1. PURPOSE AND SCOPE
This Cookie Policy (the "Policy") has been prepared in order to inform Users about the cookies and similar tracking technologies ("Cookies") used on the website www.adsmotion.co and the associated Advertiser Panel and Partner Panel (the "Website") operated by Adsmotion Teknoloji ve Reklam A.Ş. ("Adsmotion" or the "Company"), registered at Merkez Mah. Teknoloji Cad. No:1 Şişli/İstanbul, taking into account the Personal Data Protection Law No. 6698 ("KVKK"), the Law No. 6563 on the Regulation of Electronic Commerce and its secondary legislation, and the guiding principles on cookie practices published by the Personal Data Protection Authority.
This Policy is an integral part of the Adsmotion Website Visitor/User Privacy Notice and shall be interpreted and applied together with that text.
The purpose of this Policy is to set out transparently the types of Cookies used on the Website, their purposes of use, their legal bases, and the related choices and rights of Users. The Policy covers all natural persons who visit the Website, become members, or use the Advertiser Panel or the Partner Panel.
2. DEFINITIONS
Cookie
Small text files, generally consisting of letters and numbers, placed on a user's computer, mobile device or tablet through the browser when a website is visited, together with all tracking technologies such as pixel tags, local storage, SDKs and similar.
User
The natural person who visits the Website, becomes a member, or uses the Advertiser Panel/Partner Panel.
Personal Data
Any information relating to an identified or identifiable natural person.
Data Controller
Adsmotion Teknoloji ve Reklam A.Ş., which determines the purposes and means of processing personal data and is responsible for establishing and managing the data filing system.
Explicit Consent
Consent relating to a specific matter, based on information and expressed by free will.
3. WHAT IS A COOKIE AND WHICH TECHNOLOGIES DOES IT COVER?
Cookies may be used for purposes such as ensuring that the website functions properly, improving the user experience, analyzing site traffic and carrying out marketing activities; the purpose for which each of these technologies is used is set out in detail in Article 4 of this Policy.
Within the scope of this Policy, the term "Cookie" is interpreted broadly so as to cover, in addition to browser cookies in the narrow sense, pixel tags, local storage methods, SDKs and similar tracking technologies.
4. CATEGORIES OF COOKIES USED
Cookies in the categories set out below are used on the Website. The stated retention periods represent maximum periods; the periods actually applied may be shorter depending on the technical characteristics of the relevant cookie.
Strictly Necessary Cookies
- Purpose: Technically required for the core functions of the Website, the Advertiser Panel and the Partner Panel (session management, security, load balancing, fraud prevention).
- Legal basis: Legitimate interest under Article 5/2-f of the KVKK, for the fulfilment of obligations under Law No. 6563 and the provision of the core functions of the Website; a balancing test has been carried out in this respect and no explicit consent is required.
- Maximum retention period: Session duration / maximum 1 year.
Performance and Analytics Cookies
- Purpose: Measuring the number of visitors, page views and on-site navigation behavior; analyzing and improving site performance.
- Legal basis: Explicit consent (KVKK Art. 5/1).
- Maximum retention period: 2 years.
Functional Cookies
- Purpose: Improving the user experience by remembering user preferences such as language preference and session information.
- Legal basis: Explicit consent (KVKK Art. 5/1).
- Maximum retention period: 1 year.
Marketing / Targeting Cookies
- Purpose: Presenting content and announcements relevant to User interests; planning and measuring marketing activities.
- Legal basis: Explicit consent (KVKK Art. 5/1).
- Maximum retention period: 1 year.
Third-Party Cookies
- Purpose: Placed by the payment infrastructure (PayTR) and by third-party service providers offering analytics, performance measurement or social media integration.
- Legal basis: Explicit consent (KVKK Art. 5/1), except for those strictly necessary for the performance of the payment transaction.
- Maximum retention period: Subject to the policy of the relevant third party.
5. PURPOSES OF USE OF COOKIES
Cookies are used on the Website for the following purposes:
- Ensuring the technical operation, security and continuity of the Website and of the digital platform (Advertiser Panel, Partner Panel),
- Managing user sessions and remembering user preferences,
- Analyzing Website traffic, visitor behavior and site performance,
- Measuring and improving the quality of the services provided,
- Carrying out and measuring marketing and promotional activities, subject to the User's explicit consent,
- Fulfilling legal obligations and detecting and preventing unlawful use.
