data protectıon

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PERSONAL DATA PROTECTION AND PROCESSING GENERAL LIGHTNING NOTICE

We are extremely sensitive to the security of your personal data. Data Protection Regulation (GDPR) & Personal Data Protection Act; We inform you of all personal data processed by Orange including our employees, our suppliers, our partners, our business partners, our business partners, our students, third parties as part of our policy responsibilities under this policy.a) Data Officer In accordance with Data Protection Regulation (GDPR) on Protection of Personal Data, your personal data; Orange(Company) by the title of the company can be processed as described below.b) Collection, Processing and Processing Purposes of Personal DataYour personal data may vary depending on the services and business activities provided by our group companies; either automatically or non-automated, by means of our companies' units and offices, group companies, websites, social media circles, mobile applications and the like. Your personal data may be processed as long as you benefit from the products and services provided by our group companies.In addition, your personal data may be processed when you use our call centers or internet site to use our group companies services, when you visit our companies or our web page, or when you participate in training, seminars or organizations organized by our companies.Your collected personal data will be processed by our business units to benefit you from the products and services offered by our group companies and the products and services offered by our group companies will be customized to your liking, usage habits and needs and recommended to you. the legal and commercial security of individuals (administrative operations directed by our companies, ensuring the physical security and control of the locations of our companies, group companies customer evaluation / complaint management processes, reputation research processes, efficiency management, legal compliance process, ), For the purpose of establishing and implementing the commercial and business strategies of our companies and the execution of our companies' human resources policies shall be processed in accordance with the personal data processing requirements and purposes set forth in Articles 5  of the GDPR Law.c) Transferring Processed Personal DataYour collected personal data; Group Companies are required to work with you to make use of the products and services offered by our companies and our business units will make the necessary efforts to provide you with the products and services offered by our group companies to be customized according to your taste, usage habits and needs. (administrative operations directed by our companies, ensuring the physical security and control of the locations of the companies, evaluation processes of partner / client / supplier (authority or employees), reputation research processes, legal compliance process, audit, financial affairs etc.) the determination and implementation of the commercial and business strategies of our companies and the implementation of the human resources policies of our company, may be transferred to group companies, company authorities, shareholders, legally authorized public authorities and private persons within the framework of the personal data processing requirements and purposes set out in Articles 8 and 9 of the Corporate Tax Law.d) Method of collecting personal data and legal reasonYour personal data may be shared by our companies in different channels or in publicon the basis of databases and on different legal grounds; with the product we offerprovide services, develop and conduct our business activities.Your personal data collected during this process; through our employees and representatives,it is convened for legal reasons to carry out our activities. In addition, your personal data is collected to ensure complete security in your company's workplaces / work areas. Your personal data collected pursuant to this law will be subject to the personal data processing conditions specified in Articles 5 of Law (b) and (c) of this Lighting Statement within the scope of RI and its purposes.e) The Rights of the Personal Data Holder in Article 11 of GDPR: As personal data owners, your requests for your rights are requested by Berra. We will conclude your request as soon as possible and within thirty days at the latest, free of charge, according to the nature of the claim. However, if the transaction also requires a cost, the fee will be charged by our company as specified in the Personal Data Protection Board. In this context, personal data owners; - Knowing whether personal data has been processed or not, - Requesting information about personal data if it has been processed, - Knowing the purpose of processing personal data and whether they are used appropriately for their purposes, - Knowing third parties to whom personal data are transferred in the country or abroad, - requesting that these actions be corrected to third parties to whom personal data are transferred and - requesting that such processing be done in accordance with the provisions of GDPR and other relevant laws, and requesting that personal data be deleted or destroyed in the event that the reasons for its processing are not fulfilled, - requesting that the process be notified to the third party to which the personal data is transmitted, - requesting that the processed data be analyzed exclusively through automated systems, - You have the right to request the removal of the damage in the event of a corruption due to the processing of the personal data in contravention of the law due to the processing of the personal data in violation of the law. - Your request for proof of identity of your requests for personal data within the scope of Law No. 6698 and the applicants' You may forward your request applications for your rights listed above to the Berra Investment Consulting Incorporation at the address of nl-orange.com by using the Data Entry Application Form, available at nl-orange.com  Our company will conclude your request free of charge within thirty (30) days as soon as possible, according to the nature of the claim. However, if the transaction also requires a cost, you will be charged at the rate specified by the Personal Data Protection Board.Our Respects

RESPONSIBILITY

 It is the responsibility of all individuals and governments to support economic, environmental, cultural and social development for a sustainable world together with their employees and their families in order to improve the quality of life of their society. 

