References

PERSONAL DATA PROTECTION POLICY

This policy aims to explain the principles for the processing of personal data that should be known by natural persons, whose personal data we process, such as the suppliers, visitors, and users of websites (https://huqqa.com, https://themarketbosphorus.com, https://qurabiye.com) of HUQQA GIDA ISLETMELERI SAN. ve TIC. A.S. (hereinafter referred to as “HUQQA”).

Definitions

Within the scope of this policy, the following terms have the following meanings:

HUQQA: refers to HUQQA GIDA ISLETMELERI SAN. ve TIC. A.S.,

Concerned person/natural person: refers to personal data subject,

Recording medium: refers to all kinds of medium where personal data processed fully or partially through automatic means or provided that the process is a part of any data registry system through non-automatic mean are kept,  

Site: refers to the websites at the addresses https://huqqa.com, https://themarketbosphorus.com and/or https://qurabiye.com,

Data Processor: refers to the natural person or legal entity who processes the personal data on behalf of the data controller, with the authorization given by the data controller,

Data Controller: refers to the natural person or legal entity who/that determines the purpose and means of processing the personal data and is responsible for establishing and managing the data registry system.

Law No. 5651: refers to the Law on Regulation of Publications on the Internet and Suppression of Crimes Committed through Such Publication,

Law No. 6698/KVKK: refers to the Law on Personal Data Protection,

II. Obtaining and Processing of Your Personal Data

1. Processing of Personal Data of the Website Users (Online Visitor), WIFI Service Users, and Call Center Users

1.1. Processing of Personal Data of the Website Users (Online Visitor)

To make requests and suggestions, the users who use the website can fill out the form on the ‘’Contact’’ page at the links https://huqqa.com, https://themarketbosphorus.com and/or https://qurabiye.com and then, send the data such as name, surname, e-mail, phone, gender, date of birth, address, message, sector, and subject of the form.

The users accept that they share this data with the Site with their free will entirely and that this data is only requested to evaluate the requests and suggestions they send.

Furthermore, the traffic information of the users visiting the Website is processed per Law No. 5651.

1.2. Processing of Personal Data of the WIFI Service Users

To render this service and to comply with Law No. 5651 and the relevant Secondary legislation, it processes the mobile phone number and traffic information of the visitors who visit the premise of HUQQA physically and want to use the WIFI.

1.3. Processing of Personal Data of the Call Center Users

The personal data belonging to users, who call HUQQA, are collected and retained by it.

Personal data such as name, surname, phone, and e-mail address are collected from users who call HUQQA. These data are processed to conduct necessary works to benefit you from the products and services offered by our company and carry out the relevant business processes, to plan and execute activities necessary for suggesting and promoting the products and services offered by the company through customizing them according to your tastes, usage habits, and needs, to conduct necessary works by our relevant business units and relevant business processes to carry out commercial activities by the company, to plan and execute the commercial and/or business strategies of our company and to ensure legal, strategic and commercial job safety of our company and the concerned persons who have a business relationship with our company.

Your personal data that you have shared by calling HUQQA are collected and retained by our company to put your requests, suggestions, and complaints into the process, inform you about the result of the transaction and develop the services and products offered in this context.

2. Processing of Personal Data Within Procurement Processes:

HUQQA processes the personal data of the natural person suppliers, supplier employees and/or supplier officer and the natural persons, legal entity employees, and/or officers to whom product, service, or good is supplied by HUQQA, to follow up and execute the product, service or good procurement processes.

2.1. Personal data processed within procurement processes

HUQQA processes the following personal data within the scope of procurement processes:

Identity information such as name, surname, T.R. identity number concerning natural person supplier and/or purchaser; financial information such as bank details; contact information such as an address, e-mail, mobile phone and personal data of special nature such as photos and signatures in documents such as the statements of signature, circulars, etc.
Identity information such as name, surname, T.R. identity number concerning supplier and/or purchaser officer; personal data of special nature such as photos and signatures in documents such as the power of attorney/circulars, etc.; contact information such as an address, e-mail, mobile phone,
Identity information such as name, surname, T.R. identity number concerning supplier and/or purchaser employee; personal information such as SSI payroll, OHS documents; personal data of special nature such as a medical report, criminal record; educational/professional experience and experience information such as educational background, certificates; financial information such as bank details; contact information such as an address, e-mail, mobile phone.

