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Article 1 - Introduction


The purpose of this Privacy Agreement ("Agreement") is to determine the terms and conditions related to the use of the information and data shared with the Forie owner, KOBİ ULUSLARARASI TANITIM VE DAĞITIM HİZMETLERİ SAN.TİC. Inc. (“KOBİ A.Ş.”), operating at Altayçeşme Mh. Zuhal Sk. Niyazibey İş Merkezi, No: 22/7 Maltepe / İstanbul, at the stage of utilization of the site ("Site") at and mobile applications (together, referred to as "Forie") by the persons ("User") who are registered as members.


This Agreement is a supplement and an integral part of the User Agreement concluded with the User.


Article 2 – Personal Data


“Personal data" means information belonging to a natural person who is identified or can be identified by data we have access to. Personal data does not include information such as aggregated data and anonymized data, statistical data that does not belong to real persons or that does not belong to identified or identifiable natural persons.


Article 3 – Content and Consent


This Agreement explains the collection, processing, sharing with third parties, protection, ensuring security of your personal data and your rights regarding these issues.


It will be applied to all types of applications and service provisions (together hereinafter referred to as "Services") referred to in this Agreement, including our website and mobile application, regardless of your method of access or use, including mobile devices.


KOBİ A.Ş. complies with the legal regulations in force regarding the protection of personal data when determining the purpose and means of processing your personal data, in cases where it is the data controller within the scope of the provision of the Services.


By using our Services and/or creating an account, you agree to this Agreement and the User Agreement, and as described in this Agreement, you give your consent for us to collect, use, share with third parties when necessary, store and protect your personal data.


Article 4 - Cookies


We use “cookies” to collect unique information about you and to monitor your traffic on our site. A “cookie” is a small piece of data sent to your internet browser and stored on your device or network server.


For more detailed information about our use of cookie technologies and how you can control them, you can review our Cookies Policy.


Article 5 – Collection of Personal Data


When you visit the Site, use our Services, create a user account, fill out a form on the Site, update or add information to your account, make interviews, make conversations and chat with users, buy or sell products and/or services, when you contact us or other users regarding our services; we collect, process and store your personal data.


Article 6 - Use and Storage of Personal Data


We use the personal data we collect to provide and improve our Services, to provide you with a personalized experience, to communicate with you, to provide you with personalized advertising and marketing services or to detect, prevent, and investigate fraudulent/illegal activities, if any.


We retain your personal data for as long as related or necessary for our activities and prescribed by legislation in force. In addition, we may store personal data in closed accounts in order to comply with legislation in force, prevent fraud, collect fees owed, resolve disputes, assist investigations, enforce our User Agreement and take other actions as permitted or required by legislation in force.


Under the legal regulations in force, mainly Law no. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications and the Law on the Regulation of Electronic Commerce No. 6563, we would like to remind you that we are obliged to keep your personal data for the specified periods. In the event that situations requiring us to retain your personal data disappear, we will safely destroy or anonymize your personal data.


Our policy on personal data is published on the site under a separate heading.


Article 7 - Information We Collect


We can collect information such as Registration Information, Publishing Information, Payment Information, Statistical Information, etc. through the use of cookies as information collected as "Collected Information".


Registration Information: When you register to become a User on Forie, the information you enter on the registration form (name, surname, address, phone/fax number, e-mail address and other personal information, information about your business) is defined as "Registered Information".


Publication Information: The information that you approve to be published, such as company profile, product information, commercial advertisements, requests, etc., by using various publication tools from Forie is accepted as "Published Information".


Payment Information: If you purchase a service or advertisement from Forie, various additional information such as billing information, credit card number, check numbers or money transfer information is defined as "Payment Information".


Statistical Information: Information such as various aggregate statistical information about Forie and its Users, IP addresses, browser type, operating system, page views, session count, unique visitors is defined as "Statistical Information".


