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Privacy Policy

This privacy policy together with Appendix A (“Privacy Policy”) sets out how and why we collect, store, use, transfer and disclose your personal data (also referred to as personal information in this Privacy Policy) and how you may access your personal information and correct it. This Privacy Policy also explains the use of cookies on our Site. For the avoidance of doubt, “personal data” or “personal information” means information that specifically identifies an individual (such as a name, address, photo, telephone number, mobile number, e-mail address, birthday, office location, professional and personal interests, company name, title department, and spoken languages) or information about that individual that is directly linked to personally identifiable information. “Site” means https://www.Onlineavm.com.tr/ and all subpages and subdomains related to https://www.Onlineavm.com.tr/ and any additional website domains as determined by Onlineavm.com.tr from time to time”User”, “you” and “your” collectively mean the person, company, or organization that has visited or is using the Site. A user may be a visitor of Onlineavm.com.tr or an Account holder. “Account” means the account that users may create through the Site.



For the purposes of the data processing and control, the relevant legal entity is Onlineavm.com.tr. Our contact email address for any communications regarding your personal data is [email protected] (please include “personal data” in the email subject).

GDPR
If you are a resident of the European Union, you are protected by, and enjoy additional, rights under the European Union’s General Data Protection Regulation 2016/679, also known as GDPR.

Changes to Privacy Policy
We may change our Privacy Policy from time to time, and at our sole discretion. Although we will use our best endeavours to notify you of any amendment to this Privacy Policy, we will not be required to provide you with prior notification of such amendments or changes to this Privacy Policy. We encourage you to frequently check our Site for any changes to our Privacy Policy.
Your continued use of our Site, services, requesting our assistance or the provision of further personal information to us (directly or via an authorised person) after any change in this Privacy Policy will constitute your acceptance of such change.

What data do we collect?
Like most website operators, we collect non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request.
We collect non-personally identifying information to better understand how our visitors use our Site. The information collected will also help us troubleshoot problems, analyse our resources and improve our services and/or products. There is nothing in that kind of information that could enable anyone to identify who you are.
We also collect potentially personal information including:

   your name
   your contact information including your email address
   your demographic information including preferences and interests
   other information relevant to customer surveys and/or offers
   Internet Protocol (“IP”) addresses
   cookies. For the complete list of cookies we collect see the List of cookies we collect section.

How do we collect personal data?
We collect personal information in a number of ways, including:
   when you or a third-party contact us independently of our Site, such as by email, phone or in person
   when you visit and interact with our Site and related software (including any mobile applications)
   when you engage in transactions with us
   when you sign up for an Account with Onlineavm.com.tr or become a part of the Onlineavm.com.tr affiliate programme
   through cookies and other technologies that allow us to give you a better experience on our Site
   when you contact us via our Site or sign up for our newsletter/mailing list
In each case, we collect such personal information only insofar as is necessary or appropriate to fulfil the purpose of your interaction with us. We do not disclose personal information other than as described below in this Privacy Policy.
You may refuse to supply personal information, however this may prevent you from engaging in certain Site-related activities and we may not be able to provide our services and/or products or assistance to you or on your behalf.
You must not provide us with the personal information about another person unless you have first obtained that person's prior consent to do so and you have told them their personal information will be handled in accordance with this Privacy Policy (including where to find it). By providing us with information about any third party individual, you hereby warrant and represent that you have all necessary consents and permissions to do so, and that you can provide proof of the same to us.
We will not sell, distribute or lend access to your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you have given us permission for this to happen.
If you have previously given us permission to use your personal information for direct marketing purposes, you may change your mind at any time by writing to us at [email protected].



Consent



This Privacy Policy applies to the Site you are currently viewing. By clicking on the “Accept” button or accessing or otherwise using the Site, you acknowledge that you have read, understood, and irrevocably, and without condition, agree with this Privacy Policy and any other agreements that apply to you as a Onlineavm.com.tr’s Account holder or user, as amended from time to time. If you do not agree with this, you must stop using or accessing the Site immediately. If you are using the Site on behalf of a third party including, but not limited, to a business entity, you warrant that you are authorized and have the authority to bind that third party to this Privacy Policy. By clicking on the “Accept” button or accessing or otherwise using the Site, you also acknowledge that you consent to your personal information being collected, used and disclosed as set out in this Privacy Policy. This Privacy Policy should be read in conjunction with our Terms and Conditions available at https://www.Onlineavm.com.tr/terms-conditions.
 
