Privacy

Privacy statement

Thank you for visiting our website https://s4fn.com and for your interest in our company. The protection of your personal data is important to us. Personal data is information about personal or factual circumstances of an identified or identifiable natural person. This includes e.g. name, address, telephone number and date of birth, but also all other data that can be related to an identifiable person.

Since personal data enjoy special legal protection, they are only collected by us insofar as this is necessary for the provision of our website and the provision of our service. Below we describe which personal information we collect during your visit to our website and how we use it.

Our data protection practice is in accordance with the legal regulations, in particular those of the general data protection regulation of the EU (GDPR). We will only collect, process and store your personal data insofar as this is necessary for the functional provision of this website and our content and services, as well as for the processing of enquiries and, where applicable, for processing of orders/contracts, but only insofar as there is a justified interest in this regard within the meaning of Art. 6 Para. 1 p.1 lit. f GDPR or any other provision of permission. Only if you have given your prior consent separately will your data be used for further purposes specific to the consent, such as sending promotional information by newsletter.

(1) Responsible body within the meaning of Art. 4 No. 7 GDPR

Responsible body in the sense of the GDPR and other national data protection laws of the member states as well as other data protection regulations:

S4FN Bilişim A.Ş.

Armağanevler Mah. Gürsel Sok. No:17-15

34760 Istanbul

Email: contact@s4fn.com

Telephone: +90 216 606 19 27

(2) Name and address of the data protection officer

S4FN Bilişim A.Ş.

Armağanevler Mah. Gürsel Sok. No:17-15

34760 Istanbul

Email: contact@s4fn.com

Telephone: +90 216 606 19 27

(3) Provision of the website and creation of log files

Each time you access our website, our system automatically collects data and information from the system of the accessing computer. The following data will be collected:

Scope of data processing

(1) Information about the browser type and the version used

(2) The operating system of the retrieval device

(3) The IP address of the retrieval device

(4) Date and time of access

(5) Websites and resources (images, files, other page content) accessed on our website

(6) Websites from which the user’s system accessed our website (referrer tracking)

This data is stored in the log files of our system. These data are not stored together with the personal data of a specific user, so that individual site visitors are not identified.

(4) Change of the data protection declaration

We reserve the right to change the data protection declaration in order to adapt it to changed legal situations or in the event of changes to the service or data processing. However, this only applies with regard to declarations on data processing. If user consents are required or components of the data protection declaration contain provisions of the contractual relationship with the users, the changes will only be made with the consent of the users. Users are requested to inform themselves regularly about the content of the data protection declaration.

(5) Special function of the website

Our website offers various functions, the use of which involves the collection, processing and storage of personal data by us. Below we explain what happens to these data:

(6) Statistical evaluation of visits to this website – Webtracker

We use the following web trackers to evaluate visits to this website:

(7) Integration of external web services and processing of data outside the EU

On our website we use active Javascript content from external providers, so-called web services. By accessing our website, these external providers may receive personal information about your visit to our website. In this case, processing of data outside the EU may be possible. You can prevent this by installing a Java Script Blocker such as the browser plug-in ‘NoScript’ (www.noscript.net) or by deactivating Java Script in your browser. This may result in functional restrictions on websites that you visit.

We use the following external web services:

(8) Information on the use of cookies

(9) TLS encryption

We protect the transmission of your data with a secure (AES 128 bit) TLS connection. TLS (Transport Layer Security) is a security technology that ensures that your personal data is transferred securely over the Internet and cannot be viewed by third parties. The following data is encrypted: all connection data.

(10) Data security and data protection, communication by email

Your personal data is protected by technical and organisational measures during collection, storage and processing in such a way that they are not accessible to third parties. In the case of unencrypted communication by e-mail, we cannot guarantee complete data security on the transmission path to our IT systems, so that we recommend encrypted communication or the post for information with a high need for confidentiality.

(11) Revocation of Consents – Data Information and Change Requests – Deletion & Blocking of Data

At appropriate intervals you have the right to free information about your stored data as well as the right to correction, blocking or deletion of your data at any time. Your data will be deleted by us on first request, if this is not contrary to legal regulations. You can revoke any permission you have granted us to use your personal data at any time. You can send requests for information, deletion and correction of your data and suggestions at any time to the following address:

S4FN Bilişim A.Ş.

Armağanevler Mah. Gürsel Sok. No:17-15

34760 Istanbul

Email: contact@s4fn.com

Telephone: +90 216 606 19 27

(12) Right to data transferability

You have the right for us to make available to you the personal data that you have transmitted to us in a structured, common and machine-readable format. You may also request that we transfer this data to a third party immediately on your first instruction, provided that the processing is based on a consent pursuant to Art. 6 para. 1 lit. a GDPR or Art. 9 para. 2 lit. a GDPR or on a contract pursuant to Art. 6 para. 1 lit. b GDPR and the processing is carried out by us within the framework of automated data processing.

In exercising this right of data transferability, you also have the right to have your personal data transferred directly to another responsible party, insofar as this is technically feasible. Freedoms and rights of other persons must not be affected by this.