Other Information: Information about all the transactions you have done, including buying or selling products, as part of your activities at Forie. Other contents linked to your account (product in the cart, adding a company to My Favourites, etc.). Financial information related to your transactions (account number, etc.). Information you provide by contacting Forie. Other information that we need to collect and process under the laws in force to identify you or verify your identity. In some cases; messaging and other correspondence contents in order to evaluate complaints from our users or third parties regarding illegal, threatening, defamatory and other spam messages.


Article 8 - How We Can Use the Information


General: We can use the information collected; to improve our marketing services, for statistical analysis of site usage, for content development, product descriptions, and personalization of site content, structure and service quality. We may also use your Collected Information to provide you with a better service, in order to solve problems and execute the agreement between us. We do not sell, rent, use or trade any information about our members. We may share precise net information based on collected information analysis with our partners, customers, agencies and potential users. We may use your collected information in marketing campaigns, advertisements and advertising campaigns of third parties.


Registration Information: We may use your registered information both to serve you better and to notify you of our new services you may be interested in. Your e-mail address, postal address, telephone or fax number is used to contact you about various information, reviews, product postings, new service or product offerings, and information about site usage.


Publication Information: Your published information will be publicly available on Forie and any internet user will be able to access it. All information you provide to us for publication on Forie is general user information and may mean that you waive your patent-protected information. It includes privacy terms and copy rights, though not wholly.


Payment Information: Forie will share your payment information with banks or relevant brokers to complete transactions. Forie may use your payment information for credit valuation or let the banks or agents to use your payment information in such a case. Any credit card information you provide to us through the site is sent directly to the bank's credit card processing centre. Forie does not physically or electronically alter or adjust the copy of your credit card. Although Forie uses the latest technology in the use and protection of Payment Information, it cannot guarantee that such technologies and procedures completely eliminate the risks of theft, loss and misuse. Forie cannot be in a position to lie to you for any damage caused by unauthorized use, publication, disclosure, or misuse of any Payment Information that includes credit card information.


Statistical Information: We use statistical information to solve server problems, manage and improve Forie, improve usage-based services. We can use reports and analysis based on statistical information in our internal analysis, imaging and marketing activities. We may provide this statistical information to third parties, but in such a case, we will not provide your personally identifiable information without your permission.


Article 9 - Sharing Personal Data


We may share your personal data, with KOBİ A.Ş. group companies or third parties and companies from which we receive service and/or collaborate to carry out the activities described in the Privacy Agreement. These shares will take place after completing security assessments and analysis of third parties and companies.


Sharing this personal data may be necessary for us to provide our Services and enable your access to our Services, comply with our legal obligations, implement our User Agreement, ensure our marketing and advertising activities, prevent fraudulent or illegal activities related to our Services, detect and minimize them and to investigate them properly.


We disclose personal data to relevant and necessary people in order to fulfil the objectives listed below. We do not transfer your personal data to third parties for marketing and advertising purposes without your explicit consent.


(a) Members of Forie Group of Companies:

  • Providing content and services such as registration, transaction and customer support;
  • Help identify and prevent potential fraud, suspicious and illegal transactions, breach of our User Agreement and data security violations;
  • Providing you with personalized ads.


(b) Service Providers and Financial Institution Partners:

  • Preventing, detecting, minimizing and investigating potential illegal or suspicious transactions, breach of our User Agreement, fraud and/or suspicious transaction violations;
  • Serving personalized ads;
  • Help us with payment processing services and other business operations.


(c) Authorized by You or Your Use of Our Services:

  • When you make transactions with other users at home or abroad, we only convey the necessary information for completion, delivery and invoicing of the products you buy/sell from our site such as your name, account number, e-mail address, contact information, shipping and billing address for the mentioned purposes in a limited way.
  • Other users who receive your information are not permitted to use this information for purposes not related to the transaction, such as contacting you for marketing purposes, without your explicit consent. Contacting Users through unsolicited or threatening messages constitutes a breach of our User Agreement.