• Ensuring the sharing of common universal values by societies for the continuity of life and improvement of social life.
• It is to contribute to the education of society individuals who have good living conditions who can look to the future with hope.
• Responsibilities of individuals to the world they share to the society they live in,
• Taking personal efforts into consideration and performing them in group work,
• In this way, it enables them to develop and realize themselves.
  

REPORT MISCONDUCT

Legal note:

The data entered into this form is transmitted encrypted to Orange via the internet. Nevertheless, in order to maintain discretion, please do not include any confidential data such as account numbers. Via this form Orange does not accept any instructions for business transactions such as the, payment orders, trading orders, revocations of orders or authorizations, changes of address, etc. Please contact the appropriate office or your client advisor for such transactions.

By providing your telephone number and/or e-mail address above you expressly approve Orange contacting you via telephone and/or via unsecured e-mail.

* Please send us an e-mail with your attachment of you inquiry. 

Please note: 

The use of e-mail can involve substantial risks such as lack of confidentiality, potential manipulation of contents or sender's address, wrong recipient, viruses etc. Orange assumes no responsibility for any loss or damage resulting from the use of e-mails. Orange recommends in particular that you do not send any sensitive information, that you do not include details of the previous message in any reply, and that you enter e-mail addresses manually every time you write an e-mail.

Terms of use

Disclaimer

These Terms of Use apply to nl-orange.com as well as any other affiliated sites, digital services, or applications on which a link to these Terms of Use appears (collectively, the "Berra Website") and apply to all visitors. These Terms of Use and any other terms that appear on the page from which you were directed to these Terms of Use govern your use of the Berra Website. By accessing the Orange Website, you agree to be legally bound by the Terms of Use then in effect. Please also refer to the relevant additional legal information applicable to your country.

These Terms of Use as well as the information and materials contained in the Orange Website are subject to change at any time and from time to time, without notice. Berra may add features to or remove features from the Orange Website at any time and from time to time in our sole discretion. Continued access to the Berra Website following any modification in these Terms of Use will constitute your acceptance of the Terms of Use as modified.

If you do not agree to be bound by these Terms of Use, do not use the Berra Website.

Access Subject to Local Restrictions

The Berra Website and all information and functionalities contained within them are not directed at or intended for use by any person resident or located in any jurisdiction where (1) the distribution of such information or functionality is contrary to the laws of such jurisdiction; or (2) such distribution is prohibited without obtaining the necessary licenses or authorizations by the relevant branch, subsidiary or affiliate office of  Berra and such licenses or authorizations have not been obtained.

Services and Products

Products and services displayed on the Orange Website may not be eligible for sale or available to residents of certain countries or certain categories of investors. Please consult the applicable terms and conditions such as sales restrictions or key specific notes for further information.

Any materials, information or reports published, distributed or otherwise made available on the Berra Website is published for information purposes and is subject to change at any time without notice. They have no regard to the specific investment objectives, financial situation or particular needs of any specific recipient and should not be construed as a solicitation, offer or recommendation, to buy or sell any securities, investment or other financial instruments, to effect any transactions or to conclude any legal act of any kind whatsoever. Unless specifically stated otherwise, all price information is indicative only. No representation or warranty, either express or implied, is provided in relation to the accuracy, completeness or reliability of the materials, nor are they a complete statement of the securities, markets or developments referred to herein. The materials should not be regarded by recipients as a substitute for the exercise of their own judgment. Any opinions are subject to change without notice and may differ or be contrary to opinions expressed by other business areas or groups of Berra as a result of using different assumptions and criteria. Berra is not under any obligation to update or keep current the information contained herein nor to remove any outdated information from the Orange Website or to expressly mark it as being outdated.

