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- special characters: _-/()+*.:,;#$%&=?!

Spaces and umlauts will not be accepted.
Passwords marked "too weak" will not be accepted.

Further hints to create a very secure password
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- use more than one special character

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Your corporate benefits Support Team

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Date of birth & ZIP code:
The optional Date of Birth and ZIP Code fields will be used for internal purposes in order to provide a targeted search of new providers and offers and to optimize search results.

Private e-mail address & password:
In order to be able to log in to the platform, you need to submit a private e-mail address and a password of your choice.

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To complete the registration process, please enter the provided registration code. <FONT COLOR="#FF3333">You will find the registration code on the flyer.</FONT>  Data privacy:
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Terms of use

CONDITIONS OF USE

 

1.               Scope

1.1            These terms of use for membership ("Terms of Use") set out the conditions for membership of the online presentation platform for access to employee offers ("Platform").

1.2            The employee offers on the Platform are intended only for Members who use the offers as consumers, as defined in the Law No. 6502 on Consumer Protection. It is strictly forbidden to use the offers for commercial purposes, including but not limited to the commercial purchase and/or sale of products and services. However, cb Turkey cannot be held responsible for any commercial sales made in violation of this provision.

1.3            Center, Ataturk Mah. Ertuğrul Gazi Sk. Metropol İstanbul C1 Blok No: 2 b Inner Door no: 187 Ataşehir/ İstanbul, Corporate Benefits Turkey Internet Marketing and e-Commerce Platform Anonim Şirketi ("cb Turkey") is the operator of the Platform.

 

2.               Content of the Platform and the Role of cb Turkey

2.1            On the Platform, various third party companies ("Sellers") offer goods and services, coupon codes, discount codes, advantages, etc. that can be purchased or used outside the Platform and through their own websites. These offers are made available to the Members. These offers are intended for company employees, association or club members ("Member" or "Members"). cb Turkey operates a platform solely for the offering of goods and services by Vendors and DOES NOT SELL any of the goods and services offered on the Platform.

2.2            Sellers can be identified by their logos on the Platform. Members can access an imprint containing the contact information of the Seller from each Seller's website accessible through the Platform. The intellectual property rights regarding the content of the Seller displayed on the Platform belong to the relevant Seller.

2.3            Contracts for the purchase of goods or other services are concluded between Members and Sellers and outside the Platform.

2.4            Sellers are solely responsible for the content and presentation of the goods and services advertised on the Platform. Each Seller also decides in its sole discretion whether to limit the time and/or amount of discounts, goods and services. cb Turkey does not control the content provided by the Seller. Therefore, cb Turkey is not responsible for the accuracy of the information provided by Sellers or for any disruptions in the provision of their websites, products or services.

 

3.               Membership Registration, Acceptance of Terms of Use,

3.1            In order to use the Platform, the Member is required to register for membership on this website and create a Member account. Membership to the Platform is free of charge.

3.2            Membership registration can be realized with an e-mail address used by the Member.

3.3            After the Member submits the online registration form, cb Turkey will send an activation code to the e-mail address provided by the Member. By sending this code, cb Turkey invites the Member to enter into a contract based on the Terms of Use and the Member accepts these Terms of Use by entering the activation code into the Platform. The Member hereby accepts and declares that he/she has entered into a membership agreement with cb Turkey.

3.4            The membership record is kept by cb Turkey. The Member can always access the current version of the Terms of Use via the "Terms of Use" link on the Platform.

3.5            The Member accepts and undertakes that the information and contents provided by the Member within the Platform are accurate and lawful. cb Turkey is not obliged and responsible for investigating the accuracy of the information and contents transmitted or modified and provided by the Member, undertaking and guaranteeing that such information and contents are safe, accurate and lawful, and is not responsible for any damages arising from the incorrect or inaccurate information and contents.

 

4.               Access to and use of the Platform; breach of the Terms of Use

4.1            The Platform is not a site available to everyone who becomes a member. The offers on the Platform are intended only for employees of companies that have been provided with a platform by cb Turkey. Those who do not meet this condition cannot use the Platform. If cb Turkey determines that this condition has been violated, the sanctions set out in Articles 6 and 7 of the Terms of Use will be applied to the relevant person. The services provided through the Website are free of charge for the Members.