You consent to us posting and using any photographs, content and/or personal information you might upload on our Site or have otherwise provided consent to publish on our Site, blog, in our marketing material or social media channels, which we may use in order to provide information on our services and/or products, the marketing of our services and/or products or for the purpose of our functions and/or activities.



Purpose



We collect your personal information to enable you to receive the benefit of our Site and services and/or products. Subject to this Privacy Policy, we may use your personal information for the following purposes:
   to carry out our obligations and to provide you with agreed services and/or products
   to establish, maintain and administer your Account
  to send you service and/or product or promotional communications and marketing material that is relevant to you to promote     and market our services and/or products and our Site and those of third parties (including any social media pages maintained or      operated by us such as Facebook, Instagram, Snapchat, Twitter, YouTube)
   to notify you about changes to our services and/or products
   quality assurance and training
   improving our products and services, including site customisation
   to verify your identity or location, and make security checks, in relation to a purchase
   to access third-party development platforms or add-on keys
   market research and analysis
   to promote and market our services and/or products (including via any social media pages maintained, or operated, by us such as      Facebook, Instagram, Snapchat, Twitter, YouTube, Twitch, and Mixer)
   internal record-keeping to facilitate any other Purpose
 any other uses identified to you at the time of collecting your personal information or as reasonably contemplated by this     Privacy Policy and our https://www.Onlineavm.com.tr/privacy-policy

Disclosure of your personal information
We may disclose your personal information to other entities or individuals for the Purposes including but not limited to:
   our employees, trusted third parties and other people we work with to provide services and/or products to you
  third party service providers for the purpose of enabling them to provide a service such as (but not limited to) IT service      providers, data storage, web-hosting and server providers, debt collectors, payment processing and insurers
   any third-party partners or entities with whom we have a commercial relationship
   any related entity of ours
   prospective sellers or buyers of our business or assets
  any applicable or relevant regulator or third party for the purpose of legislative or contractual compliance and/or reporting or     when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, those of third parties or      the public at large
   other entities or individuals, provided you have given your consent

Accessing your personal data
To the extent required by law, you may review, edit, correct or delete any personal information you submit to us.
On request we will, as soon as reasonably possible, provide you with:
   personal data about you that is in our possession or under our control
   information about the ways in which the personal data referred to in paragraph above (Disclosure of your personal information)      has been or may have been used or disclosed by us during the year preceding the date of the request
If you are subject to protection under EU law (including all residents in the EU), you may be entitled to further rights.
We reserve the right not to provide you with your personal data or other related information if providing it could reasonably be expected to:
   threaten the safety or physical or mental health of another individual
   cause immediate or grave harm to your safety, physical or mental health
   reveal personal data about another individual
  reveal the identity of an individual who has provided personal data about another individual and the individual providing the      personal data does not consent to the disclosure of his identity
   be contrary to the national interest
If you wish to access the personal information we hold about you, you should contact us on [email protected], as described above, and we will respond to your request within a reasonable period after the request is made. If we deny you access, we will provide our reason for doing so at the time of your request.
While we do not charge a fee for a request for accessing your personal information, we may charge a reasonable fee (which will be notified to you once you make a request) for time and cost in the following circumstances:
   if an extended amount of time is required to collate and prepare material for you
   if you wish to have your files photocopied for you

Correcting and updating your personal information
Please contact us on [email protected] as soon as possible if there are any changes to your personal information or if you believe the personal information we hold about you is not accurate, complete or up-to-date so that we can update your file accordingly.
We will process any requested changes as soon as practicable and send the corrected personal data to every other organisation to which the personal data was disclosed, during the year preceding the date of the correction, unless that other organisation no longer needs the corrected personal data for any legal or business purpose or you otherwise agree that we do not need to resend the corrected information to any other organisation.

Accuracy
We take reasonable steps to ensure that the personal information we hold about you is accurate, complete and up-to-date. However, we primarily rely on you to advise us of any changes to your personal information. By accepting this Privacy Policy, you hereby undertake to use all reasonable endeavours to provide corrections and updates of your personal data in a timely manner.

Retention of personal data
We will use all reasonable endeavours to cease to retain documents containing personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that the Purpose for which that personal data was collected is no longer being served by retention of the personal data, or retention is no longer necessary for legal or business purposes.

