Cookie Policy

This is an English version of our Turkish Cookie Policy. In case of any discrepancy, the Turkish version prevails, as it is governed by Turkish law.

This Cookie Policy explains how we use cookies and similar technologies when you visit the website on the validrelay.com domain and its subdomains and the validrelay application accessed through it (together, the “Site”), the legal grounds we rely on and how you can manage your choices. It has been prepared in line with the Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) and the Personal Data Protection Authority’s Guide on Cookie Practices.

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1. Data Controller

The data controller for personal data processed through cookies is:

SUB IQ YAZILIM ÇÖZÜMLERİ TİCARET LİMİTED ŞİRKETİ
Address: SİLAHTARAĞA MAH. ÜNİVERSİTE 1. SK. NO:13/1 İÇ KAPI NO : Z16 ÇORLU TEKİRDAĞ
Central Registration System (MERSIS) No: 0781108676200001
Registered e-mail (KEP): subiqyazilim@hs06.kep.tr
E-mail: info@subiq.com.tr
Phone: 444 85 39

2. What Are Cookies?

Cookies are small text files stored on your device by your browser when you visit a website. In this policy, “cookies” also covers similar technologies such as the browser’s local storage.

• First-party cookies are set on the domain of the site you visit; third-party cookies belong to another domain. Although Google Analytics cookies belong to a third-party service, they are set on our own domain.
• Session cookies are deleted when you close your browser; persistent cookies remain on your device for the period stated in the table below.

3. Types of Cookies We Use

3.1 Strictly necessary cookies

These are strictly necessary for the Site to work securely and correctly, to provide a service you explicitly request (e.g. signing in to the application) and to remember your cookie choice. They do not depend on your consent and cannot be switched off in the preferences panel. If you block them in your browser, some parts of the Site (e.g. signing in) may not work.

After you sign in to the application, interface preferences such as the table column layout and the last movement type you used are kept in your browser’s local storage. This information stays on your device and is not sent to our servers.

3.2 Analytics cookies

These help us understand how many people visit the Site, which pages are viewed and where visitors come from (search engine, link, campaign), so that we can improve our content. We may use Google Analytics 4 for this purpose.

• Analytics cookies are used only with your consent. No Google script (neither the Google Tag Manager container nor Google Analytics’ gtag.js) is loaded on the page before you accept analytics cookies, or if you do not. Accepting only marketing cookies does not load these scripts either. (The YouTube player is not a measurement tag; it is only loaded if you load a video yourself, see section 3.4.)
• Google signals and ad personalisation are disabled in our Google Analytics settings. Unless you accept marketing cookies, the advertising consent signals are sent as “denied” and measurement data is not used for advertising.
• According to Google, Google Analytics 4 does not log or store IP addresses; the IP address is only used to derive an approximate location (country, city).

3.3 Marketing cookies

We do not currently use any marketing or advertising cookies on the Site. The marketing choice on its own does not load any script: it only causes the advertising consent signals of Google Consent Mode (ad_storage, ad_user_data, ad_personalization) to be passed as “granted” to a Google tag that has been loaded with your analytics consent. If we introduce advertising cookies in the future (e.g. to measure advertising campaigns), they will only be activated with your consent; this policy and the cookie list will be updated and you will be asked again.

3.4 Embedded videos

When a page shows a video (e.g. the webinar recording), the video provider’s player is not loaded when the page opens; a placeholder is shown instead and no request is sent to the provider. The player is loaded only when you click “Load video”, and only for that video. This click is your explicit consent to loading that video; it is independent of your cookie choices and is not stored (you are asked again when you reopen the page). Your analytics or marketing choice does not load the player on its own.

• YouTube videos are played in YouTube’s privacy-enhanced mode (youtube-nocookie.com). When you load the video, YouTube (Google) may use the cookies and browser storage listed below.
• Vimeo videos are played in Vimeo’s “do not track” (dnt) mode; according to Vimeo, no session data or cookies are kept in this mode.
• In both cases, when you load the video your IP address and browser information are sent to the provider so that the video can be delivered (see section 8).

4. Cookie List

Strictly necessary cookies

Analytics cookies (only with your consent)

Marketing cookies (only with your consent)

Embedded video (only if you load the video)

5. Personal Data Processed and Method of Collection

Through cookies we collect, automatically and by electronic means via the Site, online identifiers (cookie and consent IDs), session information and, only if you accept analytics cookies, usage data such as the pages you visit, visit duration, referring address, browser and device type, screen resolution, language and an approximate location derived from your IP address. No special categories of personal data (KVKK Art. 6) are processed through cookies.

6. Legal Grounds

• Strictly necessary cookies: KVKK Art. 5(2)(c), processing is directly related to the establishment or performance of a contract (application session); Art. 5(2)(ç), compliance with our legal obligation (respecting your cookie choice); and Art. 5(2)(f), our legitimate interests, provided that your fundamental rights and freedoms are not harmed (Site security).
• Analytics and marketing cookies: your explicit consent under KVKK Art. 5(1). Giving consent is not mandatory; refusing it does not prevent you from using the Site.
• Embedded video player (section 3.4): your explicit consent under KVKK Art. 5(1), given by clicking “Load video”. Not loading the video does not prevent you from accessing the rest of the page.
• Consent records (see section 7): KVKK Art. 5(2)(ç), legal obligation, and Art. 5(2)(e), the establishment, exercise or protection of a right.