2.2. Purpose of Personal Data Processing Within Procurement Processes

- To fulfill the obligations arising from the legislation such as the Occupational Health and Safety Law, SSI, Labor Law, Turkish Code of Commerce, Tax Procedural Law,
- To follow up and execute the contract processes related to the procurement of goods, products, or services,
- To ensure compliance with corporate company rules.

2.3. Modes of Collection and Processing of Personal Data of the Supplier and/or Purchaser

Supplier and/or purchaser officer, supplier and/or purchaser employee, or natural person supplier and/or purchaser itself,
Documents such as Circular/Power of Attorney,
Communication channels such as e-mail, phone, website,
Contract,
Reference Control Sheet.

3. Processing of Personal Data of Physical Visitors

3.1. Processed personal data of natural persons who visit HUQQA premise physically

HUQQA records images with cameras inside and outside the building to ensure the safety of its employees and visitors. The visitors are notified about the recording with the camera inside the building.

3.2. Personal Data of Natural Persons Who Visit Restaurants Physically

HUQQA processes the following personal data of special nature belonging to natural persons visiting restaurants;

- - Name and surname information,
  - Phone numbers,
  - Payment information,
  - Image record

HUQQA records images with cameras inside and outside the building to ensure the safety of its employees and visitors. The visitors are notified about the recording with the camera inside the building.

3.3. Purpose of Processing Personal Data of Visitors

HUQQA processes the personal data of people who visit the headquarters of HUQQA for the following purposes:

- - To ensure the venue security
  - To get identity information and documents per the applicable legislation,
  - To give a visitor entrance card and create a visitor number,
  - To keep records of visit entry and exit times,
  - To create a gun delivery report for visitors who come with guns,
  - To share the interior and exterior sketch of the building and necessary safety information with the visitor card.
  - To plan and execute emergency management processes (terrorism, fire),
  - To conduct security checks of people/products coming to the building,
  - To inform the law enforcement in case of crime or illegality,

HUQQA processes the personal data of the people visiting the restaurants for the following purposes;

- - To confirm and plan the reservations,
  - To ensure the issuance of invoices,
  - To ensure the security

3.3. Modes of Collection and Processing of Personal Data of Visitors

- - Official identity documents of the visitor (such as T.R. ID, driving license, passport, lawyer identity card)
  - Record images taken with CCTV,
  - Reservation requests made via phone, QFB applications,

3.4. Providing the Security of Visitors’ Personal Data and Sharing Personal Data

Both the identity information of the visitors and the CCTV records are retained in systems only accessible by authorized persons. Upon request, these personal data can be shared with public institutions and organizations that are legally authorized to request such data.

4. Processing of Personal Data of Social Responsibility Project Participants and Training Participants

4.1. The personal data of project associates, project participants, and training participants (such as volunteer workers, parents, students) who/that take a role in the social responsibility projects and training organized by HUQQA are as follows:

- - Identity information
  - Communication information
  - Education information
  - Financial Information

4.2. Purpose of Processing of Personal Data of Project Associates, Project Participants, and Training Participants

- - To raise the recognition of the company,
  - To create social benefit and awareness,
  - To plan and conduct corporate communication activities,
  - Event management,
  - To plan and carry out social responsibility and/or civil society activities,
  - To plan and carry out sponsorship activities,
  - To fulfill legal obligations of the company

4.3. Methods of Collection and Processing of Personal Data of Project Associates, Project Participants, and Training Participants

These personal data are obtained from the Project Associates and/or project participants and/or training participants themselves on a project and training basis.

III. Security and Transfer of Your Personal Data and Exercising Your Rights Related to Your Personal Data

All personal information that you have shared with us will be kept confidential in the database at HUQQA per the Art. 12 of Law No. 6698 on Protection of Personal Data and will not be shared with the third parties for commercial purposes.

HUQQA takes the following measures as a minimum to provide the security of the personal data it processes, to prevent unlawful access to them, and to prevent illegal data processing:

- - It takes hash, encryption, transaction log, access management, and physical security measures to ensure that information systems storing personal data are protected against unauthorized access and illegal data processing.
  - The website and all systems storing personal data are protected by a network firewall.