No Offer

All information and materials published, distributed or otherwise made available on the Orange Website are provided for informational purposes, for your non-commercial, personal use only. No information or materials published on the Berra Website constitutes a solicitation, an offer, or a recommendation to buy or sell any investment instruments, to effect any transactions, or to conclude any legal act of any kind whatsoever.

Berra does not provide investment, legal or tax advice through the Orange Website and nothing herein should be construed as being financial, legal, tax or other advice. Berra does not represent that any securities or services discussed are suitable for any investor. No investment or other decisions should be made solely based on the contents or information found on the Orange Website.

When making a decision about your investments, you should seek the advice of a professional financial advisor or qualified expert.

Performance

The future performance of an investment cannot be deduced from previous market value, i.e. the value of an investment may fall as well as rise. An investment may also lose value due to changes in rates of foreign exchange. Orange cannot guarantee that any capital invested will maintain or increase in values.

Forward Looking Statements

The Berra Website may contain statements that constitute "forward looking statements". While these forward looking statements may represent Berra’s judgment and future expectations, a number of risks, uncertainties and other important factors could cause actual developments and results to differ materially from Berra’s expectations. Berra is under no obligation to (and expressly disclaims any such obligation to) update or alter its forward looking statements whether as a result of new information, future events, or otherwise.

No Warranty

Your use of the Berra Website is at your own risk. The Orange Website, together with all content, information and materials contained therein, is provided "as is" and "as available" ", without any representations or warranties of any kind. Any materials, information or content accessed, downloaded or otherwise obtained through the use of the Berra Website is done at your own risk and Berra is not responsible for any damage to your computer systems or loss of data that results from the download of such material. Berra and its affiliates expressly disclaimer all representations or warranties of any kind, whether express or implied, with respect to the Berra Website, and all materials, information, content and functionalities contained herein, including but not limited to warranties of title, non-infringement, merchantability or fitness for a particular purpose. Without limiting the foregoing, Orange does not warrant the accuracy, timeliness, completeness, security, reliability or availability of the Berra Website or the information or results obtained from use of the Berra Website, or that the Berra Website will be available at all times, or is virus-free or error-free.

No Liability

To the fullest extent permitted by law, in no event shall Orange or our affiliates, or any of our directors, employees, contractors, service providers or agents have any liability whatsoever to any person for any direct or indirect loss, liability, cost, claim, expense or damage of any kind, whether in contract or in tort, including negligence, or otherwise, arising out of or related to the use of all or part of the Berra Website, or any links to third party websites.

You are solely responsible for acquiring and maintaining such electronic devices and equipment that can handle and will allow you to access and use the Berra Website and for taking adequate and appropriate data security measures in accordance with good industry practice to protect yourself against fraud or cyber-attacks on a continuous basis (e.g. by using the most recent browser versions, and installing recommended security patches and up-to-date anti-virus programs and firewalls). Berra specifically disclaims all liability for any tampering with any user's computer system by unauthorized parties, or for losses or liabilities suffered by any user arising from viruses or attacks by hackers.

In no event will Berra or our affiliates, or any of our officers, directors, employees, contractors, service providers or agents be liable for any incidental, special, punitive or consequential damages howsoever caused arising out of the use of the Berra Website, its content, or the inability to use the Berra Website.

This disclaimer of liability applies to any and all damages or injury, including those caused by any failure of performance, error, omission, interruption, deletion, defect, delay in operation or transmission, computer virus, communication line failure, theft, destruction, or unauthorized access, whether for breach of contract, tortious behavior, negligence or under any other cause of action.

Links

The Orange Website may contain third party content or links to third party websites. These content and links are provided solely for your convenience and information. Berra has no control over, does not assume any responsibility for and does not make any warranties or representations as to, any third party content or websites, including but not limited to, the accuracy, subject matter, quality or timeliness. Berra shall have no liability for third party content or websites or websites linking to or framing the Berra Website.

