protection Board.

Registered E-Mail (KEP) Address: zer@zer.hs02.kep.tr E-mail address: kvk@koczer.com Address: Ünalan Mah. Ayazma Cad. Çamlıca İş Merkezi B. Blok Kat: 1 Üsküdar/İstanbul

1. Cookies Used and Detailed Explanations

Cookie Used	Cookie Type	Domain	Purpose of Use	Retention Period
_ga_C41497SV4W	Analytics	.promena.net	Used by Google Analytics to retain user-specific statistical data.	10 Hours
_clsk	Analytics	.promena.net	Stores data relating to the time spent on the website and its sub-pages during the current session.	24 Hours
_gcl_au	Marketing	.promena.net	Conversion-tracking cookie for Google Conversion Linker (Ads/Analytics).	90 Days
_clck	Analytics	.promena.net	Collects data about the user’s navigation and behavior on the website. This is used to compile statistical reports and heat maps for the website owner.	365 Days
_fbp	Marketing	.promena.net	Used by Facebook to deliver a range of advertising products, such as real-time bidding from third-party advertisers.	90 Days
_ga_LVF59GBFH5	Analytics	.promena.net	Used by Google Analytics to retain user-specific statistical data.	1 Year
_ga	Analytics	.promena.net	Registers a unique ID used to generate statistical data on how the visitor uses the website.	1 Year
_ga_NTQYQ540PW	Analytics	.promena.net	Used by Google Analytics to retain user-specific statistical data.	1 Year
_ga_316961377	Analytics	.promena.net	Used by Google Analytics to retain user-specific statistical data.	1 Year
test_cookie	Marketing	.doubleclick.net	Used to verify whether the user’s browser supports cookies.	Session
lidc	Marketing	.linkedin.com	Used by the social networking service LinkedIn to track the use of embedded services.	.linkedin.com
li_sugr	Marketing	.linkedin.com	A cookie used to perform probabilistic matching of a user’s identity outside the Designated Countries.	90 Days
bcookie	Marketing	.linkedin.com	Used to record the 2FA status of a logged-in user	.linkedin.com
__cf_bm	Necessary	.linkedin.com	This cookie is used to distinguish humans from bots. This is useful for the website in preparing valid reports on the use of websites.	Session
SRM_B	Marketing	.c.bing.com	Tracks the user’s interaction with the website’s search-bar function. This data may be used to present the user with relevant products or services.	1 Year
SM	Marketing	.c.clarity.ms	Records a unique ID that identifies the user’s device on repeat visits across websites using the same advertising network. The ID is used to enable targeted advertising.	Session Cookie
MUID	Marketing	.bing.com	This cookie allows visitors to leave feedback on their use of the website - this information is used to optimize the website.	Session
MUID	Marketing	.clarity.ms	This cookie allows visitors to leave feedback on their use of the website - this information is used to optimize the website.	Session
CLID	Marketing	www.clarity.ms	Collects data about the user’s navigation and behavior on the website. This is used to compile statistical reports and heat maps for the website owner.	365 Days
ANONCHK	Marketing	.c.clarity.ms	Records data relating to visitors across multiple visits and multiple websites. This information is used to measure the effectiveness of advertisements on websites.	4 Seconds