We want you to know that protecting your personal information is of great importance to Socreathink Media Planning and Strategic Digital Marketing Inc. (“Socreathink”), and we respect the privacy of these data. We have prepared this Privacy Policy to explain how we use and protect the personal information you share with us. This Policy is applicable to www.socreathink.com (“Site”) and all users who use our services, as well as all information provided to us by users who purchase our services. By purchasing our services, you are expressly stating that you have read, reviewed, and accepted the provisions of the Privacy Statement. By using our website and services and/or purchasing services, you agree to comply with the practices and rules set forth in this Privacy Policy.

Socreathink complies with the legal regulations regarding privacy in Turkey. Socreathink does not commit to the application of this website to the laws of other countries, or its compliance with them, or its readiness for use in any authorized jurisdiction or any part of this website. Those who choose to use our website do so at their own discretion and are responsible for complying with all local laws, rules, and regulations. Visitors from outside of Turkey who use this website acknowledge that this site is subject to the laws and regulations of the Republic of Turkey and waive all claims arising under their national laws.

Socreathink reserves the right to change, modify, add, or remove the provisions of this Privacy Policy within the scope of legislation. Changes made to this Privacy Policy will also be published on this website. We recommend that you check our website from time to time to stay informed about the most current version of our privacy policy. You can determine whether the Privacy Policy has been revised since your last visit to our site by looking at the “Last Updated” date on this page. Please read this Privacy Policy carefully. Your use of our site and/or purchase of our services constitutes your acceptance of this Privacy Policy without any limitation, compliance, or change. If at any time you do not accept all the terms and conditions here, you must immediately cease using this site.

1-What Information Do We Collect

We collect two types of information through our website: “Personal Information” (or “PII”) and “Non-Personal Information” (or “Non-PII”). Personal Information is information that identifies you as an individual or can identify you (such as your address, phone number, or billing information), and Non-Personal Information is aggregate information, demographic information, IP addresses, and other information that does not directly identify you.

2-Non-Personal Information: When you visit our site or interact with our site, Socreathink and third parties with whom Socreathink contracts to provide services to Socreathink may collect your Non-Personal Information (e.g., a catalog of the pages on the site you visited) for the purpose of providing Socreathink and Socreathink’s services. Non-Personal Information is anonymous and does not personally identify you. Non-Personal Information is generally collected from four different sources through our website: Internet Protocol addresses and web logs; cookies, pixel tags, and other similar technologies; and other Non-Personal Information you provide voluntarily as described below.

3-IP Protocol Addresses and Web Logs: We collect and store your IP address to diagnose problems with our servers, manage our website, ensure your connection to the data service that provides your connection to our site as quickly as possible, and provide you with a personalized experience based on your language preference and the region you accessed the site. Our site’s web servers automatically collect IP addresses and log files from visitors. Your IP address is an identification number automatically assigned to your computer by your Internet Service Provider (ISP). The number is automatically identified and stored in our server log files along with the time(s) of your visit(s) and the page(s) you visited when you visit our site. This information is generally collected and does not contain any Personal Information.

In addition to the Non-Personal use of IP addresses described above, we may link your IP address to your Personal Information to prevent fraud and similar crimes.

4-Cookies: We and third-party service providers may use a standard technology called “cookies” to collect information about how you use our site. Cookies remain on your computer and help your computer’s browser recognize your computer as a known visitor to our site. For example, when you log into your Socreathink account, cookies will be used to store your email address and name in order to remember them for your next visit from the same computer. This way, we will “remember” your name and email address to speed up and simplify your transaction when you return to our site from the same computer. From time to time, a “session cookie” that helps us manage our site may also be set. The session cookie expires when you close your browser and does not store any information about you after it expires. If you do not want information to be collected through cookies, you should change your browser preferences to offer you choices about cookies. If you choose to reject cookies, you may not be able to use certain services on our site that require you to log in (e.g., services that require you to log in to the site). If personal data is collected through cookies, it will be requested with the method and content specified below in accordance with the Law on Protection of Personal Data.

5- Pixel Etiketler: We and our service providers may use tools such as “pixel tags,” “web beacons,” “clear GIFs” (collectively, “Pixel Etiketler”) or similar tools in connection with pages of our site that relate to the use of our website to track your use of the site and to provide you with more useful information and a more personalized experience during your subsequent visits. A Pixel Tag is typically a one-pixel (1×1) electronic image that is often a single pixel in size and cannot be seen by visitors to our site, which can be associated with cookies on your hard drive. Pixel Etiketler do not contain Personal Information and allow us to count users who visit certain pages of our site to deliver branded services and help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Etiketler can tell the sender whether or not the email has been opened.

