Privacy Policy

Personal data within the scope of Law No. 6698 on the Protection of Personal Data (hereinafter referred to as "Law" or "KVKK"); means any information belonging to an identified or identifiable natural person.

According to the Law, special quality personal data, which is a special type of personal data; “data about race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data” It is counted as sensitive personal data and it is stated that these data can only be processed with the express consent of the person concerned.

The explanations made for your Personal Data within the scope of this Clarification Text also include your Private Personal Data. “BM Dijital Medya Ltd. Sti.” As “Data Controller”, we take the highest possible technical and administrative security measures in order to ensure that your personal data and sensitive personal data are collected, processed, stored, shared in accordance with the law and to protect your data privacy.

In accordance with KVKK No. 6698, your personal data and personal data of special nature; In the capacity of Data Supervisor, “BM Dijital Medya Ltd. Sti.” will be collected and processed by us for the purposes described below.

1. What are the Purposes and Legal Reasons for Processing Your Personal Data?

“BM Dijital Medya Ltd. Şti.” the personal data you share with us and the personal data of special nature;

1. In order to keep the service quality, we offer at the maximum level: Your personal data and, when necessary, your personal data of special nature can be processed by the Data Controller in order to fulfill the requirements of the service activities we offer to our customers and members in accordance with the requirements of the contract and technology, to raise and improve the quality standards of our products and services offered.
2. In order to ensure communication within the scope of the services we offer: It includes communication by e-mail, text message, or MMS regarding marketing, commercial communication, market research, and statistical analysis, based on the express consent of the data subjects, and with the express consent of the data owners, e-mail, messaging or telephone. This includes the use of contact information by the Data Controller for direct marketing, such as
   In order to ensure public safety: In accordance with the KVKK, the Data Controller can provide information to the prosecution offices, courts, and relevant public officials, upon request and in accordance with the legislation, on matters related to public order and public security and legal disputes.
3. In order to offer a wide range of opportunities to our members: Your personal data and, when necessary, your personal data of special nature may be processed by the Data Controller in order to increase the variety and quality of the products we offer to our members and to reach the persons or institutions that can offer these opportunities within the legal framework.
4. To analyze advertising preferences: Your personal data and, when necessary, your personal data of special nature can be processed by the Data Controller in order to analyze your advertising preferences in accordance with the KVKK No. 6698 and the relevant secondary regulations.
5. In other cases deemed necessary by the Data Controller (transferring the data to third parties/parties, when necessary, in order to comply with any legal obligations, etc.), your personal data and sensitive personal data may be processed within the framework of the provisions of the legal legislation.

As a rule, your Personal Data and Private Personal Data are processed by the Data Controller based on your express consent for the processing of your data. However, in exceptional cases regulated by KVKK m.5/2 and m.6/3, your Personal Data and Private Personal Data can be processed within the scope of legal regulations without the need for your explicit consent. Also social media etc. Your Personal Data and Private Personal Data, which have been made public by you through intermediary channels, can also be processed to the extent permitted under the KVKK without your explicit consent.

Your Personal Data and Private Personal Data will be processed with manual and/or automatic systems used by the Data Controller and/or Data Processor within the scope of the data processing activities of the Data Controller.

2. What are the Collection Methods of Your Personal Data and Private Personal Data?

Your personal data;

1. With forms on the hortiturkey's website and mobile applications, and information such as name, surname, address, telephone, business or private e-mail address; In the form of location data, data including preferences on the pages logged in using the user name and password, IP records of the transactions performed, cookie data collected by the browser, and browsing time and details;
2. “BM Dijital Medya Ltd. Şti.” In a physical or virtual environment, face-to-face or remotely, verbally or in writing or electronically, obtained from people who share their personal data with business cards, CVs, bids, and other ways, for purposes such as establishing a commercial relationship, applying for a job, making offers, etc. from the environment;
3. In addition, data obtained from (micro) websites and social media indirectly obtained from different channels, used for websites, blogs, contests, surveys, games, campaigns, and similar purposes, e-bulletin reading or click movements, data provided by public databases. from profiles and data that are open to sharing from social media platforms (Facebook, Twitter, Google, Instagram, Linkedin, Youtube, etc.); can be processed and collected.