HUQQA stores personal data concerning online and physical visitors per the legislation and shares them with relevant public institutions and organizations upon request. The personal data concerning suppliers and/or purchasers can be shared with companies and affiliates within the body of HUQQA as well as the relevant public institutions regarding the goods, products, or services supplied. The personal data concerning participants and/or project associates of social responsibility projects organized by HUQQA can be shared in written, visual and social media with the explicit consent of the concerned person.

The rights that you have concerning your personal data you have shared within the scope of the purposes specified in this Personal Data Protection Policy and the modes of processing of the personal data per Art. 11 of Law No. 6698 are as follows:

a) to learn whether his/her personal data are processed or not,  

b) to request information if his/her personal data are processed,  

c) to learn the purpose of his/her data processing and whether this data is used for intended purposes,  

ç) to know the third parties to whom his/her personal data is transferred at home or abroad,  

d) to request the rectification of the incomplete or inaccurate data, if any,  

e) to request the erasure or destruction of his/her personal data if the conditions requiring processing are no longer available although they have been processed per Law No. 6698 and other relevant provisions,  

f) to request notification of the operations carried out in compliance with subparagraphs (d) and (e) to third parties to whom his/her personal data has been transferred,  

g) to object to the processing, exclusively by automatic means, of his/her personal data, which leads to an unfavorable consequence for the data subject,  

ğ) to request compensation for the damage arising from the unlawful processing of his/her personal data.
To exercise these rights, you can contact us using the ‘’Application Form’’ on our website through the methods specified in this form at any time.

IV. Retaining Your Personal Data Accurate and Up-to-Date

The relevant groups of the persons, whose personal data we process, accept and declare to be aware that accuracy and up-to-dateness of personal data they share through Website and/or they submit personally due to a contractual relationship are important to exercise the rights on their personal data under the KVKK and other relevant legislation and that they assume the entire responsibility of giving wrong information.

V. Personal Data Retention Period

The period for retaining the personal data of online visitors is 2 years per Law No. 5651. The period for retaining the CCTV records of physical visitors is 90 days. The personal data concerning identity information are retained within the framework of the periods stipulated in the relevant legislation. The personal data concerning suppliers and/or purchasers are retained for 10 years per the legislation following the termination of the legal relationship.

VI. Erasure, Destruction, or Anonymization of Your Personal Data

Your personal data processed for the purposes specified in this Personal Data Protection Policy will be anonymized and continued to be used by us when the purposes requiring processing are no longer available under Art. 7/f.1 of Law No. 6698, and the periods determined by the Law have expired per the Art. 17 of this Law and the Art. 138 of the Turkish Penal Code.

When the retention periods stipulated in the relevant legislation or required for processing have expired, HUQQA anonymizes the personal data it has processed by using one or several techniques specified in the Guide on the Erasure, Destruction or Anonymization of Personal Data published by the Personal Data Protection Board within 6-month period foreseen for the periodic destruction per its business processes and activities, and thus, continues to use these data in this way.

VII. Categorization of Personal Data

Concerned Person Groups	Data Category
Online visitors and WIFI Service Users, Call Center Users	Identity Data, Communication Data, Legal Transaction Data
Natural Person Supplier and/or Supplier, Supplier and/or Supplier Officer, Supplier and/or Supplier Employee	Identity Data, Communication Data, Legal Transaction Data, Financial Data, Corporate Identity Data, Visual and Audio Data, Private Personal Data, Personnel Data
Physical Visitor	Identity Data, Visual and Audio Data
Project Associate, Project Participant, Training Participant	Identity Data, Communication Data, Audio-Visual Data, Financial Data, Education Data

VIII. Amendments and Updates to the Policy

HUQQA may make amendments or updates to this Policy in line with the legal legislation and Company Policy. The concerned persons are notified about the new Policy text reflecting all these amendments and updates on the website.

Dear User, Welcome to https://www.qurabiye.com, a website of HUQQA GIDA ISLETMELERI SANAYI VE TICARET A.S. (hereinafter referred to as the ‘’COMPANY’’).

“Terms of Use and Cookie Policy” stipulates the provisions concerning providing information and rendering services on our website to our valued users.

TERMS OF USE, ACCESS, RISK, AND LIMITATION OF RESPONSIBILITY, IP ADDRESSES, AND COOKIES

The website https://www.qurabiye.com and all documents on this website are the property of the COMPANY. These documents cannot be copied or reproduced except when necessary for being displayed on the online system. Notwithstanding the foregoing, you can print out the website pages for your personal use. Regardless of the aforesaid general principles, the COMPANY can allow for downloading wallpapers, screen savers, and other programs from the site. The user assumes all kinds of legal liabilities arising from all kinds of uses which may breach the intellectual and industrial rights concerning the documents on this website.