6- Personal Information: Socreathink Media Planning and Strategic Digital Marketing Inc. (“Socreathink”) respects the privacy of Users/visitors/customers who visit its website and use its applications and attaches great importance to the protection of their privacy and the security of their personal data (hereinafter referred to as “Site” for all applications and the website www.socreathink.com in short).

Socreathink is responsible for storing and securing the personal data obtained about you. In addition, we state that your personal data will not be disclosed to third parties without your consent and cannot be used for purposes other than those notified to you.

Rights of Users Regarding Their Personal Data

In accordance with Article 11 of the Law on the Protection of Personal Data (“KVKK”), Users and Members; They have the right to request information about their personal data, including:

learning whether it has been processed or not, requesting information if it has been processed, learning the purpose of processing and whether it is used appropriately for its purpose, knowing the third parties to whom it has been transferred domestically or abroad, requesting correction if it is incomplete or incorrect, requesting its deletion / destruction within the framework of the conditions stipulated in Article 7 of the KVKK, requesting notification of the transactions made pursuant to paragraphs (d) and (e) to third parties to whom personal data has been transferred, objecting to the occurrence of a result against him by analyzing the processed data exclusively through automated systems, requesting the compensation of damages in case of damage due to the unlawful processing of personal data.

Socreathink will announce the Data Controller Representative to be appointed by Socreathink, in accordance with the legal infrastructure, in accordance with the law, on the website with the www.socreathink.com extension. You can always contact us at contact@socreathink.com to exercise your rights under Article 11 of the KVKK regarding your personal data or for any questions related to your personal data.

7- How We Use the Information We Collect:

We understand the importance of protecting the information you share with us. We take appropriate security measures under the legislation to protect this information from unauthorized access and disclosure. For example, we may access, obtain, use, process, and/or transfer personal information in accordance with legal provisions. Additionally, we encrypt credit card numbers and other sensitive information before they are sent from your computer to ours. We also use preventive systems on our servers to prevent unauthorized access to your personal information.

While you can feel safe when using our website, no system is completely secure. Despite taking all the necessary steps to protect your information, there is always a possibility of breach. Therefore, you should be very cautious when transporting and disclosing your personal information. For example, avoid sending personal information via email.

As a general rule, the processing of personal data without the explicit consent of the data subject may not be possible. However, personal data processing may be possible without the explicit consent of the data subject in cases where it is necessary for the establishment or performance of a contract, directly related to the parties to the contract, required for the establishment, use, or protection of a right, publicly disclosed by the data subject, for the legitimate interests of the data controller provided that it does not harm the fundamental rights and freedoms of the data subject, and explicitly prescribed by the law.

8- Non-Personal Information:

Since Non-Personal Information cannot identify you personally, we may use this information for any purpose. For example, we may use it to measure visit times, average time spent on our site, and pages viewed to diagnose problems with our servers and to manage, analyze, and improve the features and functionality of our site. Additionally, we reserve the right to share this non-personal information with third parties for any purpose, whether for advertising purposes or in any other way that does not disclose your personal information.

9- Explicit Consent for Personal and/or Special Qualification Personal Data:

Socreathink customers who purchase services from our website, users of our website, and other individuals who share personal data through our website or member panel, by clicking on the “check” on top of the “Consent Text Within the Scope of the Personal Data Protection Law” published on our website or member panel, permit the collection, processing, and transfer of their personal and/or special qualification personal data to the extent envisaged by the legal regulation.

In case the necessary permissions for personal data are not granted, it should be noted that some features on the Site may not be used, the service may not be partially or completely offered, in other words, the purchase of services may not be possible. Because, except for exceptional cases, it should not be ignored that obtaining, processing, and transfer of personal data are necessary for purchasing services. Socreathink does not accept any responsibility and has no liability for the fact that the services cannot be sold due to the non-granting of the necessary permissions for obtaining, processing, and transfer of personal data.

How can your Personal Data be processed?

As Socreathink, as a data controller, we can collect, record, store, keep, change, update, periodically check, reorganize, classify, process, and/or maintain your personal and/or special qualification personal data, obtained with your consent, through all kinds of channels, including but not limited to our company and company’s per retail sales channels, call centers, affiliated companies, or through internet sites and social media pages or other channels not limited to these channels; and it may be disclosed/transferred to legal or real persons who are the service providers that our company cooperates with, or who are legally obligated public institutions and organizations, and/or third parties, whether they are located domestically or abroad, for the purpose of fulfilling our company’s obligations, performing services, and/or ensuring the necessary activities for the management and operation of these services. In this regard, it is emphasized that every kind of transaction on data can be performed by us, including but not limited to obtaining, recording, storing, keeping, changing, updating, disclosing, transferring, taking over, making it available, classifying, or preventing its use, in whole or in part, automatically or non-automatically, in any data recording system as a part of any data registration system, as long as the necessary legal or service-related requirements are met and this is not contrary to the law.

How are your personal data collected?