4.2            The Offers are intended only for Members who redeem the offers or coupon or discount codes as consumers. Any use of the Offers or coupon or discount codes for commercial purposes, including but not limited to the commercial purchase, commercial offering for sale or commercial resale of goods purchased at a discount, is prohibited. In case of breach of this provision, any and all damages incurred by cb Turkey shall be indemnified in kind and cb Turkey shall have full recourse to the Member for any compensation, administrative/judicial fines that the Member may have to pay to public institutions and/or third parties due to the Member's behavior in violation of the Terms of Use.

4.3            Proof of authorization to use the Platform pursuant to Article 4.1 shall be made (i) by entering an e-mail address from a site dedicated by cb Turkey to the company providing the platform or (ii) by entering a code provided exclusively by cb Turkey to employees of the company providing the platform. In case of provision of a code, Members are under an obligation to keep this code confidential and in case of breach of this obligation, cb Turkey reserves its rights under these Terms of Use, including the provisions of clause 7.3.

4.4            Members may not share their Platform account information with other persons; they are obliged to keep this information confidential. In the event that the Member realizes that third parties have access information, the Member is obliged to immediately change this information and immediately notify cb Turkey of any malicious use of his/her account by third parties. The Member is directly responsible for such malicious use. Likewise, the Member may not use someone else's IP address, e-mail address, user name and other information on the internet, nor may the Member access or use the private information of other Members without permission. Any legal and criminal liability that may arise from such use belongs to the Member.

4.5            The Member is obliged to inform cb Turkey immediately if he/she leaves the company to which he/she is assigned as an employee of the Platform. Upon leaving the company, the Member's right to access and use the Platform will also end.

 

  1. 5.               Confidentiality of offers, coupons and discount codes

5.1            The offers and terms and conditions on the Platform are provided by the relevant Sellers exclusively to the Platform's Member groups (subject to the terms of the agreement with the sellers).

5.2            Offers and their terms and conditions as well as coupon or discount codes are trade secrets of cb Turkey and Members are obliged to keep them confidential and not to transfer them to third parties. The transmission of coupons or discount codes obtained by the Member through the Platform to third parties, the publication of such coupons or discount codes on the internet, the sale of such coupons or discount codes offline or online, the transmission and dissemination of screenshots of coupons or discount codes related to corporate benefits to the public by the Member shall constitute a breach of the Terms of Use and shall be subject to the provisions of Article 6 (penal clause) and Article 7.3 (termination of membership).

5.3            In addition to the above, the provisions of the Turkish Criminal Code No. 5237 shall apply if trade secrets are not kept.

 

6.               Penal Charter

6.1            In case of breach of the following Terms of Use by the Members,

-       article 1.2 (use of the platform and its offers for commercial purposes),

-       clause 4.1 (use of the Platform without being an employee of a company to which cb Turkey provides the Platform),

-       article 4.2, (the purchase, commercial sale or commercial resale of goods purchased at a discount for commercial purposes), or

-       Article 4.3(ii) (public disclosure of access codes)

-       article 5.2 (public communication and distribution of coupons or discount codes)

Members accept and declare that they are liable to pay cb Turkey a penalty clause in the amount of TL equivalent of €500 calculated at the exchange rate of the Central Bank on the date of payment. In the event that these violations are repeated more than once by the Member, the Member agrees and declares that he/she is obliged to pay a penalty clause to cb Turkey in the amount of TL equivalent of €2,000 calculated at the exchange rate of the Central Bank on the date of payment.  

6.2            The Member and cb Turkey agree that any penalties payable under this Section 5 may be set off against any claims for damages against cb Turkey arising out of the same event.

 

7.               Termination of Membership, Suspension, Restriction or Modification of Offer and Deletion of Member Account

7.1            The Member may delete his/her account at any time without giving any reason through the "Delete Access" item in his/her profile. The Member may terminate his/her contract without giving any reason or cb Turkey may cancel his/her membership and delete his/her account by sending an e-mail to cb Turkey support@cb-as.com.tr. The authorization of the user who terminates his/her membership to use the Platform as a Member will be canceled.

7.2            cb Turkey shall have the right to terminate the Member's membership and block the Member's access to the Platform at any time by notifying the Member in writing to the e-mail address used by the Member for the Platform two business days in advance.

7.3            In case of breach of Articles 1.2, 4.1, 4.2, 4.3 or 5.2 of the Terms of Use, cb Turkey shall be entitled to suspend or restrict the Member's access to the Platform account and terminate the membership without any notice and with immediate effect. In this case, cb Turkey's other rights and claims are reserved.

