Cookie Disclosure

1. Introduction and Purpose

This Cookie Disclosure has been prepared by KUZEY BORU ANONİM ŞİRKETİ (hereinafter referred to as the "Company" or "Data Controller") to inform you about the cookies used on the website at kuzeyboru.com.tr (hereinafter referred to as the "Site") in accordance with the Turkish Personal Data Protection Law No. 6698 ("KVKK"), the EU General Data Protection Regulation ("GDPR"), and Article 51 of the Electronic Communications Law No. 5809 along with relevant secondary legislation.

Our Company is committed to protecting the privacy of users visiting the Site and acting in accordance with the principle of transparency in the processing of personal data.

2. Identity of the Data Controller

In accordance with Article 10 of KVKK and Articles 13 and 14 of GDPR, information regarding the data controller processing your personal data is provided below:

3. What is a Cookie?

Cookies are small text files placed on users' devices (computers, tablets, smartphones, etc.) by websites. These files are used to store various information during and after the user's visit to the Site and to identify the user.

Cookies are used for various purposes such as ensuring the proper functioning of the Site, improving user experience, taking security measures, and performing statistical analysis. Data collected through cookies may be considered as "personal data" as defined in Article 3 of KVKK and "personal data" as defined in Article 4 of GDPR.

4. Cookie Types and Purposes of Use

The cookies used on our Site are classified according to their source, storage duration, and purpose of use as follows:

4.1. Cookies by Source

First-Party Cookies: Cookies created directly by the Site and readable only by the Site.

Third-Party Cookies: Cookies placed by service providers outside the Site. Analytics tools, social media integrations, and advertising networks fall into this category.

4.2. Cookies by Storage Duration

Session Cookies: Temporary cookies that are automatically deleted when the user closes the browser.

Persistent Cookies: Cookies stored on the device for a specified period or until deleted by the user.

4.3. Cookies by Purpose of Use

5. List of Cookies Used on the Site

The table below contains detailed information about the cookies used on our Site:

6. Legal Basis

The following legal bases are used for processing personal data collected through cookies:

6.1. Legal Grounds Under KVKK

In accordance with Article 5 of the Personal Data Protection Law No. 6698:

• Explicit Consent (Art. 5/1): For functional, analytics, and marketing cookies
• Explicitly Stipulated by Law (Art. 5/2-a): For fulfilling obligations arising from legislation
• Performance of Contract (Art. 5/2-c): Necessary cookies required for providing Site services
• Legitimate Interest (Art. 5/2-f): Necessary cookies for site security and basic functionality

6.2. Legal Grounds Under GDPR

In accordance with Article 6 of the EU General Data Protection Regulation:

• Consent (Art. 6/1-a): Explicit consent given freely by the user for all non-essential cookie categories
• Performance of Contract (Art. 6/1-b): Cookies necessary for providing the service
• Legitimate Interest (Art. 6/1-f): Necessary cookies for site security and basic functionality

7. Explicit Consent and Consent Mechanism

In accordance with Article 3(1)(a) of KVKK and Article 4(11) of GDPR, explicit consent is defined as "consent given for a specific matter, based on information and expressed freely."

When you first visit our Site, you are informed about cookie usage through our cookie preference management tool (cookie banner), and your separate consent is requested for cookie categories other than necessary cookies.

This consent mechanism has the following features:

• Clear and Understandable Information: Detailed explanations are provided for each cookie category.
• Granular Consent: Separate accept or reject options are offered for each cookie category.
• Equal Accessibility: "Accept All" and "Reject All" options are equally accessible.
• Free Will: Your access to the Site's basic functions is not blocked if you reject cookies.
• Withdrawability: You can withdraw your consent at any time.

8. Transfer of Personal Data

Personal data collected through cookies may be transferred to the following recipient groups in accordance with Articles 8 and 9 of KVKK and Articles 44-49 of GDPR:

8.1. Domestic Transfer

• Authorized public institutions and organizations within the scope of legal obligations
• Business partners and suppliers from whom we receive services

8.2. International Transfer

Data collected by third-party cookie providers (Google, Meta, Microsoft, etc.) may be transferred to countries where these companies' data centers are located. These transfers are carried out within the framework of Standard Contractual Clauses (SCC), Binding Corporate Rules (BCR), or transfer mechanisms to countries with adequacy decisions under GDPR.

