Cookie Policy and Clarification Text

Last Updated: August 20, 2025

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1. Introduction and Purpose

Vebrift Bilişim Yazılım Bilgisayar Danışmanlık ve Pazarlama Anonim Şirketi (“Vebrift Inc.,” “Company,” “we”), attaches great importance to the privacy and data security of users visiting our website at https://www.vebrift.com (“Site”).

This Cookie Policy has been prepared in our capacity as data controller, in accordance with the Personal Data Protection Law No. 6698 (KVKK), the EU General Data Protection Regulation (GDPR), and relevant E-Privacy regulations, to inform you about the cookies and similar technologies used on the Site and to explain your rights to manage your preferences.

Cookie Banner Notice (to be displayed in the banner):
"We use essential cookies for the Site to function. Other cookies depend on your preferences. You can change your preferences at any time in the 'Cookie Settings' section."

2. What is a Cookie and Why Are They Used?

Cookies are small text files stored on your device (computer, phone, tablet, etc.) through your browser when you visit a website. Similar technologies include pixel tags, SDKs, local storage, and web beacons.

The main purposes of cookies are:

• Ensuring Site functionality: Session management, security, and basic navigation.

• Personalizing the experience: Remembering your preferences (e.g., language/region).

• Analyzing performance: Improving the Site through usage statistics.

• Advertising and measurement: Delivering content and ads tailored to your interests (if applicable).

By duration:

• Session cookies are deleted when you close your browser.

• Persistent cookies remain on your device for a defined period.

By source:

• First-party cookies are placed directly by the Company.

• Third-party cookies may be placed by our business partners.

3. Types of Cookies We Use and Their Legal Basis

The following categories describe the types of cookies that may be used on the Site. No non-essential cookies are activated without your explicit consent.

a) Mandatory (Technical) Cookies

• Necessary for the secure and proper functioning of the Site (e.g., login, form processing, fraud prevention, storing your essential preferences).

• Not used for marketing purposes and cannot be disabled in the preference center.

• Legal basis: KVKK Art. 5(2)(c) (establishment/performance of contract) and/or Art. 5(2)(f) (legitimate interest); GDPR Art. 6(1)(b) and/or Art. 6(1)(f).

b) Functional Cookies

• Allow your preferences such as language, region, and layout to be remembered.

• Activated only with your explicit consent.

• Legal basis: KVKK Art. 5(1) (explicit consent); GDPR Art. 6(1)(a).

c) Performance/Analytical Cookies

• Generate aggregated statistics to understand and improve Site usage (e.g., most visited pages, click-through rates).

• Activated only with your explicit consent.

• Legal basis: KVKK Art. 5(1); GDPR Art. 6(1)(a).

• Note: Data is anonymized wherever possible; where anonymization is not feasible, explicit consent is required.

d) Targeting/Advertising Cookies

• May be used to display content/ads based on your interests and to measure campaign effectiveness.

• Profiling and international data transfers may occur.

• Activated only with your explicit consent.

• Legal basis: KVKK Art. 5(1) (explicit consent) and Art. 9 (international transfers); GDPR Art. 6(1)(a) and GDPR Chapter V (Arts. 45–49).

4. Cookie Inventory (Cookie List)

The name, provider, purpose, duration, type, legal basis, and (where applicable) transfer information of the cookies used on our Site are published in the “Cookie List” table and updated through regular scans. The table below is an example; the current and binding list is available under the Cookie Settings link.

 

 

 

 

 

 

 

 

 

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Storage Note: Retention periods are defined for each cookie. Consent records and preference logs are stored for reasonable periods to meet legal obligations and for evidentiary purposes.

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5. Managing Your Cookie Preferences and Withdrawing Consent

• Cookie Settings (Preference Center): You can enable or disable non-essential cookie categories from the banner displayed when you first visit our Site, or at any time via the “Cookie Settings” link at the bottom of the page. You may withdraw your consent at any time.

• Browser Settings: You may also delete or block cookies through your browser settings. Please note that blocking all cookies may cause certain parts of the Site to malfunction.

• Global Privacy Control (GPC) / “Do Not Track”: Such signals are taken into account to the extent technically possible; however, the binding choice is the one you make via the Preference Center.

6. Categories of Personal Data Processed and Recipient Groups

Data categories: Cookie ID, session ID, IP address, device/browser information, referring URL, pages viewed, clicks, timestamps, approximate location (country/city), and preference settings.

Recipient groups: Hosting and infrastructure providers, customer support and security service providers, analytics/measurement providers, advertising networks (only with consent), and legal/consulting services. These parties are contractually bound as data processors where applicable.

7. Transfer of Personal Data Abroad

Where the servers of third-party service providers are located abroad, personal data may be transferred internationally:

• Under KVKK Article 9, such transfers may be based on an adequacy decision, standard contracts/undertakings with Board approval, or explicit consent.

• Under the GDPR, transfers are carried out within the framework of Article 45 (adequacy decision), Article 46 (appropriate safeguards/SCCs), or, where applicable, Article 49 (exceptions).

8. Storage Periods and Security

• Retention periods for cookies are specified in the Cookie List. Session cookies are deleted at the end of the session; persistent cookies are automatically deleted after their defined period.

• Consent records and preference logs are retained for reasonable periods in line with legal obligations and audit requirements.

• Personal data is safeguarded through measures such as access controls, encryption, pseudonymization, and data minimization.

9. Your Rights (KVKK and GDPR)

Your rights under Article 11 of the KVKK include:

• Access, request for information, rectification, erasure/destruction, restriction of or objection to processing, notification to third parties to whom the data has been transferred, and compensation for damages.

Your rights under the GDPR include:

• Access (Art. 15), rectification (Art. 16), erasure/the “right to be forgotten” (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), objection (Art. 21 — including objection to direct marketing at any time), withdrawal of consent (Art. 7(3)), and the right to lodge a complaint with a supervisory authority (Art. 77).

10. Children’s Privacy

If you are under the minimum age prescribed by the laws of your country of residence, consent for non-essential cookies must be provided by your parent or legal guardian.

11. Policy Changes

This Policy may be updated from time to time. Updates take effect immediately upon publication on the Site, and the “Last Updated” date at the top of the page will be revised. Reasonable notice shall be provided in the event of material changes.

12. Communication and Application Methods

For questions or complaints regarding this Policy or our data protection practices, please contact:

• Vebrift Inc.

• Address: Beşiktaş, 34353 Istanbul / Türkiye

• E-mail: vebrift@gmail.com

Application Procedure: Under the KVKK, applications may be submitted in writing, by e-mail, or via the application form available on our system, in accordance with the Communiqué on the Procedures and Principles for Application to the Data Controller.

Under the GDPR, you retain the right to lodge a complaint with the competent supervisory authority in your country of residence. In Türkiye, the relevant authority is the Personal Data Protection Authority (KVKK).

13. Preference Center Texts (Recommended Short Copies)

• Mandatory: “Required for the Site to function and cannot be disabled.”

• Functional: “For preferences that personalize your experience; enabled by explicit consent.”

• Performance/Analytics: “Visit statistics and optimization; will not be activated without your consent.”

• Targeting/Advertising: “Personalized advertising and measurement; enabled with your consent.”

Note: You can use the “Cookie Settings” link at the bottom of the page to view and manage your current Cookie List and preferences.