6. LEGAL BASIS FOR COOKIES
Cookies that are strictly necessary for the operation of the Website are used without explicit consent, on the basis of Adsmotion's legitimate interest pursuant to Article 5/2-f of the KVKK. In this context, it has been established through a balancing test that the use of strictly necessary cookies serves the purpose of ensuring the core functionality of the Website and does not harm the fundamental rights and freedoms of users.
Performance, functional, marketing/targeting and third-party cookies that are not strictly necessary are used on the basis of explicit consent (KVKK Art. 5/1) obtained through the cookie consent notice ("cookie banner") presented upon first access to the Website.
7. OBTAINING AND WITHDRAWING EXPLICIT CONSENT
The User's explicit consent is obtained through the cookie preference panel presented upon first access to the Website, separately for each non-essential cookie category and by an active affirmative action ("opt-in"); consent may under no circumstances be presumed through pre-ticked boxes or implied conduct such as continued use of the Website.
The User may withdraw the explicit consent given at any time, as easily as it was given, through the cookie preference panel or via the contact channels set out in Article 11 of this Policy. Applications regarding the withdrawal of consent are concluded and notified to the user within the same procedures and periods as other applications under Article 11 of the KVKK (within thirty days at the latest). Withdrawal of consent does not affect the lawfulness of processing carried out before the date of withdrawal.
8. MANAGING AND REFUSING COOKIES
The User may accept or reject non-essential cookie categories, or customize preferences on a category basis, through the cookie preference panel. The User may also block cookies, delete existing cookies or choose to receive notifications about the use of cookies through the settings of the internet browser used; detailed information on such changes can be found in the help menu of the browser concerned.
The User acknowledges that if strictly necessary cookies are blocked or deleted, the functions provided by these cookies (e.g. logging in to the Advertiser Panel/Partner Panel, session management, security controls) may be affected, and that this may restrict the use of certain parts of the Website.
9. THIRD-PARTY COOKIES AND DATA TRANSFERS
Cookies placed by PayTR Ödeme Kuruluşu A.Ş. for the execution of payment transactions and by third-party service providers for analytics, performance measurement or similar purposes may be used on the Website. The use of such cookies is subject to the relevant third party's own privacy and cookie policies; Adsmotion supervises the operation of third-party cookies within the framework of its data security obligations under Article 12 of the KVKK and ensures that the necessary technical and administrative measures are taken.
In this context, Adsmotion enters into data processing agreements compliant with Articles 8 and 9 of the KVKK with third-party service providers involved in the processing of personal data and ensures that they take the necessary technical and administrative measures. If the User does not give explicit consent to the data transfer relating to third-party cookies, the placement of such cookies is blocked.
10. RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA
Personal data obtained through Cookies is processed in accordance with the KVKK and the relevant legislation; detailed information on the purposes of processing, legal bases, recipients of transfers and retention periods, as well as on the data subject's rights under Article 11 of the KVKK, can be found in the separately published Adsmotion KVKK Privacy Notice.
The data subject may submit requests relating to their rights under Article 11 of the KVKK to the data controller through the application methods set out in the Adsmotion KVKK Privacy Notice or via the registered electronic mail address [email protected]. Applications are concluded free of charge within thirty days at the latest pursuant to Article 13 of the KVKK; if a request is rejected, the grounds are notified in writing.
11. CONTACT
For questions and requests regarding the use of cookies and for applications under the KVKK, Users may contact Adsmotion through the following channels:
- Address: Merkez Mah. Teknoloji Cad. No:1 Şişli/İstanbul
- Registered Electronic Mail (KEP): [email protected]
- Phone: +90 (850) 840 91 01
- Website: www.adsmotion.co
Application Procedure
Applications may be made in writing or by the other methods determined under Article 11 of the KVKK, in accordance with the procedures and principles on the exercise of rights under that article. Adsmotion concludes applications within thirty days at the latest and notifies the relevant User of the outcome with reasons.
12. AMENDMENTS TO THE POLICY AND ENTRY INTO FORCE
Adsmotion reserves the right to update this Cookie Policy at any time in line with changes in the types of cookies used, legal regulations or operational needs. The current Policy enters into force as of the date it is published on the Website.
Amendments to the Policy are notified to Users through the Website or by e-mail at least fifteen (15) days before the effective date. Any update that changes the purpose of use, the categories or the retention periods of non-essential cookies is deemed a substantial amendment, and in such cases explicit consent is obtained from Users again.