Dear User, welcome to ARETE’s website at https://arete.com.tr.

These “Terms of Use and Privacy / Personal Data Protection Policy and Privacy Notice” set out the provisions governing the information and services provided to our valued users on our website.

The following definitions are important for the use of ARETE’s website at https://arete.com.tr.

Accordingly:

User/Users: Natural persons who either become members of the site by providing the information requested in the contact forms with their explicit consent, or who merely visit the site without providing personal data.

Personal Data: Any information relating to an identified or identifiable natural person.

Processing of Personal Data: Any operation performed on personal data, whether wholly or partly by automated means or otherwise than by automated means as part of any data filing system, such as collection, recording, storage, retention, alteration, re-organization, disclosure, transfer, acquisition, making retrievable, classification, or restriction of use.

Site: The website located at https://arete.com.tr.

Law No. 5846: The Law on Intellectual and Artistic Works (“FSEK”).

Law No. 5651: The Law on the Regulation of Publications on the Internet and Combating Crimes Committed Through These Publications.

Law No. 6698: The Personal Data Protection Law (“KVKK”).

---

TERMS OF USE

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

1. The website https://arete.com.tr and all documents on the site are the property of ARETE. These documents may not be copied or reproduced, except as necessary for viewing on the on-line system. Notwithstanding the foregoing, you may print pages of the site for your personal use. Independent of the general principle stated above, ARETE may provide the option to download wallpapers, screensavers, and other programs from the site. Any legal liability arising from any use that infringes the intellectual and industrial property rights related to the documents on this site belongs to the user.
2. Although ARETE has taken measures within available means to ensure that the website is free from viruses and similar malicious software, the user is responsible for procuring their own virus protection system and providing the necessary protection to ensure ultimate security. In this context, the user accepts that they are solely responsible for any errors that may occur in their own software and operating systems due to accessing https://arete.com.tr, and for any direct or indirect consequences thereof.
3. All prices, information, images, descriptions, and news (briefly “information”) on the website https://arete.com.tr are for promotional and informational purposes only. The user may not claim under any circumstances that the “information” on the website is incorrect or that they have suffered damage based on such information. The user accepts that when intending to take any action based on this information, they are obliged to obtain the final and reliable information from ARETE, and that ARETE bears no responsibility for any information on the website that is not up to date.
4. ARETE reserves the right, at its sole discretion, to change the content of the site at any time, to modify or terminate any service provided to users, and to delete user information and data registered on https://arete.com.tr. Although ARETE has taken every measure to ensure that the website is error-free, it does not provide any warranty regarding existing or potential errors on the site.
5. In the event of a criminal complaint or formal investigation request from official authorities directed at the user, and/or if it is determined that the user has carried out any electronic sabotage or attack that would prevent or alter the operation of ARETE’s systems, ARETE reserves the right to investigate the user’s identity information and to report it to the legal authorities.
6. For job applications submitted via the info ARETE email address (info@arete.com.tr), the data of applicants will be processed for recruitment purposes pursuant to the KVKK. Those who do not consent to the processing of their data should not submit job applications via this email. Persons submitting job applications shall be deemed to have consented to the processing of their data by ARETE.

It is ARETE’s responsibility to ensure the security of its website, all sub-sites, and other information systems. Scans aimed at identifying vulnerabilities that may exist in websites and other information technology systems for commercial, well-intentioned, or any other purposes, and activities such as exploiting identified vulnerabilities to damage systems or leak information, are illegal. In the event of such activities, sanctions may be applied pursuant to Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed Through These Publications. In the event of such attempts, ARETE reserves the right to initiate legal proceedings, together with the type of attack, time of attack, and data collected within the scope of the law regarding the attacker, and to demand penalties up to and including monetary fines or imprisonment.

7. In some cases, non-personal information may be collected. Examples of such information include the type of internet browser you use, your operating system, and the domain name of the site from which you reached our site via a link or advertisement.
8. When you visit the site, information may be placed on your computer. This information will be in the form of a cookie or a similar type of file and will assist us in several ways.

Cookies are used by ARETE to determine how you use the website / mobile application / mobile site, including from where and from which devices you connect to the e-commerce platforms operated by ARETE, what content you view on the website / mobile application / mobile site, and the duration of your visit.

ARETE also uses Google Analytics, a web analysis service provided by Google, Inc. (“Google”). Google Analytics uses cookies to analyze how visitors use the website / mobile application / mobile site through statistical information / reports.

For more information about the use of Google Analytics (including opt-out options), you may visit: https://www.google.com/intl/tr/policies/privacy/#infocollect

COOKIE MANAGEMENT

Depending on the type of your internet browser, you can obtain information about cookies and exercise your right to allow or refuse them by following the steps below:

Google Chrome: By clicking the “padlock” or “i” symbol in the “address bar” of your browser, you can allow or block cookies from the “Cookie” tab.

