Privacy and Cookie Policy

Privacy and Cookie Policy
The purpose of this Privacy Policy is to determine the terms and conditions relating to the use of personal data shared with the Company by Platform users / members / visitors (“Data Subject”), or generated by the Company during the Data Subject’s use of the Platform, during the operation of the website www.priviasecurity.co.uk or priviahub.com (“Site”) and its mobile application (collectively referred to as the “Platform”) operated by Privia Security Ltd. (“Company”).

The Data Subject declares that they have been informed regarding the processing of their personal data through this Privacy Policy and that they consent to the use of their personal data in the manner specified herein.

What Data is Processed?
Under this heading, the data processed by the Company and considered personal data pursuant to the Personal Data Protection Law No. 6698 are listed. Unless otherwise expressly stated, within the scope of the terms and conditions set forth under this Privacy Policy, the term “personal data” shall cover the following information:

Behavioural Advertising

In accordance with Articles 3 and 7 of the Personal Data Protection Law, data that has been rendered anonymous in an irreversible manner shall not be considered personal data under the provisions of said Law, and processing activities related to such data shall be carried out without being bound by the provisions of this Privacy Policy.

For What Purposes is Data Used?
The Company may process personal data for the purpose of customising the products and services offered by the Company in accordance with the preferences, usage habits and needs of the relevant persons and recommending them to such persons; using them within the scope of direct and indirect marketing activities; and transferring them to the Company’s representatives, solution partners and third parties from whom it receives services for these purposes.

Pursuant to Articles 5 and 8 of the Personal Data Protection Law and/or in the presence of exceptions under applicable legislation, the Company may process personal data and share it with third parties without obtaining the Data Subject’s separate consent. The main instances of such situations are set out below:

Being explicitly stipulated by laws,
Being mandatory for the protection of the life or physical integrity of a person who is unable to disclose their consent due to actual impossibility or whose consent is not legally valid, or of another person,
Being mandatory for data processing for the establishment or performance of a contract, provided it is directly related to the parties of a contract,
Being mandatory for the Company to fulfil its legal obligations,
Being mandatory for data processing for the legitimate interests of the Company, provided that the fundamental rights and freedoms of the Data Subject are not harmed.
Who Can Access the Data?
The Company may transfer personal data and new data obtained by using such personal data to third parties from whom the Company receives services, solely for the purpose of providing such services, in order to achieve the purposes set out in this Privacy Policy. The Company may also transfer data to the Company’s business partners and suppliers, as well as legally authorised institutions and organisations, within the purposes specified in this Privacy Policy.

For the purpose of improving the data subject’s experience (including improvement and personalisation), ensuring data subject security, detecting fraudulent or unauthorised uses, conducting operational evaluation research, resolving errors related to Platform services and for the management of customer relations in order to fulfil any of the purposes set out in this Privacy Policy; the Company may share data with third parties such as companies providing hosting, data analysis, infrastructure services, information technology services, customer services, e-mail services, credit card processing, audit services and similar services, as well as call centres.

The data subject acknowledges that, subject to the purposes specified above, the aforementioned third parties may store the data subject’s personal data on servers located anywhere in the world, and declares their advance consent to this matter.

About the Right of Access to Data and Correction Requests
Pursuant to Article 11 of the Law, data subjects have the right to:

Learn whether personal data is being processed,
Request information if personal data has been processed,
Learn the purpose of processing personal data and whether they are being used in accordance with their purpose,
Know the third parties to whom personal data has been transferred, whether domestically or abroad,
Request the rectification of personal data in the event it is incomplete or incorrectly processed, and request that the transaction carried out in this context be notified to the third parties to whom personal data has been transferred,
Request the deletion or destruction of personal data in the event the reasons requiring its processing have ceased to exist, despite the fact that it has been processed in accordance with the provisions of the Law and other relevant laws, and request that the transaction carried out in this context be notified to the third parties to whom personal data has been transferred,
Object to the emergence of a result against the person themselves through the analysis of processed data exclusively by automated systems,
Request the remedy of damages in the event of suffering a loss due to personal data being processed unlawfully.
The aforementioned rights, when communicated by personal data subjects through the methods specified in the Personal Data Protection and Processing Policy of Privia Security Ltd. at priviahub.com or www.priviasecurity.co.uk, shall be evaluated and concluded as soon as possible and in any case within 30 (thirty) days. While it is the principle that no fee shall be charged in relation to requests, the Company reserves the right to charge a fee over the fee schedule determined by the Personal Data Protection Board.

The data subject acknowledges that in the event of making a request that would result in any of their personal data being rendered unusable by the Company, they may not be able to fully benefit from the Platform’s operation, and declares that all liability arising in this context shall belong to them.

