This Privacy and Cookies Policy explains how your personal data are processed within the Website www.sarelle.com.tr (hereinafter referred to as the “Website”).

The entities which are responsible with the processing of your personal data within the Website, as data controllers, are:

SAGRA GRUP GIDA ÜRETİM VE TİCARET
ANONİM ŞİRKETİ

collectively referred to as “Sagra” or “we” or “us” in this Privacy and Cookies Policy.

Your personal data processed by us within the Website are either provided by you when you fill in a form in a section of the Website or when you contact us through the available means of contact posted on the Website, or collected by us through the cookies of the Website.

We do not store information or cookies and we do not access the information stored in your terminal equipment (computer, phone, tablet etc.), except under the conditions described in section 3 below.

2. For which purposes do we process your personal data?

We collect, within the Website, the personal data which are necessary for the following purposes:

• analysing the use of the Website by its visitors, through analytics cookies;
• managing advertising upon user interests, through analytics and/or social media cookies;
• giving answers to the messages or requests received through the form in the “Contact” section of the Website or by e-mail;

Since the processing of your personal data within the Website is based on your consent, (in line with Article 6 paragraph 1 point a of the European General Data Protection Regulation), you have the right to withdraw your consent at any time, by sending us a request in this respect, either through the form in the “Contact” section of the Website, or through the e-mail address or to any of the postal addresses indicated in section 1 above. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

For the cookies in respect of which your prior consent is necessary, you may withdraw your consent through the means indicated in section 3 below.

As regards the forms in the “Contact” section of the Website, the lines which are indispensable for the purposes of handling and responding your questions are marked with an asterisk and in the absence of their filling in, we will not be able to give course to your requests or applications. On the other hand, you are not obliged to fill in the lines which are not marked with an asterisk.

3.Which cookies do we use within the Website?

We do not store information or cookies and we do not access the information stored in your terminal equipment (computer, phone, tablet etc.), except with your prior consent or when such operations are made for the sole purpose of carrying out the transmission of a communication over an electronic communications network or are strictly necessary in order to provide an information society service explicitly requested by you.

A “cookie” is a small file, consisting of letters and numbers, which can be stored in a user’s terminal equipment (computer, phone, tablet etc.) when the user accesses an online service through the internet navigation application (the “browser”). The cookie file allows its issuer to identify the terminal equipment in which the cookie file was stored, during the lifespan of that cookie file.

For the use of the cookies in respect of which your prior consent is necessary, we ask for your consent in a banner displayed on the entry page of the Website. Such cookies are set by default as inactive. If you give your consent, you can withdraw it at any time, by changing the cookies settings in the “Privacy and Cookies” section of the Website.

4. To whom we may disclose your personal data?

Your personal data collected within the Website are processed by the data controllers indicated in section 1 above, which may disclose your personal data to certain entities (data processors), for the processing of the personal data by such entities on behalf of and based on the instructions of the controllers.

Thus, we may use data processors for the maintenance of the Website (for instance, providers of IT services) or for the processing of the personal data collected through the forms in the “Contact” section of the Website (for instance, providers of contact center services).

In order to find out the identity of the data processors used by us, you may send us a request in this respect, either through the form in the “Contact” section of the Website, or through the e-mail address or any of the postal addresses indicated in section 1 above.

On the other hand, as regards the cookies issued by third parties, your personal data will also be accessed by those third parties, mentioned in the table from section 3 above (for instance, Google, which is a U.S. company). Since such third parties may be located outside the European Economic Area, there is a risk that your personal data collected through the cookies used by the Website will not benefit from the same level of protection as in the European Economic Area. Therefore, you should consider this aspect when you give your consent for the cookies used by the Website.

We shall not disclose your personal data to other third parties, except if you give us your consent or if we are obliged to do so by the authorities or by the applicable legal provisions.

For the purposes indicated in section 2 above, your personal data may be processed by the data controller ETI GIDA SANAYI VE TICARET A.S. (and by its data processors) in Turkey, which is a country outside the European Economic Area and for which there is no decision of the European Commission regarding the adequacy of the level of data protection. Therefore, there is a risk that your personal data will not benefit from the same level of protection as in the European Economic Area and you should consider this aspect when you give your consent to the processing of your personal data within the Website.

5. How long do we keep your personal data?

Except for the cases in which the applicable legal provisions set out or oblige us otherwise, we will keep your personal data for no longer than is necessary for the purposes for which the personal data are processed.
Thus:

• as regards the forms in the “Contact” section of the Website or the correspondence received through the means of contact posted on the Website (e-mail), we will keep your personal data for the period which is necessary in order to answer to your messages or requests and to prove the correspondence with you, as well as, in certain cases, like the existence of a litigation, for the period of the dispute settlement procedures before the courts of law or before other authorities with specific competences related to resolving the dispute in question; as regards the personal data collected through the cookies of the Website, such data will be processed during the lifespan of the cookies (as indicated in section 3 above).

In any case, if you will withdraw your consent, we will cease the processing of your personal data and erase them, except for the cases in which the applicable legal provisions set out or oblige us otherwise.

6. Which rights do you have with respect to your personal data?

Under the conditions set forth by the legal provisions on personal data protection, you have several rights regarding your personal data:

• the right of access – allows you to obtain confirmation as to whether your personal data are being processed by us and, if affirmative, the relevant details of such processing activities;
• the right to rectification – allows you to obtain the rectification of your personal data, if inaccurate;
• the right to erasure (“the right to be forgotten”) – allows you to obtain the erasure of your personal data in certain cases (for example, if you have withdrawn your consent and your consent was the only legal basis for processing your personal data);
• the right to restriction of processing – allows you to request us not to use your personal data, except to store them, when: (i) you contest the accuracy of your personal data (until the accuracy thereof will be verified); (ii) you are opposed to the erasure of your personal data, in case of unlawful processing thereof; (iii) you request us to provide you with certain data for the establishment, exercise or defence of a legal claim; (iv) you object to the processing of your data, under specific conditions;
• the right to object to the processing – allows you to object to the processing of your personal data, in the conditions and limits brought forth by the law;
• the right to data portability – allows you to receive your personal data you have provided to us, in a structured, commonly used and machine-readable format or to transmit this personal data to another data controller.

Likewise, as mentioned in section 2 above, where the processing is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You may exercise your abovementioned rights, by sending us a request in this respect, either through the form in the “Contact” section of the Website, or through the e-mail address or any of the postal addresses indicated in section 1 above.

Last but not least, you have the right to lodge a complaint with a supervisory authority.