(d) Law Enforcement, Legal Transactions, Official and Legal Authorities:

  • We may share it to comply with legal requirements, enforce our User Agreement, interfere with claims that any content infringes the rights of others, or protect anybody's right or safety.
  • Data may also be shared with law enforcement or official authorities or authorized third parties in response to a verified request regarding criminal investigation or suspected illegal activities and other activities that may expose us, you or any other user, to legal liability. In this context, only information that we think is relevant to the investigation or examination, such as name, city, postal code, phone number, e-mail address, user identity history, IP address, fraud complaints, shopping history and listing history, is disclosed.
  • We may also share personal data with third parties involved in legal proceedings in case there is a subpoena, court order, or similar decision in essence, or we believe it is necessary in good faith to prevent a possible physical harm or financial loss or report a suspected illegal activity.
  • We would like to remind you that we are obliged to share your personal data with the competent authorities in accordance with the legal regulations in force, mainly the Law no. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications and the Law on the Regulation of Electronic Commerce No. 6563.


Additionally; this information provided by all Users who enter their information in the “Resume” area on the Forie Profile Settings page is shared with other Forie Users.


Article 10 – Privacy Standards and International Data Transfer


Your personal data may be transferred to KOBİ ULUSLARARASI TANITIM VE DAĞITIM HİZMETLERİ SAN.TİC. A.Ş., to the members of the group companies, and within this scope, potentially processed and preserved in servers at home and/or abroad subject to the conditions set forth in this Privacy Statement and subject to the conditions in the legislation in force.


We would like to remind you that your explicit consent in this Privacy Statement covers the transfer of your personal data abroad in connection with the purposes described and limited within the scope specified in the Privacy Policy. In this context, in cases where personal data transfer is in question; all additional legal requirements and measures will also be met in accordance with the legislation in force.


Article 11 - Modification


In the event that we merge with or acquired by any other company, we may share the information with these companies pursuant to our global privacy standards. In such a case, we will require that the merged new legal entity comply with this Privacy Policy regarding your personal data. If your personal data is collected, used, disclosed or stored for any purpose not covered by this Privacy Agreement, you will be informed in advance of the processing of your personal data for new purposes.


Article 12 - Security


We protect your personal data by taking appropriate technical and administrative security measures to reduce risks such as loss of your personal data, malicious use, unauthorized access to your personal data, unauthorized sharing or modification of your personal data.


Article 13 - Security Measurements


We use commercially proven security methods to prevent unauthorized access, secure data and reduce risks such as abuse. The measures we use include firewalls, data encryption, physical access controls to our data centres, and information access authority controls. If you suspect that your account has been misused, you can contact us by following the instructions in the Contact Us section.


We recommend that you use unique numbers, upper and lower-case letters and characters in your password and that it has not been used on any other site. You should not share your password with other people. If you share your password with others, you will be responsible for all the business and transactions that other people do from your account. We would like to remind you that losing control of your password may result in losing control of your personal data. None of our staff will ask you for your password by phone, e-mail or any other means. If you are using a computer that is open to sharing, you should not save your site login information (such as username and password). When your session ends, do not forget to close your account and browser window.


While you are logged in, you will be able to view, access and process your account without any other permission. This will also apply to other users of all computers, mobile phones, tablets and browsers you sign in to.


Transaction and account activities that can be performed by you or these other users include any transactions, including but not limited to:


  • Viewing and editing Profile Settings and My Companies pages;
  • Creating a new company;
  • Changing the membership plan;
  • Recruiting or firing staff, regulating powers;
  • Providing feedback;
  • Viewing and editing my favourites;
  • Messaging with firms, blocking firms, archiving conversations, etc.
  • Creating, editing and deleting purchase/sale requests;
  • Viewing order information;
  • Performing post-sales activities such as cancelling orders, requesting returns, etc.;
  • Publishing and deleting a CV;
  • Changing streaming page settings.


There is no guarantee that any data can be transported securely over the Internet and/or wireless network. In this case, no website or firm, including us, can absolutely guarantee that the information you provide will be 100% securely protected. In this regard, you assume your own risk.