Your personal and/or sensitive personal data can be collected through various channels, including but not limited to our website, our sales and marketing department employees, forms collected during customer visits, digital marketing, and call center/internet website/social media/business partners. These data may be collected orally, in writing, or electronically, with your consent. Additionally, personal data may be collected through channels such as the internet branch, social media, and call center, either verbally, in writing, or electronically.

What is the Status of Data Processed Before the Law’s Publication?

In accordance with the provisions of the law, “Personal data processed before the publication date of this Law will be brought into compliance with the provisions of this Law within two years from the publication date. However, consents lawfully obtained before the publication date of the Law shall be deemed compliant with this Law unless otherwise stated within one year.” We would like to point out that Socreathink customers, by purchasing services from Socreathink, are deemed to have accepted the Terms of Use and Privacy Policy. Therefore, with regard to personal and/or sensitive personal data obtained before the publication date of the Law, there is “your consent in accordance with the law” provided to us. In accordance with the law, these consents will be deemed compliant with this Law unless otherwise stated within one year.

What are the Purposes and Legal Grounds for Processing Your Personal Data?

First and foremost, we will collect and process your personal and/or sensitive personal data in accordance with the Law on the Protection of Personal Data No. 6698 and relevant legislation to sell, market, and distribute the services requested by our customers, and to provide the services to our customers in compliance with the contract and technological requirements.

Additionally, we will record identity, address, and other necessary information to sell services and provide the services requested by our customers, prepare all records and documents that will be the basis for processing in electronic or paper form, comply with information storage, reporting, informing, and other obligations required by legislation and competent authorities, provide the requested products/services, and fulfill the requirements of the service and contract. The reasons mentioned here constitute the purposes and reasons for processing your personal data.

As a rule, processing personal data without the explicit consent of the data subject is not possible. However, in cases where any of the following situations exist: “necessity for processing personal data belonging to the parties of a contract directly related to the establishment or performance of a contract,” “necessity for processing personal data for the establishment, exercise, or protection of a right,” “necessity for the data controller to fulfill its legal obligation,” “the personal data being made public by the data subject,” “processing personal data 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,” and/or “explicitly prescribed by the laws,” personal data may be processed without seeking the explicit consent of the data subject.

The details of the purposes for using and processing your personal data are summarized below:

  • Website: We may use the Personal Information you provide, with your consent, to create a better website based on your interests, show you content that you may be interested in, and display content according to your preferences.

  • Communication: With your consent, we may use your Personal Information to inform you about Socreathink and its services, as well as promotions on behalf of some of our partners.

  • Administrative Matters: Socreathink reserves the right to contact you in case of any changes in the Site Terms of Use and/or this Privacy Policy, or to inform you about other administrative matters related to our website (e.g., facilitating, completing, or confirming a transaction).

  • Fulfilling Requests and Facilitating Transactions: With your consent, Socreathink may use your Personal Information to fulfill your requests and facilitate transactions. However, in cases where any of the following situations exist: “necessity for processing personal data belonging to the parties of a contract directly related to the establishment or performance of a contract,” “necessity for processing personal data for the establishment, exercise, or protection of a right,” “necessity for the data controller to fulfill its legal obligation,” “the personal data being made public by the data subject,” “processing personal data 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,” and/or “explicitly prescribed by the laws,” personal data may be processed without seeking the explicit consent of the data subject.

  • Special Business Purposes: With your consent, Personal Information may be used for purposes such as ad targeting, data analysis, audits, fraud prevention, and other internal business purposes.

  • Shopping/Commercial Services: When you make a purchase through the Site, we may collect your credit card number, billing address, and other information related to your purchase (collectively, “Payment Information”) with your consent. We will use your Payment Information, with your consent, to bill you for your purchase and process your purchase. By providing your Payment Information, you authorize us to provide this information to third parties as necessary to confirm and fulfill your order (for example, to process your credit card number).

  • Share on Social Media: Our website allows you to share certain activities or site features with other individuals you believe may be interested in them via email or Social Media Services, with your consent.

  • Newsletter Subscription: With your consent, our website may send you text and links via email services, announcing certain activities, promotions, or features of our services.

  • Job Listings

    When you apply for a position at Socreathink and submit your personal information through our website, these details will be used solely to evaluate your application and process the related procedures. With your consent, we may retain your personal information for a certain period to assess your application for current or future positions.

    Information about persons or organizations to whom we may transfer your personal data

    For the purposes mentioned above, the individuals or organizations to whom we may transfer your personal and/or special-category personal data, with your consent, include our direct/indirect domestic/foreign subsidiaries, individuals and organizations with whom we cooperate to carry out our operations, program-service partner individuals and organizations, banks, domestic/foreign organizations, and other relevant third parties. It should be noted that as our company collaborates with business partners, necessary personal and/or special-category personal information may be shared with these partners, banks, and other relevant third parties within the scope of the requirements, and may be transferred to domestic and/or foreign entities.

