Privacy Policy

Privacy Policy

The principles followed by Elba Bant A.Ş. (“ELBA”) while collecting and using personal data obtained from users (“User(s)”) within their consent through the website ( “Website”) are regulated under this Privacy Policy.

Personal data that may be collected

ELBA may collect the User’s identity information, contact information such as e-mail address and telephone number, and other information that may be necessary for the provision of services and possible commercial relationship in relation to the Website and that are considered personal data under the Personal Data Protection Act and any other applicable legislation. The User expressly consents to the processing of such data within the scope and for the purposes indicated in this Privacy Policy.

Pursuant to Articles 3 and 7 of the Personal Data Protection Act, data that is irrevocably anonymised shall not be considered personal data under the said provisions, and the processing of such data shall be carried out without prejudice to the provisions of this Privacy Policy.

Purpose of data use

ELBA uses the collected personal data in order to provide the user with the benefits of the website, to complete the registration of the user to the website, to improve and develop the services provided, to introduce new services and to inform the user about the new services, to make the necessary notifications in this regard, to contact the user and to fulfil the obligations arising from the nature of the services provided.

The personal data in question may be processed as part of ELBA’s reporting and business development activities, and may be used for the purposes of various statistical evaluations, database creation and market research, without revealing the user’s identity. In case the user gives a separate explicit consent, the information in question may be processed, stored, transferred to third parties for the purposes of direct marketing by ELBA and the parties with which it cooperates within the scope of such consent, and the user may be contacted for the purposes of promoting certain applications, goods and services and for sending notifications regarding maintenance and support activities using such information.

Pursuant to articles 5 and 8 of the Code on the protection of personal data and/or to the extent that the exceptions provided for by the applicable legislation allow it, ELBA may process and communicate personal data to third parties without obtaining the consent of the User in the following cases, which are not exhaustive:

The processing is expressly provided for by law,
Processing is necessary to protect the vital interests or physical integrity of the data subject or of a third party if the data subject is unable to give his/her consent due to practical impossibility,
Processing is necessary for the execution or performance of a contract between the user and ELBA,
Processing is necessary to comply with legal obligations,
Personal data has been made public by the user himself/herself,
Processing is necessary for the establishment, exercise or protection of a right,
Processing is necessary for the purposes of the legitimate interest pursued by ELBA, provided that such interest does not harm the fundamental rights and freedoms of the User.
Transfer of data

ELBA may transfer the personal data of the user and new data generated by using such personal data within the framework of the website, for the purpose of enabling the performance of the services provided to the user, to third parties providing services to ELBA, provided that such transfer is limited to the purpose of providing such services. In this regard, for the purpose of improving the user’s experience (including improvement and customisation), ensuring the user’s security, identifying fraudulent or unauthorised use, operational evaluation research, troubleshooting errors related to the website or ELBA services, and realising any of the objectives set forth in this Privacy Policy or other privacy notices provided to the user, ELBA may share the user’s data with third parties such as outsource service providers, hosting service providers, law firms, research companies and call centers.

The User agrees in advance that the aforementioned third parties may store the User’s personal data in the servers located in any part of the world, limited to the aforementioned purposes.

User’s right to access and rectify personal data

By requesting, the user is entitled to

  • Know whether or not personal data concerning him/her is being processed,
  • Request further information if personal data concerning him/her are being processed,
  • Know the purposes for which personal data are processed and whether or not personal data are processed in accordance with these purposes,
  • Know the third parties to whom the personal data is disclosed in the country or abroad,
  • Request the rectification of incomplete or inaccurate personal data,
  • Request the cancellation or destruction of the data in accordance with the provisions of the relevant legislation,
  • Request that the third parties to whom the personal data have been disclosed be informed of the rectification, erasure or destruction operations carried out in accordance with the relevant legislation,
  • To oppose any negative consequences that may be drawn from the processing of personal data with the aid of automated means,
  • Demand compensation for the damage suffered as a result of unlawful processing.

The user can send the above mentioned requests in written form to ELBA may give its reasoned affirmative/negative response with respect to the aforementioned requests, in written form or digitally. As a general rule, the actions taken to answer the requests are free of charge. However, in the event that the actions entail costs, a fee may be charged in accordance with the tariff established by the Data Protection Agency pursuant to article 13 of the Personal Data Protection Code.

The User undertakes that the information provided by him/her to ELBA under this Privacy Policy is complete, accurate and up to date, and that he/she will update this information immediately in case of any change in this information. ELBA shall not be held responsible if the user fails to update such information.

The User agrees and represents that he/she may not fully benefit from the services provided by ELBA if he/she makes a request that prevents ELBA from using any of his/her personal data, and he/she shall be held liable for any matter arising in this regard.

Storage period of personal data

ELBA keeps the personal data provided by the user for the purpose of fulfilling the obligations arising from the nature of the services and the commercial relationship, for the entire duration of the provision of the services and the commercial relationship.

In addition, ELBA can keep the personal data in case of a dispute between ELBA and the user, limited to the purpose of making the necessary defences within the scope of the dispute and for the period of limitation specified by the applicable legislation.


Measures, guarantees and liability regarding data security

Subject to the conditions established by the applicable legislation or by this Privacy Policy, ELBA undertakes to

  • Prevent the unlawful processing of personal data,
  • Prevent unlawful access to personal data,
  • Take the necessary technical and administrative measures to ensure the appropriate level of security for the purposes of preserving personal data and to carry out the necessary audits.
  • In case the website provides links to other applications, ELBA is not responsible for the privacy policies and content of such applications.

ELBA cannot be held responsible for any damages that may result from any use of personal data that falls within the scope of the above terms.

Changes to the privacy policy

Users who make use of the services provided on the website are deemed to have read and accepted all the terms and conditions herein. ELBA reserves the right to modify the provisions of the Privacy Policy without prior notice. The updated Privacy Policy shall be effective from the date it is presented to the User in any manner.


All rights to the content, products, images of products, text, software and other materials on this website are reserved by ELBA and the same are protected by intellectual property rights (patent, trademark, design and copyright) by ELBA. Reproduction or copying of any material from this website without the written permission of ELBA is prohibited.