Transfer of data
We will not transfer any personal data to a country or territory outside United Arab Emirates, except in accordance with the requirements prescribed under the laws of United Arab Emirates to ensure that organisations provide a standard of protection to the personal data transferred that is comparable to the protection under the laws of United Arab Emirates and this Privacy Policy.

Security
We take reasonable steps to ensure that your personal information is treated securely and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
To prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online. In order to minimise the likelihood of security breaches, we do not publicly disclose the nature of such security measures.
Although we aim to create a safe, secure environment by trying to limit access to the Site to legitimate users, we cannot guarantee that unauthorised parties will not gain access. To the extent permitted by applicable law, we expressly exclude any liability arising from any unauthorised access to your personal information.
Please contact us on [email protected] immediately if you become aware of any unauthorised use of your Account by anyone else or any other breach of security.

Cookies
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our Site in order to tailor it to customer needs. We only use this information for statistical analysis purposes, after which the data is removed from the system.
Cookies help us to provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Many web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You should note that this may prevent you from taking full advantage of the Site and its associated services.
We do or may use the following cookies:
    Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies       that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.
   Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move      around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are       finding what they are looking for easily.
    Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content       for you, greet you by name and remember your preferences (for example, your choice of language or region).
    Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We      will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share      this information with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
If you do not wish to have cookies placed on your computer you should set your browsers to refuse cookies before using our Site, with the drawback that certain features of our Site may not function properly without the aid of cookies.
The table below lists the cookies we collect and what information they store.
Business transfer

If we, or substantially all of our assets, were acquired, or in the event that we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge and agree that if such transfers occur, that any acquirer of our business may continue to use your personal information as set forth in this Privacy Policy.



Use of personal information for direct marketing
From time to time, we may use the personal information we collect from you to identify particular services and/or products that we believe may be of interest to you. We may then contact you to let you know about these services and/or products, new features and how they may benefit you, solicit your feedback, or just keep you up to date with what's going on with us and our services and/or products.
Direct marketing from us generally takes the form of an electronic marketing email. Where we use your personal information to send you marketing information by email, SMS, MMS or other electronic means we may do so with your express or deemed consent. Every directly addressed marketing contact sent or made by us will include a means by which you may unsubscribe (or opt out) of receiving further marketing information. Additionally, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us. Contact us on [email protected] to make a request.



Links to third party websites
Our Site may contain links to and from third party websites. If you click on such links, you do so at your own risk and subject to whatever privacy policy and/or website terms may govern the use of such websites.
We have no control over, and are not responsible, nor liable for, the content, privacy practices or website terms of such websites or any information you provide to them. You should read the privacy policy of these third parties to find out how they handle your personal information when you visit their websites.



Privacy complaints
If you believe that we have breached your privacy rights in any way, or you would like to discuss any issues about our Privacy Policy, please contact us on [email protected]. All such enquiries or complaints will be taken seriously and will be handled as soon as reasonably practicable.
APPENDIX A
ALTERNATIVE CLAUSES/ADDITIONAL CLAUSES

1.More detailed background on data collection
Information we collect, and how we do it
We collect information, both general and personal, in a number of ways, as detailed in this Privacy Policy. In the case of personal or personally-identifiable information, we collect information only insofar as it is, and remains, necessary to fulfil the purpose of your interaction with us. We collect and store information using a number of technologies such as cookies, caches, databases, and logs. We do not use or disclose personal information other than as described in this Privacy Policy.
You may refuse to provide us with personal information, and you may object to our collection of information; however, this may impact your ability to use or benefit from our Site, platforms, apps, products, and/or services, and our ability to provide you with support or assistance.



Information you provide, content you create, and files you upload
When you create an Account on our Site and other affiliated platforms, including any mobile applications, you provide us with personal information that includes your name, email address, phone number, and a password.
Even if you do not create an Account, you may opt to provide us with personal information for specific purposes. For instance, you may provide us with an email address to receive marketing material or updates about our services or a phone number so that we may call you back about a customer inquiry.
We also collect content that you create, upload, or receive from others when using our Site and other platforms. This includes comments as well as orders, invoices, sites and documents you generate.



Information we collect about your browser and devices
While you use our Site and other platforms, we collect general information of the sort that web browsers, servers and network operators typically make available, such as unique identifiers (e.g. persistent cookies, MAC addresses, device IDs, IMEI numbers), browser type and settings, location data, device type and settings, operating system, IP address, mobile network information including operator name and phone number and application version number, language preferences, crash reports, system activity, and the date, time and referral URL of each visitor request.
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