The right to data transfer does not apply to the processing of personal data necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

(13) Right of appeal to the supervisory authority pursuant to Art. 77 para. 1 GDPR

If you suspect that your data is being illegally processed on our site, you can of course at any time bring about a judicial clarification of the problem. Irrespective of this, you have the option of contacting a supervisory authority. You have the right to appeal in the EU Member State of your place of residence, workplace and/or place of alleged infringement, i.e. you can choose the supervisory authority to which you apply in the above places. The supervisory authority to which the complaint was submitted will then inform you of the status and results of your complaint, including the possibility of a judicial remedy under Art. 78 GDPR.

(14) Newsletter

We use the information below to inform you about the contents of our newsletter and the subscription, delivery and statistical analyses procedures and your right to unsubscribe. By subscribing to our newsletter, you agree to receive our newsletter and the procedures described.

Contents of the newsletter: we only send out newsletters, emails and other electronic notifications containing promotional information (referred to below as “Newsletter”) with the consent of the recipient or with legal permission. Insofar as the contents of a newsletter are specifically described when a user subscribes to it, they are binding with regard to the consent granted by the user. In all other cases, our newsletter contains information about our services and our company.

Double opt-in and logging: subscribing to our newsletter takes place using what is referred to as the double opt-in procedure. This means that you receive an email after subscribing asking you to confirm your subscription. Confirmation is mandatory to ensure that nobody subscribes to the newsletter in your name with an email address that is not yours. Subscription to the newsletter is logged to prove that the subscription process has taken place in line with the legal requirements. This includes storing the time at which subscription and confirmation took place, along with the IP address. Likewise, changes to data stored on your person with the mailing service provider are logged.

Subscription data: to subscribe to the newsletter, you just need to provide your email address.

Germany: the dispatch of the newsletter and its related performance measurement is based on the consent granted by the recipient in accordance with Art. 6 (1) (a) and Art. 7 GDPR in conjunction with Sec. 7 (2) (3) Unfair Competition Act (UWG) based on statutory permission pursuant to Sec. 7 (3) UWG.

The logging of the subscription process is based on our legitimate interests in accordance with Art. 6 (1) (f) GDPR. Our interest lies in operating a user-friendly and secure newsletter system which serves both our business interests and the expectations of our users and also allows us to prove that consent has been granted.

Online access and data management: cases exist where we direct newsletter recipients to the MailChimp website. For example, our newsletters contain a link which recipients can click on to access the newsletters online (for example, if they encounter problems viewing the newsletters in their email programme). Newsletter recipients can also subsequently correct their data, such as their email address. Likewise, the MailChimp privacy policy is only available on their website.

In this context, we would like to point out that cookies are used on the MailChimp website and as a result personal data is processed by MailChimp, its partners and service providers (e.g. Google Analytics). We have no influence over the collection of this data. Further information can be found in the privacy policy of MailChimp.

Cancellation/Revocation - you can cancel your subscription to our newsletter at any time, i.e. revoke your consent. A link for unsubscribing from our newsletter can be found at the end of each newsletter. An individual request for deletion can be submitted at any time, provided that the existence of previous consent is confirmed at the same time.

We use this data exclusively for dispatching the requested information and offers within the context of our newsletter marketing.

(14.1) Newsletter - Mailing Service

The newsletter is mailed by the mailing service “MailChimp", a newsletter mailing platform from the US provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.

You can view the privacy policy from the mailing service provider here: https://mailchimp.com/legal/privacy/. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield Agreement and therefore provides a guarantee of compliance with the European level of data protection (https://www.privacyshield.gov/participant?id=a2zt0000000TO6hAAG&status=Active). We use the mailing service provider based on our legitimate interests according to Art. 6 (1) (f) GDPR and a contract processing agreement according to Art. 28 (3) (1) GDPR.

The mailing service provider is allowed to use the recipient’s data in a pseudonymous form, i.e. without assignment to a user, to optimise or improve their own services, e.g. for technical optimisation of the mailing service, to display the newsletter or for statistical purposes. However, the mailing service provider neither uses the data from our newsletter recipients for their own mailing activities, nor do they pass the data on to third parties.

(14.2) Newsletter - Success Measurement

Our newsletter contains what is referred to as a ‘web beacon’, i.e. a pixel-sized file, that is retrieved from our server when the newsletter is opened, or insofar as we use a mailing service provider, from their server. Technical information, such as information about your browser and system and your IP address and the time of retrieval is collected in the first instance when the newsletter is opened.

This information is used to improve the technical performance of our services based on the technical data or the target groups and their reading habits, based on their retrieval locations (which can be determined using the IP address) or access times. The statistical surveys performed also include determining if the newsletters are opened, when they are opened and which links are clicked on. Although this information can be assigned to individual newsletter recipients for technical reasons, it is neither our aim nor that of the mailing service provider, insofar as one is used, to surveil individual users. These evaluations serve us much more to determine the reading habits of our users and to adapt our content to them or to send different content according to their interests.

Status: February 2020