7.4            In addition to the above, the Member and cb Turkey reserve the right to terminate the agreement between them for cause.

7.5            Upon termination or expiration, the Member's account and access to the Platform will be deleted.

 

8.               Limitation of Liability

8.1            The Member agrees that cb Turkey's liability in the event of slight negligence is limited to breach of a material contractual/ Terms of Use obligation. For the purposes of this clause, material contractual obligations are those obligations which must be imposed on the member in accordance with the meaning and purpose of the contract or the fulfillment of which ensures the proper performance of the contract and on which the member can rely on regular compliance.

8.2            In the case of liability arising from slight negligence, such liability shall be limited to damages that were foreseeable or typical at the time the contract was concluded. In such cases, cb Turkey's liability shall be limited to foreseeable direct damages and shall not include claims for indirect damages or lost profits.

8.3            The personal liability of cb Turkey's employees, legal representatives and agents is subject to cb Turkey's exclusions and limitations of liability set out in these Terms of Use. All limitations of liability also apply to all legal (including tort) and contractual claims arising out of the use of the Platform or the member relationship.

8.4            The limitations of liability set forth in these Terms of Use do not apply in cases of intent or gross negligence and the provisions of law shall apply in such cases.

 

9.               Intellectual Property

9.1             The Member may not use, resell, share, distribute, display, exhibit, reproduce, process, create derivative works of, prepare derivative works from or prepare works subject to cb Turkey's copyrights on the Platform under any circumstances. Otherwise, the Member shall be liable for all damages that cb Turkey may incur.

9.2            Copying or using the software used in the design and database creation of the Platform, all rights to which belong to cb Turkey, is strictly prohibited.

 

10.            Privacy

10.1        cb Turkey may use the information of the Members in accordance with the regulations in the Clarification Text and the Personal Data Protection Policy. cb Turkey shall not make the confidential information of the Members available to third parties and institutions, except as otherwise permitted in the User Agreement.

 

11.            Applicable Law and Competent Court

11.1        The validity, interpretation and performance of these Terms of Use shall be governed by the laws of the Republic of Turkey and the Istanbul Central Courts and Enforcement Offices are hereby authorized to settle any dispute arising out of the Terms of Use.

 

12.            Amendment of the Terms of Use

12.1        cb Turkey, at its sole discretion and unilaterally, has the right to change any provision of these Terms of Use and its annexes at any time. The Member shall be informed about the changed terms and conditions. When the Member accepts the new terms and conditions by approving them at the next login, the amended terms and conditions become part of the agreement. Refusal of approval shall be deemed as termination of the account by the Member.

 

13.            Force Majeure

13.1        The term force majeure shall be construed as unavoidable events beyond cb Turkey's reasonable control and which cb Turkey is unable to prevent despite exercising due diligence, including but not limited to acts of God, riots, war, strikes, attacks on the Platform and the system despite cb Turkey taking the necessary information security measures.

13.2        11.2. In all cases of force majeure, the Member and cb Turkey shall not be liable for late or incomplete performance or non-performance of any of the acquisitions specified in these Terms of Use.

 

14.            Validity of Records

14.1        The Member accepts, declares and undertakes that the electronic and system records, commercial records, book records, microfilm, microfiche and computer records kept by cb Turkey in its own database, servers shall constitute valid, binding, conclusive and exclusive evidence in disputes that may arise from these Terms of Use and that this article is an evidence contract within the meaning of Article 193 of the CCP.

 

15.            Notification Addresses

15.1        The e-mail address used by the Members when opening an account with cb Turkey shall be deemed to be the legal address for any notifications to be made in relation to these Terms of Use.

 

16.            Enforcement

16.1        The Member declares, accepts and undertakes that he/she has read, understood and accepted all of the articles contained in these Terms of Use and confirms the accuracy of the information he/she has provided about himself/herself.

 

 

Privacy statement

CLARIFICATION TEXT AND POLICY ON THE PROCESSING AND PROTECTION OF PERSONAL DATA

 

I.        Data Controller

 

Corporate Benefits Turkey Internet Pazarlama ve E-Ticaret Platformu Aracılık Hizmetleri A.Ş. ("cb Turkey")


Address Ataturk Mah. Ertugrul Gazi Sk. Metropol Istanbul C1 block no: 2 b Interior Door no:187 Ataşehir/ Istanbul


 As the owner of the website provided by Cb Turkey with a separate domain dedicated to you or your company (hereinafter referred to as the "Website"), Corporate Benefits Turkey Internet Pazarlama ve E-Ticaret Platformu Aracılık Hizmetleri A.Ş. aims to take all necessary technical, legal and managerial measures regarding the processing and protection of personal data and to fully demonstrate all due diligence.


