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1. PREAMBLE

İHKİB (Istanbul Apparel Exporters’ Association), with its address at Yenibosna Merkez Mahallesi, Sanayi Cad. No:3 Dış Ticaret Kompleksi B Blok P.K.34197 Bahçelievler / İSTANBUL (“İHKİB” or “We”) respect your privacy, whether you are a İTKİB client, one of our client’s clients or users, or simply an individual visiting our website, and we are committed to protecting your privacy through our compliance with this policy. The use of personal information collected through our services shall be limited to the purpose of providing the service for which our clients have engaged İTKİB. Our servers are at this time located in the Turkey (Istanbul) & Germany (Frankfurt) and operated by Sirius Interactive (sirius.com.tr). This policy describes our practices in connection with information that we collect through our websites (collectively, our “Websites”), through our platform (collectively, our “Platform”), as well as through email messages that we send to you (collectively, including the Websites and the Platform, our “Services”).

This policy also applies to information about you that we collect or receive:

In e-mail, text and other electronic messages between you and İTKİB.
When you interact with our advertising and Platform on third-party websites and services.

It does not apply to information collected by:

Any third party, including through any third-party application or content (including advertising) that may link to or be accessible from our Services. Please read this policy carefully to understand our policies and practices regarding the collection of information about you, whether via our Websites, Platform, or from other sources, and how we will treat it. If you do not agree with our policies and practices, you may choose not to use our Services.

2. DATA COLLECTION – GENERAL REMARKS

The data collection plays an important role in the İTKİB event planning. İTKİB and event managers can collect personal data about the people who attend their events and they – as well as İTKİB - can customize the event experience, as well as future products and Services. In this context our Clients as event planners are data controllers, since they collect and control the personal data of their Clients, in this case, event attendees. As data controllers, event planners must be in compliance with GDPR and they are responsible for taking steps to ensure the personal data you hold is accurate and up to date. Furthermore, the event planners should have implemented measures to maintain accuracy and taken reasonable steps to erase or rectify any inaccurate personal data. İTKİB processes the data owned by the event planner and you.

İTKİB as a data controller and a data processor

EU and Republic of Turkey data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.

İTKİB may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances. In most cases, we are the data processors, and the event organizer is the data controller.

Data Controller

For example, if you use your account with us to create events as an event organizers, İTKİB will be a data controller in respect of the Personal Data that you provide as part of your account. We will also be a data controller of the Personal Data that we have obtained about the use of the Applications or Properties, which could relate to Organizers or Attendees. We use this to conduct research and analysis to help better understand and serve Users of the Services as well as to improve our platform and provide you with more targeted recommendations about features we think may be of interest to you.

Data Processor

However, if you are imported as an Attendee, we will process your Personal Data to help administer that event on behalf of the Organizer (for example, sending confirmation, promotional and feedback emails, processing payments, etc.) and to help the Organizer target, and understand the success of, their event and event planning (for example, providing event reports, using analytics to gain insights into the effectiveness, etc.). In these circumstances, we merely provides the “tools” for Organizers; we do not decide what Personal Data to request on questionnaire forms, nor is it responsible for the continued accuracy any Personal Data provided. Any questions that you may have relating to your Personal Data and your rights under data protection law should therefore be directed to the Organizer as the data controller, not to İTKİB.

3. CLOUD

At this time İTKİB uses Cloud Services from Google, AWS, DigitalOcean. In terms of data protection, cloud computing means the processing of personal data on behalf of the İTKİB as cloud user through the cloud provider. The GDPR (Article 28) requires that the cloud user only chooses cloud providers that provide reasonable guarantees for proper technical and organizational measures. Google complies with data processing and security conditions and act for us as a processor of personal data under the GDPR. Google provides its clients with updated contract terms in accordance with the new requirements of the GDPR.

4. İTKİB PLATFORM

Our İTKİB Platform allows any Client that uses it (our Clients and İTKİB itself) to build event sites and manage events. This can include collecting contact information and other demographic information from Visitors or Clients who are participating in events. İTKİB provides the Platform to our Clients to manage their events or to find events, and we use it to run our Services.

