Respecting the privacy of the visitors of https://portal.tr-test.com.tr/default.aspx, which is operated by TRtest (the “ ”) under TRtestFoundation, is essential to our . This Privacy Policy which holds the characteristics of protection of personal data protection policy, destruction policy and information notice, sets out the privacy rules that our follows during its operation within TRtest.
1. Data Controller
In line with the requirements of the current technology, your personal data is being processed by TRtest as the data controller, whose headquarters is located at “İvedik OSB Mahallesi, 2224. CaddeTeknopark ANKARA No:1/250 C Blok Kat:13 Yenimahalle / ANKARA TÜRKİYE”, under the procedures indicated below.
2. Purpose of Processing Personal Data and Legal Grounds
In the event that you become a member of our web site and/or use our services, in order to provide you with better service and fulfill our contractual obligations to you, we need some of your personal data, such as; your name, surname, email address, information as to the organization that you are connected to, telephone number, gender, birthday, academic interests, the country, city and province that you reside at, profession, educational and professional background, IP address that you use to visit our website, your instant location data, username and password that you use in our website, computer and linkage information such as type and version of your web browser, operating system and information as to the websites that provide you to visit our website. Other than these information, collective statistical data that are not personal data such as visiting frequency and time of our web site are being processed, in order to analyze and understand the behaviors and choices of the web site visitors.
Personal data collected on our website are processed in order to; (i) improve Turkey's academic and scientific cooperation, (ii) contribute to the economy, (iii) transfer the know-how, (iv) improve the quality of human resources, (v) carry out scientific diplomacy activities, (vi) organize value added activities and programs, (vii) provide positive contribution to the perception of Turkey on international platforms, (viii) use global expertise and human resources to achieve development targets, (ix) announce scientific developments and efforts taking place in Turkey to the world, (x) ensure the active participation of the Turkish academic world to the international decision making processes, (xi) enable Turkish and foreign academicians and scientists to take advantage of the academic and scientific studies carried out in Turkey, (xii) to grant you access to our services, (xiii) inform you of the academic content, news and events, industrial, commercial, scientific and technological developments, products, works and collaborations, (xiv) deal with your questions and requests, (xv) maintain, operate, develop and improve our services, (xvi) obtain information about our service users and analyze how you interact with our services and carry out logical analyzes (e.g. for accounting, audit, finance, legal requirements and other requirements) in order to improve our operations, (xvii) fulfill our relevant legal obligations and cooperate with administrative and executive institutions, (xviii) manage your account on our website and (xix) customize information and commercial electronic messages sent to you, in order for them to be more compliant and relevant.
For the purpose of research, we combine the data as to web site visits with anonymous demographic information and may use these information collectively, in order to create better content. We may combine the website visit information with your personal data in order to provide personalized content in our web site and mobile application.
Our obligation to process your personal data arises from the European Union General Data Protection Regulation (also known as the “GDPR”), the Turkish Law on the Protection of Personal Data No. 6698 (the “Law”), the Turkish Criminal Code No. 5237 and the secondary provisions. In addition, we need to process the personal data of our members and web site visitors in order to fulfill our obligations within the commercial relationships and other bilateral and/or multilateral collaboration protocols formed as per the said provisions and provide the best service.
3. Principles of Processing Personal Data
Your personal data are being processed by the within TRtest, in line with the principles set out below.
• Lawfulness and Fairness
The operates with good faith as it processes your personal data. Within this scope, the solely processes personal data for the purposes that the data subjects are informed of.
• Keeping Personal Data Accurate and, Where Necessary, Up to Date
Technical measures are being taken and destruction processes are being set out, in order to ensure that personal data processed by the are correct and up to date. Control mechanisms are formed in order to correct the personal data that is false and check the accuracy of personal data.
• Processing for Specified, Explicit and Legitimate Purposes (Purpose Limitation)
Data processing within the is only executed for legitimate purposes, as per previously set out rules and the law. The purposes are set out before the processing of personal data and the data subjects are being explicitly informed of such purposes as their personal data are collected. In the event that the personal data processing purposes change, this Privacy Policy gets updated and the puts the effort to notify the data subjects of the change through other channels.
• Data Minimization
Personal data are being processed for previously set out purposes and the personal data that are not relevant to achieve the purposes are not being processed. Only the personal data of the data subjects that are necessary to achieve the purposes are being collected.