The Clarification Text and Policy on the Processing and Protection of Personal Data ("cb Turkey KVK Policy") regulates the principles adopted in the protection and processing of personal data of natural persons ("User") who register on the Website to benefit from the goods and services of the sellers offered at advantageous prices on the Website.


II.        General Information on Personal Data


1.       Scope of Processing Personal Data

1.1            In principle, cb Turkey collects and uses the personal data of its Users only to the extent necessary to provide content and services through a functional Website. The collection and processing of Users' personal data regularly takes place only with the consent of the User. Regarding the exceptions to this, cb Turkey is subject to the regulations of the Law No. 6698 on the Protection of Personal Data ("LPPD").


2.       Legal Basis for Data Processing

2.1    cb Turkey does not process personal data without the explicit consent of the data subject.

2.2    In the presence of one of the following conditions, it is possible for cb Turkey to process personal data without seeking the explicit consent of the data subject:

  1. Explicitly stipulated in the law.
  2. It is mandatory for the protection of the life or physical integrity of the person who is unable to disclose his/her consent due to actual impossibility or whose consent is not legally valid.
  3. Provided that it is directly related to the conclusion or performance of a contract, it is necessary to process personal data of the parties to the contract.
  4. cb It is necessary for Turkey to fulfill its legal obligation.
  5. It has been made public by the person concerned.
  6. Data processing is mandatory for the establishment, exercise or protection of a right.
  7. Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.


3.       Data Retention Period

cb Turkey retains personal data for the purpose of providing its services for the period during which the services are provided.


cb Turkey may also store and process personal data in accordance with the provisions of other laws to which it is subject within the scope of the service it provides.


cb Turkey deletes, destroys or anonymizes personal data ex officio or upon the request of the data subject in the event that the reasons requiring the processing of personal data disappear or the periods in other personal data processing/storage regulations to which it is subject expire.


III.        Scope of Stored and Processed Personal Data

 

4.       Website and log files

 

4.1    Type and scope of processed data

Each time the Website is accessed, the following data and information are received from the computer accessing the Website through the cb Turkey data recording system:

a)               Information about the browser type and version used

b)               User's operating system

c)               IP address of the user

d)               Date and time of access

e)               Websites accessed by the user's system through the Website

The data is also stored in the log files of the data recording system. This data is not stored together with other personal data.

When a voucher code is generated, the following personal data is stored to protect against misuse (e.g. commercial resale)

a)     Coupon Code

b)     Offer

c)     Company portal where the voucher code is offered

d)     Name, surname

e)     User's e-mail address

f)      Time of generation of the voucher code (date and time)

g)     User's IP address


4.2    Legal basis

The legal basis for the temporary storage of data and log files is paragraph 5.2(f) of KVKK.


4.3    Purpose of Data Processing

The temporary storage of the IP address by the data recording system is necessary for the Website to be made available to the user's computer. For this purpose, the User's IP address is stored for the duration of the session.


The storage in log files is done in order to ensure the functionality of the Website. Furthermore, the data is used to optimize the Website and to ensure the security of cb Turkey information technology systems. In this context, data is not processed for marketing purposes.


Cb Turkey's data processing activities within this scope are based on its legitimate interests.


4.4    Rights of the data subject

Collecting data and storing data in log files for the purpose of presenting the Website to the User's computer is necessary for the Website to function correctly. For this reason, the User cannot be granted the right to object to a result that arises against him by analyzing the data exclusively through automated systems or to request the deletion of this data.


5.       Use of Cookies

 

5.1    Type and scope of processed data

The Website uses cookies. Cookies are low-dimensional rich text formats that allow certain information about users to be stored on users' terminal devices when a website is visited. When a user visits a website, a cookie may be stored on the user's operating system. This cookie contains a characteristic string that allows the browser to be uniquely identified when the website is revisited.

cb Turkey uses cookies to make the Website user-friendly. Some elements of the Website require the browser to be re-identified even when a new page is visited.

The following data is stored and transmitted in cookies:


  • An identity that allows user identification

The Website uses external services and cookies to collect statistical data and improve advantageous offers. The figures obtained as a result of these services are used to show the "top 5 offers from colleagues" on a company platform.