5. USE BY OUR CLIENTS

Our Clients use the Platform to build event sites and manage events. İTKİB does not control the content of event sites or the types of information that our Clients may choose to collect or manage using our Platform. That information belongs to them and is used, disclosed and protected by them according to their own privacy policies and is not subject to this Privacy Policy. İTKİB processes our Clients’ information as they direct and in accordance with our agreements with our Clients, and we store it on our servers, but we do not have control over its collection or management. Our agreements with our Clients prohibit us from using that information, except as necessary to provide and improve the Platform and our Services, as permitted by this Privacy Policy, and as required by law. İTKİB might have no direct relationship with individuals who provide Personal Information to our Clients. Our Clients control and are responsible for correcting, deleting or updating information they have collected from you using the Platform. İTKİB may work with the Clients to help them provide notice to their visitors about their data collection, processing and usage. İTKİB is not responsible for the Clients’ use of information they collect on the subscription service.

6. PUBLIC FORUMS

İTKİB offers publicly accessible message boards and community forums. Please keep in mind that if you directly disclose any information through such public message boards or forums, this information may be collected and used by others. İTKİB will correct or delete any information you have posted on the Platform if you so request.

7. LOG FILES

İTKİB may collect demographic information, such as your ZIP code, age, gender, preferences, interests and favorites using log files. There may also be information about your computer hardware and software that is automatically collected by us. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by İTKİB for the operation of the Platform, to maintain its quality and to provide general statistics regarding use of the Platform. For these purposes, İTKİB may link this automatically-collected data to personal information such as name, email address, address, and phone number.

YOUR PRIVACY CLASSIFICATION This policy classifies those accessing and using our Services as one of the following:
VISITORS: Individuals and entities that access and interact with our Websites (for instance, to read about İTKİB products and services, downloads), as well as those whom we meet or learn about through referral, from third parties or other external sources, are referred to as “Website Visitors” or simply “Visitors”. Personally identifiable information pertaining to Visitors subject to this policy is maintained in one or more İTKİB databases and Website analytics and management systems where Platform end-user information is maintained.
CLIENTS: Individuals and entities that are İTKİB’s direct clients (for example, event planners), including individuals attending İTKİB events, as well as client personnel that are assigned a login ID and are authorized to access and use our Platform pursuant to an active İTKİB agreement or under a temporary evaluation license if available, are referred to as “Clients.” Personally identifiable information of Client personnel associated with their Platform accounts is treated as End-User information, and will not be used for any purpose other than providing and supporting our Platform.
END-USERS: Clients’ business contacts, which may include their own current and prospective clients, members, partners, or other third-party contacts that use our Platform to interact with our Clients (for example, individuals that register for an event organized by a Client, download an event-related mobile app) are referred to as “Platform End-Users” or simply “End-Users.” İTKİB does not use personally identifiable information of End-Users for any purpose other than providing and supporting the Platform.

8. INFORMATION WE COLLECT AND HOW WE COLLECT IT

İTKİB, and our Clients that use our Platform to organize and manage events or to provide other services, may collect several types of information from and about End-Users, including:

“Personal Information” that identifies an End-User as an individual or relates to an identifiable person. For example, this includes name, organization, title, postal address, e-mail address, telephone number, fax number, social media account ID or other identifiers by which End-Users may be contacted online or offline. This also may include information that permits End-Users to purchase products or services from İTKİB or from our clients through the Platform, such as credit or debit card number, or other payment account number, as well as applicable expiration dates and billing/shipping addresses;
“Other Information” that does not reveal a person’s identity or directly relate to an individual, on its own or in combination with other information we have collected, such as browser and device information, operating system, device type, system and performance information, usage data, information collected through cookies, pixel tags and other technologies, general geographic location, demographic information and other information provided by a person, such as dietary preferences, interests, activities, age, gender, education and occupation.