Social Bookmarks

The Orange Website may contain social bookmarks which are identifiable by means of their respective buttons. Social bookmarks allow users of certain social media platforms to post links to selected Orange web pages on their social media accounts in order to bookmark them or share them with their social media contacts. If you use social bookmarks, you will be sending personal identifying data to the respective social media platform. Any comments or activity made by or carried out by persons using social bookmarks is not controlled, endorsed or monitored by Orange shall not be responsible or liable for such. Persons who share Orange communications via social bookmarks are not authorized to speak for or represent Orange and their views and opinions must be regarded as strictly their own and not Orange's. In addition, the provisions in these Terms of Use relating to Links also apply to social bookmarks.

Intellectual Property Rights

Orange, or the applicable third party owner, retains all right, title and interest (including copyrights, trademarks, patents, as well as any other intellectual property or other right) in all information and content (including all text, data, graphics and logos) on the Berra Website. Individual pages and/or sections of the Berra Website may be printed for personal or internal use only, and provided that such print outs retain all applicable copyright or other proprietary notices. All users must not, without limitation, modify, copy, transmit, distribute, display, perform, reproduce, publish, license, frame, create derivative works from, transfer or otherwise use in any other way, whether in whole or in part, any information, text, graphics, images, video clips, directories, databases, listings or software obtained from the Berra Website for commercial or public purposes, without the prior written permission of Berra. Systematic retrieval of content from the Berra Website to create or compile, directly or indirectly, a collection, compilation, database or directory (whether through robots, spiders, automatic devices or manual processes) or creating links to the Berra Website without the prior written permission from Orange is strictly prohibited.

The key symbol and Orange are among the registered and unregistered trademarks of Orange. Other marks may be trademarks of their respective owners. Except as noted above, you may not use any trademarks of Berra for any purpose without the prior written permission of Berra.

Electronic Communication (E-Mail)

The Internet is an universally accessible medium. Ordinary e-mail messages sent over the Internet are neither confidential nor secure. They may be easily accessible by third parties and may entail a considerable amount of danger and risk including: (a) lack of confidentiality (e-mails and their attachments can be read and/or monitored without detection); (b) manipulation or falsification of the sender's address or of the e-mail's (or attachment's) content (e.g. changing the sender's address(es) or details); (c) system outages and other transmission errors, which can cause e-mails and. their attachments to be delayed, mutilated, misrouted and deleted; (d) viruses, worms, Trojan horses etc. may be spread undetected by third parties and may cause considerable damage; and (e) interception by third parties.

You are therefore recommended to communicate with Orange by using a secure channel if such channel is provided by Orange. In no event should you use ordinary E-mail to transmit personal or confidential information such as any account related data.

Unless explicitly stated otherwise, Orange does not accept any orders or instructions sent by E-mail or any other electronic messaging system.

Orange shall not be liable to you or anybody else for any damages incurred in connection with any messages sent to Berra using ordinary E-mail or any other electronic messaging system.

Please see our email addresses for more information about our e-mail practices and policy.

Privacy Statement

Orange has established a Privacy Statement, as modified from time to time, which explains how personal data is collected on the Berra Website and used. The Privacy Statement is part of these Terms of Use and is incorporated herein by reference.

Severability Clause

To the extent that any provision of these Terms of Use is found by any competent court or authority to be invalid, unlawful or unenforceable in any jurisdiction, that provision shall be deemed to be severed from these Terms of Use but such finding shall not affect the validity, lawfulness or enforceability of the remainder of these Terms of Use in that jurisdiction, nor shall it affect the validity, lawfulness or enforceability of these Terms of Use in any other jurisdiction.

Conflict with Additional Terms

Certain web pages or areas on the Orange Website may contain additional terms, conditions, disclosures and disclaimers (collectively, the “Additional Terms”). In the event of a conflict between these Terms of Use and the Additional Terms, the Additional Terms will govern for those web pages or areas.

Last updated in May 2017.