Each time the User accesses the Internet content provided by the cb Turkey portal, certain information transmitted by the User's browser during the registration process for web control is collected and evaluated. Such collection is carried out through a pixel placed on each page. The data collected are as follows:

-       Request (filename of the requested file)

-       Browser type/version (e.g. Internet Explorer 6.0)

-       Browser language (e.g. Turkish)

-       Operating system used (e.g. Windows XP)

-       internal resolution of the browser window

-       screen resolution

-       JavaScript activation

-       Turn Java on/off

-       cookie information on/off

-       color depth

-       referrer URL (previously visited page)

-       abbreviated IP address for geographic identification

-       access time

-       Clicks on the Website


The Service Provider stores the IP address of the User only in a shortened (anonymized) form and uses it only for session recognition, geolocation and to fend off cyber-attacks. The IP address is then immediately deleted so that the data collected remains anonymous.

The following cookies are used in this context:

-       Session cookie (for session recognition)

5.2    Legal basis

The legal basis for the processing of cookies containing personal data is paragraph 5.2(f) of the KVKK.


5.3    Purpose of Data Processing

The purpose of using technically necessary cookies is to facilitate the use of websites for users. Some features of the Website cannot be provided without the use of cookies. Therefore, the browser must be re-recognized each time a new page is visited.


6. Use of a Content Delivery Network (CDN) and Security Services (MyraSecurity)

 Description, Purpose and Scope of Data Processing

For optimizing loading times (performance), increasing reliability and protecting our IT infrastructure against malicious attacks (e.g. so-called DDoS attacks) we have implemented a content delivery network (CDN).

For this purpose, we use the services of Myra Security GmbH, Landsberger Straße 187, 80687 Munich, Germany ("MyraSecurity").

A CDN is a network of regionally distributed servers that helps making available content from our website to you faster and more securely – including but not limited to static files, such as images, JavaScript and CSS files. From a technical point of view, MyraSecurity serves as a so-called reverse proxy. This means that the traffic between your device and our servers is routed through MyraSecurity's infrastructure for speeding up delivery and analyzing and defending against potential threats.

Within such process, technical protocol data (so-called access logs) are processed. These include, but shall not be limited to:

  • Your IP address
  • Date and time of access
  • The requested content (e.g. URL) and
  • Information about your browser and operating system (e.g. user-agent)

The processing of this data is technically required to ensure the stability, performance and security of our website.

 Legal basis for data processing.

The legal basis for the use of MyraSecurity is our legitimate interest in providing our platform securely, quickly and reliably in accordance with Art. 6 (1) (f) GDPR.

 MyraSecurity acts for us solely as a technical service provider bound to our instructions. We have concluded a contract processing agreement with MyraSecurity in accordance with Art. 28 GDPR. This ensures that the data is processed only according to our instructions and not for MyraSecurity's own purposes. The data processing takes only place in data centres within the European Union (EU) or the European Economic Area (EEA). MyraSecurity does not use its own cookies for this service to analyze user behavior.

 Duration of storage

The access logs containing your IP address are stored for a maximum period of 10 days to ensure stability and security and are automatically deleted or anonymized afterwards.


7.       Authorized Electronic Message (Newsletter) Sending

 

7.1    Type and scope of processed data

Free newsletters can be subscribed to on the Website. Registration for the monthly newsletter can be done at the same time as registration on the Website. In addition, the newsletter can be subscribed to at any time in the "My data" field. Below are the data taken from the login form when registering for the newsletter:

  • Gender (for addressing purposes)
  • Name and surname
  • Date of birth 
  • Company e-mail address 
  • Password
  • Registration date and time
  • Distributor engagement (company platform)

In addition to monthly newsletters, once the registration and login process is complete, you can subscribe to a special newsletter that will be sent at irregular intervals.


User consent is obtained during the registration process for the purpose of data processing and cb Turkey's KVK Policy is referred to.


For the purpose of sending newsletters, data is shared with a marketing automation and digital data analysis company. This data is only used for sending the newsletters.

In order to send the newsletters, the following personal data is shared with the service provider company:

  • Gender (for addressing purposes)
  • Company e-mail address
  • Surname
  • Distributor engagement (company platform and newsletter type)


7.2    Legal basis

In case the User consents after the User registers to the newsletter, the legal basis for data processing is paragraph 5.2(f) of the KVKK.