Retention Period of Personal Data
The Company shall retain the personal data provided by the data subject for as long as required by the processing purposes specified above.

In addition, in the event of any dispute arising between the Company and the data subject, the Company may retain personal data for the purposes of carrying out the necessary defences, limited to such purposes and for the duration of the statute of limitations periods determined under applicable legislation.

Security Measures and Commitments Regarding Data Security
The Company commits to taking the necessary technical and administrative measures and carrying out the necessary audits in order to ensure the appropriate level of security to prevent personal data from being processed unlawfully, prevent unauthorised access to personal data, and to ensure the preservation of personal data, under the conditions determined in the applicable legislation or expressed in this Privacy Policy.

The Company may not disclose the personal data it obtains about the Data Subject to others in violation of the provisions of this Privacy Policy and the Personal Data Protection Law, nor may it use such data outside the purpose of processing.

In the event that links are provided to other applications through the Platform, the Company bears no responsibility for the privacy policies and content of those applications.

Cookies
Cookies are used on the Platform in order for Data Subjects to benefit from the Platform in the most efficient manner and to improve the user experience. If you prefer not to use cookies, you can delete or block cookies from your browser settings. However, we would like to remind you that this may affect your use of the Platform.

What are Cookies and Why are They Used?
Cookies are small text files stored on your device or network server through browsers by the websites you visit. For more detailed information about cookies, you can visit aboutcookies.org.

The main purposes of using cookies on our Website are listed below:

To improve the services offered to you by increasing the functionality and performance of the website,
To improve the Website and offer new features through the Website, and to personalise the offered features according to your preferences;
To ensure the legal and commercial security of the Website, yourself and our Company.
To use within the scope of direct and indirect marketing activities.
Categories of Cookies Used on the Site
Technical Cookies: Technical cookies ensure the functioning of the Site and identify pages and areas of the website that are not working.

Authentication Cookies: In the event that visitors log into the Site using their passwords, such cookies identify the visitor as a site user on each page they visit on the Site, thus preventing the user from having to re-enter their password on each page.

Flash Cookies: These are types of cookies used to activate image or audio content on the Site.

Personalisation Cookies: These are types of cookies used to remember users’ preferences when visiting different pages of different websites.

Cookies Used on the Platform
Advertising: Used for the purpose of showing behavioural and targeted advertisements to visitors. It is possible to accept or reject via browser settings.

Analytical Cookies: Collected solely for analysis purposes.

Market Analysis: Used for the purpose of conducting market analysis. It is possible to accept or reject via browser settings.

Campaign / Promotion: Used to measure the impact of campaigns. It is possible to accept or reject via browser settings.

Facebook: Such cookies enable the tracking of Facebook members (or non-members) for market analysis and product development purposes. It is possible to accept or reject via browser settings.

Twitter: Such cookies are used to track members or non-members of social media networks for market analysis and product development purposes. It is possible to accept or reject via browser settings.

Google: Such cookies are used to collect all statistical data, and in this way cumulative statistical data such as whether the Site is used continuously, how frequently each page is visited and the duration of visits are retained. For more information about Google’s analytical data processing activities and principles regarding personal data protection, you can click here. Cookie Controls: tools.google.com/dlpage/gaoptout

Session: Session cookies are used to ensure session continuity. It is possible to accept or reject via browser settings.

Load Balancing: Load balancing cookies are used to reduce server load by distributing the load. It is possible to accept or reject via browser settings.

Security: Security cookies are used for security checks. It is possible to accept or reject via browser settings.

Fraud Detection: Used to detect click fraud. It is possible to accept or reject via browser settings.

User ID: User ID cookies are used to ensure that users only see their own information. It is possible to accept or reject via browser settings.

Language: Records the language selected by the user and offers options accordingly. It is possible to accept or reject via browser settings.

Mobile: If the user is visiting the Site from a mobile device, it is used to display the main website (for example, whether the device has Flash enabled), or that they are on a mobile site that does not require Flash. The source site is recorded for better understanding of user preferences. It is possible to accept or reject via browser settings.

Can the Use of Cookies be Blocked by Data Subjects?
Data subjects have the opportunity to personalise their preferences regarding cookies by changing their browser settings. If the browser being used offers this option, it is possible to change cookie preferences through browser settings. Thus, while it may vary depending on the options offered by the browser, data subjects have the ability to block the use of cookies, choose to receive a warning before cookies are used, or to disable or delete only certain cookies.

Cookie preferences may need to be made separately for each device through which the user accesses the Platform.

Changes to the Privacy Policy
The Company may amend the provisions of this Privacy Policy at any time. The current Privacy Policy shall enter into force on the date it is presented to the Data Subject by any method.