Article 14 - Third Party Privacy Practices


This Privacy Agreement deals only with the use of personal data we collect from you. If you disclose your personal data to others or are directed to third party websites, their privacy statements and practices will prevail. If you present your personal data to third parties, we cannot guarantee the privacy and security of your personal data and we recommend that you evaluate the privacy and security policies of the person you share with before taking any action and sharing your personal data. This also applies if third parties to whom you disclose your personal data are bidders, buyers or sellers on our sites.


Article 15 - Minors


Forie and its content are not designed to serve minors under laws in force, and we do not intend to sell any of our products or services to minors. However, we are not able to determine the age of anyone who wants to access our site. Therefore, we apply this Privacy Agreement for all age groups. If a minor gives us his/her personal information without parental protection or guardian’s permission, his/her parent or guardian should contact us to delete this information.


Article 16 - Terms for Using the Information You Provide on Forie


When you make transactions with other users, we allow you to obtain the personal data of the other user (such as name, account number, e-mail address, contact information, address information for shipping and invoice) or provide you with this information to complete the transaction. You have to inform other users about your privacy practices and respect their privacy. In any case, you should allow other users to delete themselves from your database and offer them the opportunity to review the information you have collected about them. You may use the personal data you have access only for purposes related to Forie transactions or for other services offered through Forie (such as escrow, shipping, fraud complaints and communication between members) or for the purposes which the owner of the information give his/her explicit consent. Using the personal data of users with whom you have access for different purposes constitutes a breach of our Privacy Policy and User Agreement.


Without the explicit consent of users, you are not allowed to add them (SMS, e-mail or mail) to the address list, call them for marketing purposes or send SMS to them, even if those users have purchased products from you. Sending unsolicited or threatening e-mails and SMS is against our User Agreement. You can report spam or fake emails related to Forie and SMS senders to us by following the instructions in the Contact Us section.


Article 17 – Your Rights


If you have any questions or complaints regarding the Privacy Agreement or wish to exercise your rights under this Privacy Agreement or legislation in force, you can contact us in writing.


In addition to your rights under the Access section you can:

  • apply us and learn whether your personal data is processed or not and request information if it is processed, under the Law no. 6698 on the Protection of Personal Data. Thus; in accordance with the Law no. 6698 on the Protection of Personal Data you can,
  • learn whether your personal data is used for intended purposes;
  • learn the third parties to whom your personal data is transferred at home or abroad;
  • request the rectification of the incomplete or inaccurate data, if any, request the erasure or destruction or anonymization of your personal data when the reason that require processing disappear. As such, you may also request notification of the o erasure or destruction or anonymization to third parties to whom your personal data has been transferred.
  • exercise your right to object related to your processed personal data and your right to request compensation for the damage, if any.


Article 18 - Information update


You can access, view and change your Registered Information and Published Information by accessing your account on Forie with your username and password.


Article 19 - Communication Options


You can choose the ways we can contact you. E-mail or SMS options are available on your settings page as communication options.


Article 20 – Revoking Consent


If you revoke your consent regarding the use or disclosure of your personal data for the purposes set out in this Privacy Statement, you may not be able to benefit from some or all of our Services. Since the information requested from you is needed to provide the Service and to perform the activities described in this Privacy Statement; in the absence of such information, we may not be able to offer, wholly and completely, all of our Services in our User Agreement with customer support.


Article 21 - Right to Modify the Privacy Agreement


KOBI A.Ş. reserves the right to modify the Privacy Agreement. The changes will be published on the Site and will be valid as of the moment they are published.


You agree that all Collected Information will be managed by the current Agreement and will be effective. If you do not accept the new Agreement, you must apply to KOBİ A.Ş. in writing from the address information at the Terms of Use and below. You can request the deletion of all or some of your Collected Information under Forie's management.


Article 22 – Feedback


If you have any questions or complaints regarding this Privacy Statement or wish to exercise your rights under this Privacy Statement or legislation in force, you can apply in written to KOBİ ULUSLARARANI TANITIM VE DAĞITIM HİZMETLERİ SAN.TİC. A.Ş., Niyazibey İş Merkezi No: 7 Maltepe / İstanbul.


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