If you want to create a link with the website, this link shall be directed to the homepage of https://www.qurabiye.com. [https://www.qurabiye.com]

Although the COMPANY has taken measures to ensure that the website is free of viruses and similar software within the bounds of possibility, the user is obliged to supply his/her own virus protection system and provide the necessary protection to ensure the ultimate security. In this context, the user hereby accepts that s/he is responsible for all errors that may occur in his/her own software and operating systems and the direct or indirect consequences of these due to his/her website http://www.qurabiye.com.

All kinds of prices, information, images, explanations, and news (hereinafter referred to as ‘’information’’) on the website http://www.qurabiye.com are only for promotional and information purposes. The user cannot claim that the ‘’information’’ on the website is incorrect or s/he has suffered a loss based on this information. When the user intends to take action based on the information, s/he accepts that s/he is obliged to obtain the final and reliable information from the COMPANY and that the COMPANY has no responsibility if the information published on the website is not up-to-date.

The COMPANY reserves the right to change the content of the site at any time, to change or terminate any service provided to users, and to delete the user information and data registered on the website http://www.qurabiye.com at its sole discretion. Although the COMPANY has taken every measure to ensure that the website is error-free, it does not give any guarantee concerning the errors that occur or may occur on the website.
If the service charge information is provided on the website http://www.qurabiye.com, the relevant information is valid on the date of the last update. We kindly request you to get in contact with the COMPANY for final information concerning services and reservations. In this context, the COMPANY declares that the information on the website (unless otherwise expressly stated) is not an offer for rending service and does not constitute a commitment on behalf of the COMPANY.
If a criminal complaint or an official investigation request is received from the official authorities and/or it is determined that the user has committed any electronic sabotage or attack that will prevent the operation of the COMPANY’s systems or change their operation, the COMPANY has the right to investigate the user’s identity information and notify the legal authorities.

The COMPANY assumes the responsibility of ensuring the security of the COMPANY’s website and all its subsites and other information systems. Any damage to the systems by scanning for the detection of vulnerabilities in websites and other information technology systems for commercial, well-intended, or other purposes, and exploiting the vulnerabilities that can be detected and any activity such as leaking information, etc. are illegal. In case of such activities, sanctions may be imposed per Law No. 5651 on Regulation of Publications on The Internet and Combating Crimes Committed By Means of Such Publications. In case of such attempts, the COMPANY reserves the right to initiate legal actions with the data collected under the law regarding the type and time of attack and attacker and to demand fines or imprisonment as a result of this legal action.

In some cases, non-personal information may be collected. Examples of this type of information are the type of internet browser you use, your operating system, and the domain name of the website through which you have accessed our site with a link or an advertisement.

When you visit the website, information may be placed on your computer. This information will be in the form of a cookie (‘’cookie’’) or similar file and they will help us in several ways. However, it is aimed to provide you with a better internet experience by tracking your preferences during your visits to our website. To illustrate, the cookies will enable us to organize the websites and advertisements according to your interests and preferences. Almost all internet browsers have options to delete cookies from your hard disk, prevent them from being written, or receive a warning message before they are saved. For more information on this, please refer to your browser’s help files and usage information.

Our company integrates personal data obtained from online and offline sources in compliance with the relevant legislation into internet-based platforms. Our company uses this data to conduct necessary data analytics studies by the business departments to benefit its customers from the products and services offered by our company, to customize the products and services offered according to the usage habits and needs of the customers and thus, recommend them to the customers and/or to analyze them for the companies/brands with which we make cooperation and thus, provide customized advertisements, campaigns, and other benefits. In this direction, it also utilizes data management platforms and similar digital advertising platforms and technologies to be able to advertise with the target audience and/or provide a target audience to the advertisers’ digital advertising projects. For the management of these platforms, cooperation can be made with different companies within the framework of certain contracts, and thus, support can be taken from various companies in operational processes.

Our company can divide its customers into several categories and groups on digital advertising platforms or technologies by using online customer information obtained in several ways such as cookies, digital device identification information and SDK (software development kit), and customer information obtained from offline sources. This data is integrated into digital advertising platforms and securely kept using various algorithms and internationally accepted encryption methods.