Internet Explorer: Click the “Security” tab from the “Tool” or “Tools” section in the upper-right corner of your browser, and manage your cookies by selecting “allow” or “do not allow.”

Mozilla Firefox: Click the “open menu” tab in the upper-right corner of your browser. Click the “Options” icon and manage your cookies using the “Privacy and Security” button.

For other browsers (such as Opera, Microsoft Edge), you can review the relevant browser’s help or support pages.

Safari: From the “Settings” section of your phone, select the “Safari” tab, and manage all your cookies from the “Privacy and Security” section.

In addition to the above options, to obtain information about all cookies and for cookie management, you may visit https://www.allaboutcookies.org or https://www.youronlinechoices.eu/, or you may use the “Privacy Badger” application (https://www.eff.org/tr/privacybadger).

For cookie or SDK management in mobile applications, you can follow the instructions in the Privacy or Settings section of your device, or you can download Lumen Privacy Monitor (https://haystack.mobi) to your phone.

If you refuse persistent cookies or session cookies, you can continue to use the website, mobile application, and mobile site, but you may not be able to access all functions of the website, mobile application, and mobile site, or your access may be limited. This situation may vary in mobile applications.

9. Matters to Be Considered Pursuant to Law No. 5846 on Intellectual and Artistic Works and Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed Through These Publications

The User/Users acknowledge and declare that the website may contain links providing access to another website or content; that the control, accuracy, or adequacy thereof has no relation to ARETE; that ARETE does not in any way endorse these sites or guarantee the accuracy of the information they contain; that ARETE has no responsibility for the content on these sites; and that neither ARETE nor any of its group companies, employees, managers, or authorized persons or organizations shall have any legal or criminal liability for any material or moral, positive or negative, or potential damage or expense arising from the use of these sites and/or content, or from decisions made based on this content, or due to the User/Users’ failure to read or comply with the terms of use of the site, and that the accuracy and/or adequacy of the information on the site is not guaranteed by ARETE.

The User/Users acknowledge and declare that the website may contain any text, information, comment, opinion, news, image, picture, figure, graphic, or other material belonging to ARETE or to a third party or organization; that ARETE has the legal rights regulated by the Industrial Property Law regarding such materials; and that these materials may not be copied, modified, reproduced, published, sold, or licensed, or interfered with, without ARETE’s permission.

All logos, trademarks, and corporate emblems published on this site are protected by the provisions of the Industrial Property Law and other relevant legislation. Logos may not be copied or used in any way. The User/Users acknowledge and declare that neither ARETE nor any of its group companies, employees, managers, or authorized persons or organizations shall have any legal or criminal liability arising from the appearance of the ARETE logo or pages of the website on another website in any way, or from the use of information obtained from any content uploaded to the website by third parties or visitors, or from any content that does not give rise to liability under general internet practices.

10. ARETE has the right to change, renew, or cancel any provision of the “Terms of Use” on the website https://arete.com.tr without notice. Each amended, renewed, or repealed provision shall take effect for all users on its publication date.
11. Applicable Law, Competent Courts and Enforcement Offices

These “Terms of Use and Privacy Notice” are subject to the laws of the Republic of Turkey. In the event of any dispute, controversy, claim, or demand regarding the matters set forth herein, the Istanbul Courts and Enforcement Offices shall have jurisdiction.

12. Final Provision

The User/Users irrevocably accept, declare, and undertake that they have read the above “Terms of Use and Privacy Notice” before accessing the website and that they will comply with all matters set forth above.

---

PRIVACY / PERSONAL DATA PROTECTION POLICY AND PRIVACY NOTICE

This “Privacy / Personal Data Protection Policy and Privacy Notice” sets out our policy regarding your personal data while providing services related to the https://arete.com.tr site.

This Privacy / Personal Data Protection Policy and Privacy Notice explains:

• What types of personal data ARETE collects,
• How this personal data is used,
• What your rights are regarding the personal data processed by ARETE and how you can exercise these rights, and
• Aims to inform and enlighten data subjects pursuant to Article 10 of the “Personal Data Protection Law” (KVKK) and the “Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform.”

1. Identity of the Data Controller

ARETE Bilgisayar Otomasyon Danışmanlık ve Eğitim Hizmetleri Sanayi Ticaret Limited Şirketi, registered with the Istanbul Trade Registry Office under registration number 540324-487906, with MERSIS number 0074040637300015, with headquarters at “İÇERENKÖY MAH. ÇAYIR CAD. ÖZCE CENTER NO:3 K:11 ATAŞEHİR/İSTANBUL.”

2. Personal Data Processed, Purpose and Legal Basis of Processing

In order to provide you with better service, and within the framework of legal obligations arising from Personal Data Protection Law No. 6698, Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed Through These Publications and related secondary legislation, Law No. 6563 on the Regulation of Electronic Commerce and related secondary legislation, Turkish Penal Code No. 5237 and related legislation; we request your personal data (name, surname, date of birth, mobile phone number, e-mail, gender, address, profession, education, marital status, vehicle license plate, information that the member consents to share through social media accounts when connected via those channels, navigation and click information on the application, and location information when the application is opened) that will enable us to fulfill the said purposes and legal obligations.