3. Notification of Third Parties and/or Organizations to which Your Personal Data may be Transferred

Persons/institutions and organizations to which your personal data and sensitive personal data that you have shared with the Data Controller can be transferred in accordance with the personal data processing purposes detailed above; our main shareholders, shareholders, advertisers, direct or indirect domestic and foreign affiliates; especially “BM Dijital Medya Ltd. Şti.” Program partner organizations, domestic/foreign organizations, and other third parties, from which we receive services, cooperate with us, to carry out our activities and/or as a Data Processor, including, but not limited to, member companies using the infrastructure of the program and persons and organizations related to the service provided, and are organizations.

Your personal data collected by any of the above-mentioned methods to be processed in Turkey or to be processed and stored outside of Turkey provided that it remains within the scope of KVKK and in accordance with the contractual purposes, to service intermediaries abroad (to countries accredited by the Personal Data Board and where there is sufficient protection for the protection of personal data). can also be transferred.

Your personal data;

• Our business partners with whom we cooperate and/or receive services for the presentation and promotion of products and services,
• To the competent authorities who will determine your location in case of an emergency call,
• Regulatory and supervisory institutions and other official institutions such as courts and enforcement offices, other public institutions or organizations that are authorized to request your personal data,
• “BM Dijital Medya Ltd. Sti.” It can be transferred to legal entities that have a commercial relationship with you and have your telephone number if deemed necessary.

In the KVKK, it is regulated that the provisions of the Law will not be applied if it is processed within the scope of preventive, protective, and intelligence activities carried out by public institutions and organizations that have been authorized by law to ensure national defense, national security, public security, public order or economic security.

In this context, since the Covid-19 virus, which affects the whole world and our country, threatens public security and public order, your personal data and private personal data may be transferred to the Ministry of Health and authorized public institutions and organizations.

Apart from this, pursuant to article 4/1 of the KVKK, your Personal Data may be transferred to other related parties and authorized institutions and organizations where the transfer is required for the purposes determined at home and abroad, without your express consent, within the scope of exceptional cases that do not require your explicit consent within the scope of KVKK art.5.2 and 6.3.

4. What are the Processing Times of Your Personal Data and Private Personal Data?

Your Personal Data and Special Qualified Personal Data, in accordance with the statutory legislation on the protection of Personal Data, in particular the provisions of the KVKK, and the periods mandated by other relevant legislation, and in any case, as long as the above legitimate purposes are not eliminated, the data controller's storage and destruction policy regarding personal data and special qualities personal data will be processed accordingly.

5. Your Legal Rights Regarding Your Personal Data and Our Support as Data Controller

Pursuant to Article 11 of the KVKK; By applying to the Data Controller;

• Learning whether your personal data is processed or not,
• If your personal data has been processed, requesting information from the Data Controller and/or Data Processor,
• To learn the purpose of processing your personal data and whether they are used in accordance with the purpose,
  Knowing the third parties to whom your personal data is transferred in the country or abroad,
• If your personal data is incomplete or incorrectly processed, request the correction of them from the Data Controller,
• To request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the KVKK,
• Requesting notification of the transactions made pursuant to the above two articles (4th and 5th articles) to third parties to whom personal data has been transferred,
• Objecting to the emergence of a result against you by analyzing your processed data exclusively through automated systems,
• In the event that your personal data is damaged due to unlawful processing, you have the right to demand compensation for the damage.

In this context, you can create your requests regarding these rights in a way that will meet the conditions determined by the Personal Data Protection Authority, and send an e-mail to our address from your registered e-mail address: iletisim@hortiturkey.com; You can contact us through our website. In addition to these, all your requests can be delivered to our Company with a wet signed petition or you can send them through a notary public.

Accordingly, “BM Dijital Medya Ltd. Şti.” In the capacity of the data controller, written applications containing the above-mentioned requests from the data subject will be returned to the relevant person in a maximum of 30 (thirty) days, in writing or electronically, and necessary actions will be taken. Applications will be made free of charge unless a fee schedule is published by the decision to be determined by the Personal Data Protection Board.

The terms of this notice may be revised if necessary. We will post important amendments to this Statement with appropriate notices on our website or by contacting our users using other communication channels.

In case you want additional information regarding this Clarification Text and Privacy Statement and/or you want to contact the Group Data Protection Officer and the local Privacy Manager and forward your requests, please send an e-mail to iletisim@hortiturkey.com.