7.3    Purpose of Data Processing

Data on the user's e-mail address is collected for the purpose of transmitting the newsletter. The collection of other personal data during the registration process serves to prevent misuse of the services or the e-mail address used.


7.4    Rights of the data subject

The newsletter subscription can be terminated at any time by the user concerned. For this purpose, each newsletter contains a link to the employee's "My Data" section. Using this link, the employee can unsubscribe from the newsletters.


The "My data" section transparently shows when a monthly newsletter or special newsletter was ordered or canceled.


The right of the user to change or remove communication permissions from the settings section of the membership is secured by the Electronic Communication Law No. 5809.


8.       User Registration

 

8.1    Type and scope of processed data

On the Website, Users are offered the opportunity to register on the portal by providing their personal data. This data is entered into a login form, transmitted to cb Turkey and stored. None of this data is transferred to third parties. Below are the data collected during the registration process:

  • Gender (for addressing purposes)
  • Name and surname
  • Date of birth 
  • Company e-mail address and permission for electronic submission
  • Password
  • Registration date and time


The User's consent to the processing of this data is obtained as part of the registration process. In addition, the following data is stored:

  • Language preference for multilingual platforms
  • Location (web browser shared by the user. The user can also specify the location manually)
  • Registration date
  • Timestamp registration code
  • Timestamp with registration for monthly email newsletter
  • Timestamp with registration in a special newsletter
  • Acceptance of the User Agreement and Privacy Policy
  • Connected business platform
  • Login with timestamp
  • APP Usage iOS / Android Yes / No
  • Bids saved in the watchlist
  • Generation of coupon codes
  • Storage of vouchers
  • Content of contact forms
  • Content of the recall form
  • User reviews with timestamp of offers

iOS/Android app 

  • Access to location (automatic detection of location / new - send push message if the branch in the watchlist is nearby)
  • Access to the camera (QR code scanning)
  • Receiving push messages - New offers Yes / No
  • Receiving push messages - Expired offers Yes / No
  • Receiving push messages - Near the branch in the watchlist Yes / No


8.2    Legal basis

The processing of data collected during subscription takes place due to different legal grounds:

  • The legal basis for the processing of the data that is essential for providing access to the Portal and user administration (first name, last name, email address), shall be Art. 6 para. 1 lit. b GDPR (performance of contract).
  • The legal basis for the processing of the optional data (e.g. title, date of birth, postal code) shall be Art. 6 (1) (a) GDPR if the user has provided his consent
  • The legal basis for collecting the salutation is Art. 6 (1) (f) GDPR (legitimate interest). The details of our legitimate interest and the balancing of interests carried out can be found under Section 3.
  • The legal basis with respect to the fingerprinting for access control and abuse prevention is Art. 6 para. 1 sentence 1 lit. f GDPR (legitimate interest).


8.3    Purpose of Data Processing and Legitimate Interests

For making available certain content and services on our website the user needs to subscribe. With successful subscription, the user gains access to our platform for employee offers. [...] Collecting personal data within the subscription process serves to identify and address users, support requests, legal evidence, marketing and target group analyses and to display saved offers.

Justification of the legitimate interest in collecting the salutation (Art. 6 para. 1 lit. f GDPR):

The salutation is collected for safeguarding our legitimate interest in high-quality, addressee-oriented and professional communication. We consider appropriate communication in the context of support, system notifications, and general provision of information to be essential for ensuring the quality of service and maintain the relationship of trust with our users. In our opinion, your interests and fundamental rights do not outweigh our stated interest in the necessary balancing, as the use of a customary form of address ("Mr" or "Mrs") is a common and reasonably expected practice in business transactions. Our analysis has shown that our interest in a structured basis for professional communication outweighs the interest of the data subjects in these circumstances.

Justification of the legitimate interest for fingerprinting (Art. 6 para. 1 lit. f GDPR):

We process a fingerprint generated by your device or browser to safeguard our legitimate interests in ensuring platform integrity and preventing abuse. Our business model is based on granting exclusive benefits to authorized users only (employees of partner companies). This model is existentially endangered by the unauthorized disclosing of access data, automatically creating accounts and commercially using discounts.