We collect this information:

Directly from individuals when they provide it to us.
Automatically from End-Users as they use the Platform, or from Website Visitors as they navigate through the Websites, using technologies described in “Third Party Advertisers and Analytics.” Information collected automatically may include browser and device information, details regarding use of the Services, IP addresses and information collected through cookies, web beacons and other technologies.
From third party sources, such as public databases, joint marketing partners, and social media platforms. For example, if a Website Visitor elects to connect his social media account to his account for our Websites, certain Personal Information from the social media account will be shared with us, which may include Personal Information that is part of the Visitor’s profile or his friends’ profiles.

The information we collect through our Services may include:

Information that a person provides when utilizing one of our Services, for instance at the time an End-User registers to attend an event being organized by a İTKİB client (İTKİB Event Registration).
Information that Website Visitors provide by filling in forms on our Websites and Platform. This includes information provided at the time of registering to receive product information, attend events, or access other special content on our Websites.
Information that Clients and End-Users provide when receiving technical or client account support. This includes records and copies of Client and End-User correspondence (including e-mail addresses).
Details of transactions Clients carry out through our Platform and of the fulfillment of Client orders.

Some of our Websites or Platform allow Visitors to create or post content on message boards, chat, profile pages and blogs and other services to which Visitors are able to post information and materials. Please note that any information posted or disclosed through these sections of our Websites or Platform might become public information and may be available to other Visitors and to the general public. We urge caution to anyone deciding to disclose their Personal Information, or any other information. Anyone submitting Personal Information relating to other people to İTKİB in connection with the Services represents that they have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

9. HOW WE USE INFORMATION

We may use information that we collect or that is provided to us, including Personal Information, for any of the following purposes:

To present our Services and their contents.
To provide End-Users with information, products, or services they request from İTKİB or our Clients using our Platform, for example by processing event registrations, enrolling End-Users in programs in which they choose to participate or providing End-Users with access for a meeting organized by a Client.
To manage Platform accounts, provide client service, and process payments for purchases by End-Users.
To provide Clients with notices about their İTKİB accounts, including expiration and renewal notices.
To notify Clients and End-Users about changes to our Services, any products or services we offer or provide though our Services, our terms and conditions applicable to the Services, or this Privacy Policy.
To communicate with Clients and Visitors by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest and that are offered by us or other third parties, but only upon request.
To allow Clients and Visitors to participate in online products, access and download materials, and use other interactive features on our Services.
To better tailor Website and Platform experience to Visitors interests, Platform experience to End-User or Client interests, and display content according to user preferences.
To facilitate social sharing functionality.
For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, and operating and expanding our business activities.
As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes; (e) to protect our operations; (f) to protect our rights, privacy, safety or property, you or others; (g) to allow us to pursue available remedies or limit the damages that we may sustain; and (h) to protect against or identify fraudulent transactions. This includes exchanging information with other companies and organizations where reasonably necessary for the purposes of fraud protection and credit risk reduction.
In any other way we may describe when you provide the information.
To fulfill any other purpose for which you provide it or with your consent.

We may also use contact information of Clients and Visitors to contact them via email, telephone or direct mail about products and services that may be of interest to them, if contact information was provided for that purpose. Where required, we will seek and obtain recipients’ express authorization before we send marketing emails. If you do not want us to use your information in this way, please adjust your email preferences on the profile page.

DISCLOSURE OF YOUR INFORMATION We may disclose aggregated information about users and the use of our Services, and information that does not identify any individual, without restriction. If you choose to use our Services to transact business with Clients (for example, register for an event), any information you provide in connection with that transaction will be transferred to, and under the control of, the Client. Clients will also have access to information (including Personal Information and Application usage data) related to how End-Users interact with the Platform that they use to organize and manage meetings and events. Although our own use and disclosure of your information will be in compliance with this Privacy Policy, İTKİB cannot and does not take responsibility for the privacy practices of Clients, even if we make sure that Clients guarantee compliance with applicable data protection laws.