• Storage Limitation
The Institution stores personal data, only for the time period set out under the respective law or until the relevant processing purpose is achieved. Within this scope, initially the time periods set out under the respective laws are taken into consideration while storing personal data. In the event that there is no time period indicated under the respective law, personal data stored for the time period that is necessary for the relevant processing purpose to be achieved.
4. Locations to which Processed Personal Data are Transferred and Purpose of Transfer
Your personal data may be transferred to authorized members of our website, our business partners, tax consultants, subcontractors, respective public institutions and Türk Telekomünikasyon A.Ş. (for hosting services), in accordance with the related applicable legislation and membership agreement. Data transfer purpose is parallel with the purpose of processing personal data processing.
In order to carry out our business, we may transfer your personal data to; institutions and organizations that we co-operate with, local/foreign real persons and institutions that provide cloud service, local/foreign institutions that provide service to send commercial electronic messages to our members, courier companies, subsidiary tools within various marketing operations, in order to provide better service and maintain member satisfaction, various local/foreign agencies and advertisement companies, survey companies, other local/foreign third persons and respective business partners.
Our collaborates with institutions for auxiliary services such as sending notifications, mails or e-mails and making credit card payments. Your personal data may be shared with the said institutions in order for them to fulfill their business as per the respective legal provisions. However, we would like to indicate that the said institutions do not have the right to use your personal data for any other business.
5. The Method and Legal Ground for Personal Data Collection
Your personal data are being collected in writing and electronically by our in order to carry out our business through various methods, especially by way of internal networks within the , using cookies and partially automatic methods as a part of the data registry system. Your personal data are being processed and transferred in accordance with the general principles, conditions for processing personal data and exceptions regulated under the respective data protection laws, for the purposes indicated in the Privacy Policy, Cookie Policy, Information Notice, Terms of Use, Frequently Asked Questions, explicit consent forms as per the Membership Contract, all the procedures and rules set out in the web site and the Membership Contract.
6. Retaining and Deleting Personal Data
Personal data processing operations within TRtest are classified based on data categories. In the event that a data category is no longer necessary in relation to the legal and operational purposes for which it is processed, erasure, destruction or anonymization processes are carried out.
Your personal data can also be retained within the legal terms of limitation, in order for us to fulfill our legal or administrative obligations or exercise our rights (such as asserting objections before the courts).
7. Automated Decision Making
Automated decision making means the ability to make decisions using technology, without human involvement.
7.1. Profiling
Profiling means automatically processing personal data to evaluate certain personal aspects about an individual, in particular to analyze or predict aspects concerning performance at work, economic status, health, personal, educational and/or professional preferences, interests, reliability, behavior, location or movements.
When we send or display personalized communications or content, we may use some profiling techniques. This means that we may collect personal data about you in the different scenarios mentioned above, and use this data to analyze, evaluate, or predict your personal preferences, interests, behavior and/or location.
Based on our analysis, we then send or display communications and/or content specifically tailored to your interests and needs.
You have the right to object at any time to the use of your personal data for “profiling” and request the processing of such data to be restricted.
8. International Transfers of Your Personal Data
By taking all the necessary measures, we can transfer the personal data that are being processed to third parties and their subsidiaries abroad, solely for our legitimate interests. In the event that hosting services are provided from countries within European Union, your personal data can be transferred to the country of the hosting service provider. In addition, personal data can be transferred to international organizations that cooperate with TRtest , solely for the respective processing purpose.
The personal data can be transferred by our , for legitimate and legal data processing purposes, to foreign countries as to which the European Commission has rendered an "adequacy decision" and in case the data protection authority of the respective country is deemed to be able to provide necessary protection. In the event that there is no "adequacy decision" about the countries to which personal data are being transferred and such countries are not deemed to be able to provide necessary protection, the data controllers in the said countries undertakes to provide the necessary protection in writing and thereby the personal data is transferred to such countries.