This personal data is processed, based on your explicit consent, for the following purposes: planning, monitoring, and developing processes related to the provision, sale, marketing, promotion, and after-sales support of products and services offered by our company; providing you with various advantages and personally suitable advertising, promotion, sales, marketing, event management, information, promotion, campaign notifications; designing and/or executing Customer Relationship Management (CRM) processes, loyalty programs, and membership processes; designing and/or executing advertising and/or promotional and/or marketing activities in digital and/or other channels; planning and/or executing corporate communication activities, customer relationship management processes, social responsibility and/or civil society activities, sponsorship activities; conducting surveys and customer satisfaction research and all kinds of communication for the purpose of providing services within this scope; ensuring the legal and commercial security of our company and persons in business relations with our company; job applications and human resources practices; and providing services within this scope, in compliance with the law and rules of good faith, accurately and where necessary up-to-date, for specific, explicit, and legitimate purposes, in a manner connected with, limited to, and proportionate to the purposes for which they are processed, and retained only for the period stipulated in the relevant legislation or required for the purposes of processing.

3. Method and Legal Basis of Personal Data Collection

Your Personal Data may be collected verbally, in writing, or electronically through automated or non-automated methods within the framework of our company’s commercial activities, via our website, social media channels, parties with whom we have business relations and/or from whom we receive complementary services, contracted institutions, and other similar channels. Your personal data may also be processed and shared within the scope of personal data processing conditions and purposes specified in Articles 5 and 6 of the Law, and in line with the legal grounds and purposes set out in Article 2 of this Privacy Notice.

4. Your Rights Pursuant to Article 11 of Personal Data Protection Law No. 6698

By applying to ARETE, you have the right to:

a) Learn whether your personal data is processed,

b) Request information if it has been processed,

c) Learn the purpose of processing and whether it is used in accordance with its purpose,

d) Know the third parties to whom it has been transferred domestically/internationally,

e) Request correction if it has been processed incompletely/incorrectly,

f) Request its deletion/destruction within the framework of the conditions set out in Article 7 of Personal Data Protection Law No. 6698,

g) Request that the processing operations carried out pursuant to subparagraphs (d) and (e) above be notified to third parties to whom it has been transferred,

h) Object to the emergence of an adverse outcome against you due to analysis exclusively by automated systems,

i) Request compensation for damages in case you suffer damage due to its unlawful processing.

Pursuant to Article 11 of Personal Data Protection Law No. 6698, you may submit your requests regarding your personal data to our company address in writing by petition, together with information/documents verifying your identity.

Your application must be made in accordance with paragraph 2 of Article 5 titled “Application Procedure” of the “Communiqué on the Procedures and Principles of Application to the Data Controller.” Your application will be evaluated by our company, and depending on the nature of your request, a response will be provided within a maximum of 30 (thirty) days.

5. Measures Regarding the Protection of Personal Data

The protection of personal data is an important matter for ARETE. ARETE takes the necessary measures to protect personal data against unauthorized access or loss, misuse, disclosure, alteration, or destruction of such information.

ARETE undertakes to keep your personal data confidential, to take all necessary technical and administrative measures for ensuring confidentiality and security, and to exercise due care. Despite ARETE taking the necessary information security measures, in the event that personal data is damaged or falls into the hands of third parties as a result of attacks on the website and system, ARETE shall immediately notify you and the Personal Data Protection Authority.

6. Maintaining Your Personal Data Accurately and Up-to-Date

The User/Users acknowledge and declare that they know the importance, in terms of being able to exercise their rights over their personal data within the meaning of Personal Data Protection Law No. 6698 and other relevant legislation, of ensuring that the information they share on the website is accurate and maintained up-to-date, and that any liability arising from providing incorrect information shall belong entirely to themselves.

7. Deletion, Destruction, or Anonymization of Your Personal Data

Your personal data processed for the purposes specified in these “Terms of Use and Privacy / Personal Data Protection Policy and Privacy Notice” shall continue to be used by us in anonymized form, when the purpose requiring processing pursuant to Article 7/1 of Law No. 6698 ceases to exist, and pursuant to Article 138 of the Turkish Penal Code, after the periods determined by laws have elapsed.

8. Changes to the Privacy / Personal Data Protection Policy and Privacy Notice

ARETE may make changes to these “Terms of Use and Privacy / Personal Data Protection Policy and Privacy Notice” at any time. These changes shall take effect immediately upon publication of the amended new “Terms of Use and Privacy / Personal Data Protection Policy and Privacy Notice” on the “https://arete.com.tr” site. You will be duly informed of changes to these “Terms of Use and Privacy / Personal Data Protection Policy and Privacy Notice.”