7. Consent Records

When you save your cookie choice (accept all, reject all or a custom selection), we record the following to be able to prove your consent: a random consent ID, the categories you chose, the type of decision, the cookie policy version, date and time, page language, a truncated browser identifier (user agent) and a one-way, keyed hash of your IP address (for IPv6 addresses, of its first 64 bits only). Your IP address itself is not stored. Consent records are kept while your choice is valid and afterwards for evidential purposes in case of a dispute, for at most 3 years; records older than 3 years are deleted automatically every day.

8. Disclosure and International Transfers

Data obtained through strictly necessary cookies is not shared with third parties; it is only processed on the systems of the infrastructure providers hosting the Site, for the purpose of providing the service.

If you accept analytics cookies, usage data is transferred to Google LLC and its affiliates (“Google”), which provide the measurement service, and may be processed on Google’s servers outside Türkiye (including the United States). This transfer only takes place with your consent and in accordance with the mechanisms set out in KVKK Art. 9 (appropriate safeguards such as the standard contracts announced by the Personal Data Protection Board or, where these cannot be applied, the conditions for occasional transfers under Art. 9(6)). How Google uses data: policies.google.com/technologies/partner-sites.

If you choose to load an embedded video (section 3.4), your IP address and browser information are transferred to the video provider (Google LLC for YouTube, Vimeo.com, Inc. for Vimeo) and may be processed on the provider’s servers outside Türkiye (including the United States). This transfer only takes place if you load the video and in accordance with the KVKK Art. 9 mechanisms described above; the provider processes this data under its own privacy policy.

9. Managing Your Choices and Withdrawing Consent

• On your first visit, the notice offers “Accept”, “Reject” and “Preferences” as equal options. Optional categories are off by default and are only activated if you switch them on.
• You can change your choice or withdraw your consent at any time using the “Cookie preferences” link at the bottom of every page. Withdrawal does not affect the lawfulness of processing carried out before it. When you reject analytics cookies or withdraw that consent, the Google Analytics cookies on our domain (_ga, _ga_<ID>) are deleted; when you reject marketing cookies, the advertising cookies are deleted. Withdrawing consent for one category does not affect the cookies of the other category you still consent to.
• Your choice is remembered for 6 months. After that, or when our policy changes significantly, you will be asked again.
• Rejecting cookies does not prevent you from accessing the content of the Site.
• You can also delete or block cookies in your browser settings (see the “cookies” section of the Chrome, Firefox, Safari or Edge help pages). To opt out of Google Analytics on all websites, you can use Google’s opt-out browser add-on.

10. Retention Periods

How long each cookie stays on your device is stated in the list above. Measurement data in Google Analytics is kept for at most 14 months. Consent records are kept for at most 3 years. At the end of these periods the data is deleted, destroyed or anonymised.

11. Your Rights under the KVKK

Under KVKK Art. 11, you have the right to apply to the data controller to:

• learn whether your personal data is processed and, if so, request information about it,
• learn the purpose of processing and whether the data is used in line with that purpose,
• know the third parties to whom it is transferred in Türkiye or abroad,
• request its correction if it is incomplete or inaccurate, its deletion or destruction under the conditions of KVKK Art. 7, and the notification of these operations to the third parties to whom it was transferred,
• object to a result against you arising from analysis exclusively by automated systems,
• claim compensation if you suffer damage due to unlawful processing.

You may submit your application in writing to the address above, to our registered e-mail (KEP) address, or from the e-mail address you have previously notified to us and that is registered in our systems to info@subiq.com.tr, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. Applications are concluded free of charge within 30 days at the latest; if the operation entails an additional cost, the fee in the tariff set by the Board may be charged. If your application is rejected, you find the response insufficient or no response is given in time, you may lodge a complaint with the Personal Data Protection Board under KVKK Art. 14.

12. Visitors from the European Union / European Economic Area

Where the EU General Data Protection Regulation (“GDPR”) applies, strictly necessary cookies are based on Art. 6(1)(b) and (f) GDPR and on the “strictly necessary” exemption in the national laws implementing Art. 5(3) of the ePrivacy Directive; analytics and marketing cookies are based on your consent under Art. 6(1)(a) GDPR. You can exercise your rights under Arts. 15–22 GDPR (access, rectification, erasure, restriction, data portability, objection) using the contact details above and lodge a complaint with the supervisory authority in your country. For transfers from the EU to the United States, Google relies on its certification under the EU-U.S. Data Privacy Framework and on the European Commission’s standard contractual clauses.

13. Changes

We update this policy when our use of cookies changes. The current version is published on this page with its version number and date. In the event of significant changes, such as a new cookie category, purpose or international transfer, you will be asked for your choice again.

14. Contact

For questions about cookies, write to info@subiq.com.tr. Our processing of personal data other than through cookies is described in our Privacy Policy & Data Protection Notice.