If you want to remove cookies from your computer and cell phone, we recommend you follow the following processes: First, you can use your browser and access the cookies already installed on your terminal to delete the cookies displayed in the main title one by one or all at once:

For other browsers, you can review your browser’s help or support pages.

In addition, you can visit the following pages or use the ‘’Privacy Badger’’ application to be informed about all cookies and to manage cookies:

•https://www.allaboutcookies.or

•https://www.youronlinechoices.eu/

•https://www.youradchoices.com/

Blocking or deleting the ‘’necessary cookies’’ to ensure the technical functionality of the site used on our company website may affect or even prevent the use of these sites.

Matters to be Considered Per the Law No. 5846 on Intellectual and Artistic Works and Law No.5651 on Regulation of Publications on The Internet and Combating Crimes Committed By Means of Such Publications

The User(s) accept(s) and declare(s) that there may be links on the website allowing access to another website or content, the control, accuracy, or adequacy of these is not related to the COMPANY and the COMPANY does not support these sites in any way or guarantee the accuracy of the information contained on these sites and does not assume any responsibility for the contents contained in these sites, and the COMPANY or any group company or their employees, managers, authorized persons or institutions has no any legal or penal responsibility for the use of these sites and/or their contents or the results of decisions taken based on these contents, and for material or immaterial, positive or negative or possible damages or expenses s/he has suffered since s/he has not read the terms of use of the website or has read but not acted under these terms, and that the COMPANY has not guaranteed the accuracy and/or adequacy of the information given on the website.

The User(s) accept(s) and declare(s) that there may be any text, information, comments, opinions, news, images, pictures, figures, charts, and other materials belonging to the COMPANY or a third party or organization on the website and the COMPANY has legal rights related to these materials per the Law on Intellectual and Artistic Works and these cannot be copied, modified, reproduced, published, sold or let somebody use or intervened to these without consent of the COMPANY.

All logos, trademarks, and corporate emblems published on this site are protected under the provisions of Decree-Law No. 556 on the Protection of Trademarks. The logos cannot be copied or used in any way. The User(s) accept(s) and declare(s) that the COMPANY or any affiliate group company or their employees, managers, authorized persons, or institutions have no legal or penal responsibility for the use of any information to be obtained due to the inclusion of the COMPANY logo or the pages of the website on another website in any way, or any content uploaded to the website by third parties or visitors, or any content that does not result in the use of the internet within the framework of general practices.

The COMPANY has the right to change, renew or cancel any article of the Terms of Use and Cookie Policy on the http://www.qurabiye.com website without notice. Any provision changed, renewed, or canceled will take effect for all users at the date of publication.

Type of Cookie	Function of Cookie	Explanation of Cookie In Terms of Data
Mandatory	These cookies are required for the Websites to function properly, and they enable you to browse our sites and utilize the site features. An example of this is remembering previous actions (e.g. text input) when returning to a page within the same session.	These cookies do not identify you. If you do not accept these cookies, the performance of the website or parts of the site may be affected.
Performance	These cookies help us to understand how visitors interact with our website by providing information on issues such as areas visited, time spent on the site, and error messages encountered. This enables us to improve the performance of our website.	These cookies do not identify you. All data is taken and aggregated anonymously.
Functionality	These cookies enable our websites to remember your preferences (e.g. your username, the region you are in, or the language you use) for a more customized online experience. Cookies also enable visitors to watch videos, play games, and use social tools such as blogs, chat rooms, and forums.	The information that these cookies collect may include confidential data that can identify you, such as your username or profile picture. We must always be transparent about what data we collect, what we do with that data, and who we share it with. If you do not accept these cookies, the performance and functionality of the website may be affected and some content on the website may not be accessible.
Targeting Advertising	These cookies are used to deliver content that is close to you and your interests. They can be used to serve targeted ads or to limit the number of times an ad is displayed to you. We may use these cookies to remember the websites you visit and share this information with third parties, including advertisers and our own companies.	Many types of these cookies can collect personally identifiable information by tracking consumers with their IP addresses. For detailed information on the data collected and how this data is used, visit the Targeting/Advertising section below.

References

U.D.P

Terms of Use

Privacy Policy

Cookies Policy

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