Cookie Disclosure Text

Prepared within the scope of Article 10 of the Law on the Protection of Personal Data No. 6698

1. Identity of the Data Controller

Pursuant to the Law on the Protection of Personal Data No. 6698 ("Law"), your personal data may be processed by ZENITH TANZİM SERGİLEME ÜRETİM SANAYİ VE TİCARET ANONİM ŞİRKETİ ("Company"), acting as the data controller, within the scope described below.

Address: Zafer SB Mah (Ege Serbest Bölge) Defne Sokak No:12 35410 Gaziemir İZMİR / TÜRKİYE

MERSİS No: 0997 1729 9520 0001

KEP (Registered Electronic Mail) Address: zenithtanzim@hs03.kep.tr

Website: https://www.zenith-rsm.com/

2. What is a Cookie and the Scope of this Text

Cookies are small text files placed on your computer, phone, or tablet by the websites you visit, via your browser. Our Site is operated solely for the purpose of promoting our products, providing information about our brand, and sharing our contact details, and does not offer membership, account creation, or any online transaction functionality. This Disclosure Text has been prepared to fulfil our disclosure obligation under Article 10 of the Law with respect to the personal data processed through cookies during your visit to our website. For detailed information on the types of cookies, their purposes of use, and retention periods, please refer to our Cookie Policy.

3. Categories of Personal Data Processed

  • Transaction security information: IP address, browser and device information, operating system information

  • Website usage information: pages visited, session duration, click and browsing actions (through Google Analytics statistics)

  • Approximate location information: general location data (at city/country level) derived by Google Analytics based on IP address, solely for statistical reporting purposes

Our Company does not use marketing/advertising-oriented targeting cookies or personalised advertising (e.g. Google Ads/remarketing) on its website; the data collected is processed solely on a statistical basis to measure website performance.

4. Purposes and Legal Grounds for Processing Personal Data

Personal data processed through strictly necessary/technical cookies is processed, without seeking your explicit consent, for the purposes of operating the website, ensuring its security, and fulfilling legal obligations, based on the legal grounds set out in Article 5/2(f) of the Law — "the processing of data being mandatory for the legitimate interests of the data controller, provided that this does not violate the fundamental rights and freedoms of the data subject" — and Article 5/2(ç) — legal obligation.

Personal data processed through analytics (Google Analytics) cookies, on the other hand, is processed based on your explicit consent pursuant to Article 5/1 of the Law, for the purposes of maintaining visitor statistics, measuring website performance, and improving website content accordingly. These cookies are activated only if you provide consent through our cookie preference management panel, and are not used for marketing or advertising purposes.

5. Parties to Whom Personal Data May Be Transferred and the Purpose of Transfer

Your personal data obtained through cookies may be transferred, solely for the purpose of analysing website performance, to Google LLC / Google Ireland Limited ("Google"), the provider of the Google Analytics service, and, where required, to competent public authorities and institutions, in accordance with Articles 8 and 9 of the Law.

Google Analytics data may be transferred abroad (primarily to the United States) due to Google's server infrastructure. This transfer is carried out based on your explicit consent and/or, within the scope of Article 9 of the Law, on the list of countries deemed to provide adequate protection as determined by the Personal Data Protection Board, or on appropriate safeguards undertaken by the relevant parties (such as standard contractual clauses). Our Company does not share cookie data with any third party other than Google Analytics.

6. Method of Collecting Personal Data and Legal Grounds

Your personal data is collected automatically, through electronic means, via cookies and similar technologies placed on your browser during your visit to our website. This collection is carried out based on the legal grounds set out above (explicit consent, legitimate interest, legal obligation).

7. Your Rights under Article 11 of the Law

Pursuant to Article 11 of the Law, you may apply to our Company to exercise the following rights:

  • To learn whether your personal data is being processed;

  • To request information if it has been processed;

  • To learn the purpose of processing and whether the data is used in accordance with that purpose;

  • To know the third parties, domestic or abroad, to whom your personal data has been transferred;

  • To request correction of your personal data if it is processed incompletely or incorrectly;

  • To request the deletion or destruction of your personal data within the framework of the conditions set out in Article 7 of the Law;

  • To request that the actions taken pursuant to correction, deletion, or destruction requests be notified to the third parties to whom your personal data has been transferred;

  • To object to the emergence of a result against you through the analysis of processed data exclusively by automated systems;

  • To request compensation for damages in the event you suffer harm due to the unlawful processing of your personal data.

In addition, you may withdraw your consent at any time, through the cookie preference management panel on our Site, with respect to cookies processed based on explicit consent (analytics, functional, marketing-purpose). Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

8. Method of Application

You may submit your requests regarding the rights listed above, together with documents verifying your identity, in accordance with the procedures set out in the Communiqué on the Procedures and Principles of Application to the Data Controller, through the following channels:

  • In writing, by a wet-signed petition, to: Zafer SB Mah (Ege Serbest Bölge) Defne Sokak No:12 35410 Gaziemir İZMİR / TÜRKİYE

  • By email, using a secure electronic signature or mobile signature, to: info@zenith-rsm.com

  • By Registered Electronic Mail (KEP) to: zenithtanzim@hs03.kep.tr

  • Through a notary public, by way of a formal notice sent to the address above.

Your application will be concluded free of charge, as soon as possible depending on the nature of the request and, in any event, within thirty (30) days at the latest. However, if the process requires an additional cost, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board.