9. Managing Your Cookie Preferences

You can manage your cookie preferences through the following methods:

9.1. Cookie Preference Management Tool

You can access the cookie preference management tool by clicking the "Cookie Settings" link at the bottom of our Site and change your preferences at any time.

9.2. Browser Settings

You can block or delete cookies through your internet browser settings. Cookie management links for commonly used browsers are provided below:

• Google Chrome
• Mozilla Firefox
• Safari
• Microsoft Edge

9.3. Opt-Out Links

You can disable relevant cookies using opt-out mechanisms provided by third-party cookie providers:

• Google Analytics Opt-out
• Google Ads Settings
• Meta (Facebook) Ad Preferences
• Network Advertising Initiative

10. Rights of the Data Subject

10.1. Rights Under KVKK

In accordance with Article 11 of KVKK, you can exercise the following rights by applying to our Company as the data controller:

• a) Learning whether your personal data is being processed
• b) Requesting information if your personal data has been processed
• c) Learning the purpose of processing your personal data and whether they are used in accordance with their purpose
• ç) Knowing the third parties to whom your personal data is transferred domestically or abroad
• d) Requesting correction of your personal data if it is incomplete or incorrectly processed
• e) Requesting deletion or destruction of your personal data within the framework of conditions stipulated in Article 7 of KVKK
• f) Requesting notification of correction, deletion, and destruction operations to third parties to whom personal data has been transferred
• g) Objecting to the emergence of a result against you through analysis of processed data exclusively by automatic systems
• ğ) Requesting compensation for damages if you suffer damage due to unlawful processing of personal data

10.2. Rights Under GDPR

In accordance with Articles 15-22 of GDPR, users residing in the European Economic Area (EEA) have the following rights:

• Right of Access (Art. 15): Access to your personal data and information about processing activities
• Right to Rectification (Art. 16): Correction of inaccurate or incomplete data
• Right to Erasure (Art. 17): Deletion of data under the "right to be forgotten"
• Right to Restriction of Processing (Art. 18): Restriction of processing in certain circumstances
• Right to Data Portability (Art. 20): Receiving your data in a structured format and transferring to another data controller
• Right to Object (Art. 21): Objection to processing based on legitimate interest and direct marketing

11. Application Method

You can apply to our Company through the following methods to exercise the rights mentioned above:

• Email: [email protected] by email with identity verification
• Written Application: KIRIMLI OSB MAH., MEHMETÇİK BLV., 2/1, MERKEZ, AKSARAY by registered mail with return receipt

Your applications will be concluded free of charge as soon as possible depending on the nature of the request, and within thirty (30) days at the latest.

12. Data Security

Our Company takes the necessary technical and administrative measures in accordance with Article 12 of KVKK and Article 32 of GDPR to ensure the security of personal data collected through cookies. These measures include:

• Use of SSL/TLS encryption protocols
• Implementation of firewall and intrusion detection systems
• Establishment of access control and authorization mechanisms
• Regular security audits

13. Retention Period

Personal data collected through cookies are stored for as long as the processing purposes require and in any case taking into account the limitation periods stipulated in the relevant legislation. Session cookies are automatically deleted when the browser is closed, while persistent cookies are stored on your device for a certain period.

If you withdraw your consent, the relevant cookies and data collected through them will be immediately deleted.

14. Third-Party Privacy Policies

Third-party cookies used on our Site are subject to the privacy policies of the relevant service providers. You can access these policies from the following links:

• Google
• Meta (Facebook/Instagram)
• Microsoft
• LinkedIn
• HubSpot
• Cloudflare

15. Changes

Our Company reserves the right to update this Cookie Disclosure in line with changes in legislation, technological developments, or business requirements. Significant changes will be notified to you through the Site or by email, and your consent will be requested again when necessary.

16. Contact

For questions about this Cookie Disclosure or our cookie practices, you can contact us through the following communication channels:

Last Updated: 20.05.2026