    Affiliate Communications: Commercial electronic messages under the scope of the contract may be sent to you with your prior consent. Since obtaining consent can be done in writing or through various electronic communication means, if you do not want to receive commercial electronic messages under the contract, please remember to uncheck the consent option in the “sending electronic messages” section. In addition, you have the right to refuse to receive commercial electronic messages related to changes in the services requested and/or the terms of use, as well as communication for the purpose of contacting you. However, if you provide contact information to be contacted, it is legally possible to communicate without obtaining additional consent for commercial electronic messages related to changes in the services requested and/or the terms of the contract, provided that it does not harm the fundamental rights and freedoms of the data subject, in accordance with the law and for the legitimate interests of the data controller, and/or is explicitly provided for in the laws.

    Furthermore, during the provision of the service, it is legally possible to send communications for marketing, promotion, and/or amendment services for the same or similar services without obtaining new consent if your consent is obtained for this type of communication. However, you have the right to refuse such communication and withdraw your consent, and it is sufficient to inform us in any way. If you choose to participate in the opt-in email system, our affiliates may also send you announcements and notifications about events, products, or services that may interest you at any time.

    Job Listings Service Providers: We work with third parties as service providers, including but not limited to data analysis, service delivery, credit card transactions, and administrative tasks. If you use our services, with your consent, we reserve the right to share your Personal Information with these third parties to the extent required for them to provide the relevant services. We take all reasonable steps to ensure that these third parties also take the same care in preserving your personal information as we do, and these third parties will also be fully responsible for your personal information within the scope of the legislation.

    Other Purposes:

    • In the event of a court order or similar request for investigation, a request for cooperation from an authorized government agency, determining or enforcing our legal rights, defending against legal claims, or in other legally required cases, we may share or use Personal Information. We may use or waive any rights or objections.

    • Collection of Information by Third Parties

    Third-Party Advertisements: Advertisements appearing on our website are provided by third-party advertising partners. Third-party advertisers on our site may place or recognize unique cookies on your browser. Non-Personal Information about your site visits, such as the number of times you view an ad, can be used to provide advertising services to you.

    Third-Party Links: Our website may contain links to websites owned or operated by third parties that are not owned or operated by Socreathink. We provide these links for convenience only. The inclusion of a link on our website does not imply that Socreathink endorses or has reviewed the third-party website for security or approval.

    If you provide Personal Information to any such third-party website, your transaction will be conducted by that third-party website (rather than Socreathink.com) and any Personal Information you provide will be collected and controlled by that third party’s privacy policy, not Socreathink’s. Socreathink is not responsible for the privacy practices or content of third-party websites. You also have the right to unsubscribe from receiving commercial electronic communications at any time.

    Even if you have opted out of receiving newsletters, Socreathink may still send you emails related to service purchases from Socreathink. These may include customer service-related emails containing information about the status of the service, service delivery, and updates related to the service and contract.

    Children’s Use of the Site:

    The Site is not intended for individuals under the age of thirteen (13), and we do not want these individuals to provide their Personal Information through our site. If a parent or guardian becomes aware that their child has provided us with Personal Information without their permission (for example, by falsely stating their age), the parent or guardian should contact us at contact@socreathink.com. If Socreathink determines that it has collected Personal Information from a child under the age of 13, Socreathink will immediately delete the information and the account(s) believed to be owned by those under the age of 13.

    Access, Update, or Deletion of Information Collected About You

    Our website also offers you the opportunity to delete or modify your Personal Information within the framework of the Personal Data Protection Law. You can do this by logging into the panel provided to you and following the instructions to change your user information, or by using our contact channels. We will respond to your change requests as soon as possible within the legal framework. In relation to your other rights under the Personal Data Protection Law, you can review the “Rights of Data Subjects Regarding Their Personal Data” section of this text again.

    Security of Your Personal Information

    Socreathink uses security measures, including physical, electronic, and operational safeguards, within the framework of legal provisions, to protect the security of Personal Information collected through the Site and to prevent unauthorized access.

    While Socreathink takes all necessary steps to protect Personal Information under its control, it cannot guarantee that all data communication or data storage methods over the internet are 100% secure. We are not responsible for any damage that may occur as a result of the interception, alteration, or misuse of information during these transfers. In case you believe that there has been a breach of the site’s security, please contact us at contact@socreathink.com.

    Online and Offline Applications

    Please note that this Privacy Policy applies only to online information collection and dissemination practices related to our website and does not apply to any offline practices.

    Contacting Socreathink Regarding the Site

    If you have any questions or different requests about this Policy, you can email these questions and/or requests to contact@socreathink.com. Please note that email communications may not necessarily be secure. Therefore, do not use your email correspondence with us to provide credit card information or other sensitive information.