9. Cookies
Cookies are small text files that websites send to computers or other devices connected to the Internet to identify the browser alone or to store some information or settings on the browser. When certain types of cookies are received, the browser can send a notification to you, or inform you of how some cookies can be restricted or disabled. Without cookies, you may not use all the features of our website. Web analytics services of third parties such as Coremetrics and Google Analytics can be used on the website. Service providers who provide these services use technologies such as cookies, network provider records, and network markers to help analyze how the visitors use the site. Information gathered through these tools (including IP addresses) is disclosed to the relevant service providers who will use this information to evaluate the use of the website. We can use the content of pixel tags when the website is visited or sent e-mails are opened.
Please see our , in order to obtain detailed information as to cookie use.
10. Measures That are Taken to Ensure the Security of Personal Data
In line with the importance given to the protection of personal data and data security, our takes all the technical and administrative measures necessary to maintain the necessary security level as per the provisions under the Law and GDPR, in order to;
- Prevent unlawful processing of personal data,
- Prevent unlawful access to personal data,
- Retain personal data.
11. Your Rights and Choices
In this Section 11, we have summarized the rights that you have under data protection law. In the event that you request to exercise your rights below for the first time, the will answer the request free of charge. However, in case answering your request requires extra cost, both the first request and following the following requests may be subject to a fee.
(a) Right to be informed:
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data, and your rights. This is why we are providing you with the information under this Privacy Policy.
(b) Right to access:
You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. Said additional information include details as to processing purposes, respective personal data categories and the recipients of the personal data. Provided that the rights and freedoms of others are not affected, we will supply to you a copy of your personal data.
(c) Right to Rectification:
You have the right to have your personal data rectified if it is incorrect or outdated and/or completed if it is incomplete. Even though you have the right to rectification as per the respective regulations, you can rather easily rectify and/or update your personal data through the respective sections in your personal profile.
(d) Right to Erasure / Right to be Forgotten:
In some circumstances you have the right to demand the erasure of your personal data without undue delay. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
(e) Right to Restrict Processing:
In some circumstances you have the right to restrict the processing of your personal data. Right to restriction of processing can be used where one of the following applies: you contest the accuracy of the personal data; processing is unlawful and you oppose the erasure of the personal data and request restriction of their use instead; we no longer need the personal data for the purposes of the processing, but we are required by you for the establishment, exercise or defence of legal claims; and you object to processing pending the verification whether our legitimate grounds override yours. Where processing has been restricted on this basis, we can continue to store your personal data. However, we can only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest. Even though you have the right to restrict processing as per the respective regulations, you can also exercise the right to suspend your personal profile through the respective section in your personal profile, instead of or together with the right to restrict processing. In the event that you exercise your right to suspend your personal profile, third parties’ access to your personal data in your personal profile and processing of your personal data will be suspended for the suspension period. Where your personal profile is suspended on this basis, we can continue to store your personal data.
(f) Right to Object to Processing:
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or the exercise of any official authority vested in us or; the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
You have the right to object to the processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for public interest.
(g) Right to Data Portability:
You have the right to move, copy or transfer your personal data from our database to another, by the means of current technology. This only applies to personal data that you have provided, where processing is based on a contract or your consent, and in the circumstances where processing is carried out by automated means.
(h) Right to Withdraw Consent:
To the extent that the legal basis for the processing of your personal data is your consent, you have the right to withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
(i) Right to Complain to a Supervisory Authority:
If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. Do not hesitate to contact us at the details below before lodging any complaint with the competent data protection authority as we will always seek to resolve your complaint in the first instance.
For more information as to this Privacy Policy, or to request any of the rights noted above, you can fill out the application form in the link below and send an e-mail to info@tr-test.com.tr. You can also fill out the application form and submit it to the address below via registered letter with return receipt:
“TRtest İvedik OSB Mahallesi, 2224. Cadde TeknoparkANKARA No:1/250 C Blok Kat:13 Yenimahalle / ANKARA TÜRKİYE”
Our website may provide links to other websites for your convenience and information. These web sites may be operated independently from the . Linked web sites may have their own privacy statements and policies, and it is strongly recommended to review such documents in the event of a visit to any linked website. Our is responsible neither for these sites nor any content, use and/or privacy of these sites unless the linked websites that you visit are owned or controlled by our .
This Privacy Policy, which is prepared by our within TRtest, may be updated periodically to indicate our personal data practice without any prior notice. In the event that any important update is made in our Privacy Policy, a noticeable notification will be published in our website in order to inform you. In addition, you can find the latest date of update in the very top section of this Privacy Policy.