We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:

To our contractors, service providers, and other third parties as reasonably necessary or prudent to provide, maintain and support our Services, such as, for example, payment processors, data analytics providers, and data center or Web hosting providers.
To a third party in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of İTKİB’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by İTKİB about our Website Visitors, Clients and End-Users is among the assets transferred.
To fulfill the purpose for which information is provided. Here are some examples:
If End-Users provide an email address when registering for an event, we will use the e-mail address to send the End-User information and announcements relating to that event.
If End-Users utilize one of our Platform to pay for event registration fees or other products and services using their credit cards, we will pass the credit card information to payment card processors to validate the payment information and complete the transactions.
To your friends associated with Visitors’ social media accounts and to Visitors’ social media account providers, in connection with social sharing activity, such as if a Visitor connects her social media account to her Website profile.
As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to carry out our obligations and enforce our terms and conditions applicable to the Services and other agreements, including for billing and collection purposes; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, our clients, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. This includes exchanging information with other companies and organizations where reasonably necessary for the purposes of fraud protection and credit risk reduction.
For any other purpose disclosed by us when you provide the information or with your consent.

10. THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services or this Policy link. The inclusion of a link on the Services or within this Policy does not imply endorsement of the linked site or service by us or by our affiliates. Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, or any other company, social media platform providers, operating system providers, wireless service providers or device manufacturers, including any Personal Information you disclose to other organizations through or in connection with the Platform, even though we have data protection agreements with our contractors, if necessary.

11. COOKIES AND SIMILAR TECHNOLOGIES

We and our partners may use cookies, token or similar technologies as you navigate through and interact with our Websites, our Platform, and with third party websites or other online services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including: - Details of your visits to our Services, such as the date and time you access our Services, length of time you spend on our Services, websites you visited before or after our Services, the resources and content that you access and use on the Services, and whether your interaction with our Services results in your requesting information about İTKİB or making a purchase. - Information about your computer and internet connection, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, language, Internet browser type and version and the name and version of the Services (such as the Application) you are using. The technologies we use for this automatic data collection may include: - Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access or receive certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites or receive our Services. For more information about cookies and how to disable them, see www.allaboutcookies.org.

Session Cookies and Persistent Cookies. A “session” cookie lasts for a single browser session only and is deleted when the user closes the web browser. A “persistent” cookie remains on the user’s device (even while powered off) until it expires or is deleted. A persistent cookie will be reactivated when a user returns to the website which posted the cookie. Cookies cannot read or access other cookies or any data from a user’s hard drive. Cookies alone will not personally identify a user; however, a cookie may recognize a user’s individual web browser or device through an IP Address, browser version, operating system and other information, and End users of our Services who log into their İTKİB accounts may be individually identifiable to particular Services using session cookies.
Flash Cookies. Certain features of our Services may use local storage, such as “Flash cookies” to collect and store information about your preferences and navigation to, from and on our Websites. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages on our Services and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs). Web beacons differ from cookies in that the information is not stored on your hard drive, but invisibly embedded on web pages or in email. Web beacons permit us to track online movements of web users – for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). This enables İTKİB to provide a website experience more tailored to your preferences and interests.
Log files: For technical reasons (security reasons and protection of our Website), İTKİB collects server log data which are received from your browser. The log data are deleted after 14 days.
Advertising and analytics. When you access and use the Services and other websites, we or a third-party partner may serve you advertisements regarding goods and services that may be of interest to you (or in some cases, to users who our service providers deem to have characteristics similar to our Clients) based on information relating to your access to and use of the Services and other websites. To do so, we or our service providers may place or recognize a unique cookie on your browser (alone or in conjunction with web beacons, pixel tags or other tracking technologies).
We also may use information associated with Visitor social media accounts.

We use third party analytics providers, including Google Analytics and others, to collect information about your use of the Services and enable us to improve how the Services work. The information allows us to see the overall patterns of usage on the Services, helps us record any difficulties you have with the Services, shows us whether our advertising is effective or not, and allows us to use responses to advertisements to optimize ad performance. Google Analytics use cookies and other, similar technologies to collect information about the Services use and to report website trends to us, without identifying individual End-Users or Visitors to us.

12. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You may set your web browser to restrict or to entirely block cookies, to configure cookie notification settings and/or to delete cookies already present on the browser or device. Visitors who block cookies may be able to access a Website but will not be able to use most of the content, Platform and services available on that site. Limiting or restricting certain types of cookies may also prevent a Client or End-User from using certain portions of the Platform, depending on how the browser settings are configured.
Promotional Offers from İTKİB. If you do not wish İTKİB to use your contact details to send you promotional messages, or would like us to prevent a Client from using the Platform to send you emails to promote its own or third parties’ products or services, you can (i) adjust your email preferences on the profile page, or (ii) at any other time by sending an email stating your request to us. We will try to comply with your request(s) as soon as reasonably practicable. Please also note that if you, as a Website Visitor or Client, opt-out of receiving marketing-related emails from us (or as an End-User opt-out of receiving marketing-related emails from one of our Clients), we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

13. ACCESSING AND CORRECTING YOUR INFORMATION

Upon request, İTKİB will provide you with information about whether we hold any of your Personal Information. If you are a registered user of one of our Services, you can review, request deletion, and change your Personal Information by logging into the Services and visiting your account profile page. For example:

Users of our Platform may update or correct their Personal Information, other profile settings and user preferences.
Users who have opted to join an event attendee list (visible to other users for that event) may have the option to later hide themselves from the list if desired.
You may also send us an e-mail to request access to, correct or delete any Personal Information that you have provided to us. In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information that you have provided to us suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information that you have provided to us. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will respond to your request within a reasonable timeframe. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Please note that we may need to retain certain personal information for the period of time necessary to fulfill the purposes outlined in this Privacy Policy, including, for example, record keeping purposes (7 years), including but not limited to completing any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase, you may not be able to change or delete the Personal Information provided until after the completion of such purchase), or to comply with applicable laws. There may also be residual information that will remain within our databases and other records, which will not be removed.

14. CROSS-BORDER TRANSFERS (OTHER THAN TO THE E.U. OR REPUBLİC OF TURKEY)

Although Services are controlled and operated by us from Republic of Turkey, by using the Services you consent to the transfer of information to countries outside of your country of residence, which may have different data protection rules than those of your country, if we need such third country contractors to fulfil our contractual duties.

15. DATA SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.

16. INFORMATION COLLECTED ON BEHALF OF OUR CLIENTS

İTKİB collects information under the direction of its clients and has no direct relationship with the End-User individuals whose Personal Information it processes. If you are an End-User of one of our Clients and would no longer like to be contacted by one of our Clients that use our Service, please contact the Client that you interact with directly. We may transfer Personal Information to companies that help us provide our Service. Transfers to subsequent third parties are covered by the service agreements with our Clients. Please note that Clients may have their own / additional Terms and Services, which you have to comply with.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Information should direct his query to İTKİB’s Client (i.e., the data controller). If requested to remove Personal Information we will respond within a reasonable timeframe.

We will retain Personal Information we process on behalf of our Clients for as long as needed to provide services to our Client. İTKİB will retain this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

17. CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by means of a notice on this Website or our Platform within a reasonable timeframe prior to the changes becoming effective, or by email (sent to the e-mail address specified in your account). We encourage you to periodically review this page for the latest information on our privacy practices.

18. CONTACT INFORMATION

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: İTKİB Privacy Representative [email protected] Please note that email communications are not always secure; so please do not include credit card information or sensitive information in your emails to us.

19. COMPLAINTS

You have at any time the right to revoke your consent to the use of your personal data. Your request for information, deletion, correction, or data transfer, unless this is a disproportionate effort, shall be addressed to us immediately. We will be happy assisting you with your query.

If you believe that the processing of your personal data by us violates the applicable data protection law or your data protection claims have been violated in another way, it is possible to complain to the competent supervisory authority. In Republic of Turkey, the data protection authority is responsible for this.