Protecting your account only with username and password is not sufficient for this purpose, as access data can be easily shared. Fingerprinting is therefore necessary to detect and stop patterns of abuse and to ensure that the terms of use are respected. The affection of your rights is kept as low as possible: The fingerprint created is pseudonymous, is used exclusively for this security purpose, is not passed on to uninvolved third parties and is not used for advertising or tracking purposes beyond our platform. When balancing the interests, our compelling interest in protecting our service and the entire user community from fraud and abuse outweighs your interest in protecting this specific technical data, particularly with you as authorized user also having an interest in the exclusivity and security of the platform.


8.4    Rights of the data subject

Users have the option to cancel their registration at any time. Stored data on users can be changed at any time. The access account can be deleted or changes can be made in this area through the "Delete Access" link in the "My Data" section.


9.       Contact Form and Email Contact


9.1    Type and scope of processed data

The Website contains a contact form to contact cb Turkey online. When the User accepts this option, all data entered in the input form is transmitted to cb Turkey and stored. These data are the following:

  • Gender (for addressing purposes)
  • Name and surname
  • Email address
  • Subject of the message
  • Content of the message
  • Browser type/version
  • Operating system used


When the message is sent, the following data is also stored:

  • User IP address
  • Date and time of sending the message


Instead of the contact forum, it is also possible to contact cb Turkey via e-mail. In this case, the personal data transmitted by the user via e-mail will be stored.




9.2    Legal basis

In case the User consents, the legal basis for data processing is Article 5.1 of the LPPD.


The legal basis for the processing of data transmitted during e-mail transmission is Article 5.2/f of the KVKK. If it is intended to conclude a contract by e-mail communication, in this case, the additional legal basis for the processing of data is Article 5.2/c of the KVKK.


9.3    Purpose of Data Processing

Personal data received from the contact form is processed only for the purpose of processing the communication. In the communication via e-mail, the relevant data is processed due to the necessary legitimate interest as well as the processing of the communication.


Other personal data processed during the submission process is used to prevent misuse of the contact form and to ensure the security of our information technology systems.


9.4    Rights of the data subject

The User has the option to withdraw his/her consent to the processing of his/her personal data at any time. The User may object to the storage of his/her personal data at any time by contacting cb Turkey by e-mail. In such a case, the communication cannot be continued. All personal data stored during the communication will be deleted in this case.


 IV.        Transfer of Personal Data


9.       Transfer of Personal Data Abroad

Our Company may also transfer personal data abroad for processing in Turkey or for processing and storage outside Turkey, including outsourcing, in accordance with the conditions stipulated in the KVKK and other relevant legislation and by taking the security measures specified in the legislation, as mentioned above.

Cb Turkey, KVKK 5. Within the scope of Article 5; (i) the processing of the User's personal data is necessary in this context, directly related to the establishment and performance of the contract with the User, and (ii) the User has the opportunity to exercise his/her rights and to apply for effective legal remedies in the country of transfer, provided that the User's fundamental rights and freedoms are not harmed, since data processing is mandatory for the legitimate interests of the User, The standard agreements announced by the Board, including data categories, purposes of data transfer, recipient and recipient groups, technical and administrative measures to be taken by the data recipient, are first transmitted to corporate benefits GmbH, the main partner of cb Turkey, and corporate benefits IT solutions GmbH, which is under the roof of corporate benefits group of companies, for the provision of services.

In addition, data may be transferred by corporate benefits GmbH and corporate benefits IT solutions GmbH, the main partner of cb Turkey, for data processing purposes to the best of our knowledge and in accordance with subparagraphs c, e and f of Article 5 of the KVKK, to request processors, companies that store portal data in the capacity of technical service providers, service providers that determine location, each of which is based abroad, for the purpose of processing service requests via e-mail or through "service portal forms", with standard contracts in accordance with EU legislation between the relevant parties.


V.        Rights regarding Personal Data

Pursuant to Article 11 of the LPPD, the rights of data subjects regarding their personal data are as follows:

-       Learning whether personal data is processed by cb Turkey,

-       Request information if personal data has been processed,

-       To learn the purpose of processing personal data and whether they are used for their intended purpose,

-       To know the third parties to whom personal data are transferred domestically or abroad,

-       To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,

-       Although it has been processed in accordance with the provisions of the KVKK and other relevant laws, to request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,

-       To object to the occurrence of a result to the detriment of the data subject by analyzing the processed data exclusively through automated systems,

-       In case of damage due to unlawful processing of personal data, to demand compensation for the damage.

 

These requests can be submitted to cb Turkey via the contact form.


11.2025

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