Privacy Policy

Data Controller under the Law

In accordance with Article 3 of the Law, the Data Controller is:

SANUS SIGORTA BROKERLIĞI ANONIM ŞIRKETI (“Sanus”)

Harbiye Mah. Asker Ocağı Cad. Süzer Plaza No: 6 İç Kapı No: 120 Şişli / İstanbul

Tax ID: 7441222438

Trade registry number: 1094833 / Istanbul Trade Registry

Sanus processes personal data of users in compliance with the Law and related secondary regulations.

Principles Governing the Processing of Personal Data

Personal data are processed in accordance with the following principles, pursuant to Article 4 of the Law:

Employees of Sanus are required to comply with the company's policies and procedures regarding the protection of personal data and the safeguarding of privacy. In this context, all employees are responsible for acting in accordance with data security and privacy rules.

Sanus is committed to carefully reviewing all reports and complaints alleging violations of the Privacy Policy, conducting the necessary assessments, and taking appropriate measures in accordance with applicable legislation and internal company procedures if any breach is identified.

Legal Grounds for Processing Personal Data (Article 5 and 6)

Personal data are processed in accordance with Articles 5 and 6 of the Law. Personal data shall not be processed without explicit consent of the data subject.

Personal data may be processed without seeking the explicit consent of the data subject only in cases where one of the following conditions is met (Article 5 of the Law):

Personal data relating to a person's race, ethnic origin, political opinion, philosophical belief, religion, religious sect or other beliefs, appearance, membership in associations, foundations or trade unions, data concerning health, sexual life, criminal convictions and security measures, as well as biometric and genetic data, are considered special categories of personal data. Special categories of personal data, if any, are processed only in compliance with the Law and with adequate administrative and technical safeguards.

It is prohibited to process special categories of personal data. However, such processing is permitted under the following conditions under Article 6 of the Law:

Separate information notices and policies have been prepared for each section where data collection activities are carried out, as well as for the cookies used on this website, regarding the processing of personal data. You can access these notices and policies directly through the relevant sections.

Purposes of Processing Your Personal Data

Your personal data are collected by Sanus for the purpose of providing services to you, through automatic or non-automatic means via registration, through channels such as e-mail, relevant websites and mobile applications, and through the accounts to which you have granted access, in electronic environments, as well as through the call center channel or physically via mail/cargo, based on the following legal grounds set forth in Article 5 of the Law.

Personal data will be processed for the following purposes

Personal data may be processed by our company, as well as by our authorized business partners and service providers, for purposes including the evaluation and finalization of job applications; reviewing and responding to requests, suggestions, complaints, and feedback; developing our products and services in line with your needs and expectations; responding to quotation requests and providing suitable offers; enhancing customer satisfaction; improving the use of our website and digital platforms; enhancing user experience; conducting marketing, advertising, and promotional activities; carrying out satisfaction surveys and market research; offering campaigns, benefits, products, and services tailored to your interests; ensuring the effective and efficient operation of our business activities; promoting our services and related products to you; and carrying out commercial communication activities for advertising, marketing, and promotional purposes regarding new products, special offers, and other topics or products that we believe may be of interest to you.

In order to benefit from certain services and functionalities available on our website, you may be required to share certain personal data with us. Personal data requested within this scope is collected, stored, updated, analyzed, and, where necessary, shared with our business partners, suppliers, and authorized third parties solely for the purpose of providing the relevant service, fulfilling your request, or carrying out the related activity, in compliance with applicable legislation.

These service providers may offer services in areas such as data analytics, advertising and marketing, information technology infrastructure, server and data hosting services, cybersecurity solutions, electronic communication services (including SMS and email), and customer support processes. Such disclosures are made only to the extent necessary to ensure the effective and secure delivery of services, and the relevant parties are subject to data security and confidentiality obligations.

The decision to share your personal data is entirely at your discretion. However, if the personal data required for the provision of a particular service or activity is not provided, you may not be able to benefit from the relevant services or functionalities, either partially or in full.

Personal Data Being Processed

In this context, your personal data, the email address you provide during newsletter subscription, your preferences, requests, and usage habits regarding our products and services, your past experiences, as well as information related to payment and invoicing processes may be processed.

As part of your subscription to commercial electronic communications, your personal data (such as your name, surname, email address, telephone number, and communication preferences) may be processed for the purposes of sending you information regarding our products and services, as well as marketing, promotional, campaign, event, survey, and other commercial communications that may be of interest to you. Your personal data will be processed based on your explicit consent and may be shared with our service providers, business partners, and third-party electronic communication service providers to the extent necessary for these purposes and in compliance with applicable data protection laws. You may withdraw your consent and unsubscribe from commercial electronic communications at any time.

These data may be collected, used, and processed for the purposes of providing and improving our services, enhancing customer satisfaction, conducting analysis and evaluation activities, fulfilling legal obligations, and ensuring the continuity of our business operations.

Personal data of individuals benefiting from the products and services offered by Sanus via online platforms, including user identification information (username and password), IP address information, system access logs, user activity records (records related to actions such as password creation and password reset), website login and logout information, and device identifiers (device ID) and token information of the device used for access, are processed for the purposes of ensuring technical, administrative, legal and commercial security, and providing the services.

Such personal data are processed on the following legal bases: (i) processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract; and/or (ii) data processing is necessary for the establishment, exercise or protection of any right.

Your personal data may be shared, for the purposes stated above, with our employees, business partners, service providers, suppliers, affiliates, authorized dealers, and, where permitted or required by law, with authorized public institutions and organizations, as well as other relevant third parties.

Transfer of Personal Data to Third Parties and/or Abroad

Your personal data may be transferred to third parties and/or abroad in accordance with the conditions specified in Articles 8 and 9 of the Law for the purposes stated above, based on your explicit consent where required.

Accordingly, your personal data may be transferred to third parties and/or abroad for the purposes stated above under the following circumstances:

Personal data may be transferred abroad if one of the conditions specified in Articles 5 and 6 of the Law is met and there is an adequacy decision regarding the country, sectors within the country, or international organizations to which the transfer will be made. Transfers are conducted in compliance with the principles of the Law.

Your personal data may be transferred, in line with the purposes stated above and within the framework of the conditions set forth in Articles 8 and 9 of the Law, based on your explicit consent, to (i) domestic and foreign third parties from whom Sanus receives services for storage, archiving, and hosting systems for the purpose of carrying out its information security processes; (ii) domestic and foreign vendors, our consultants, trainers, employees, business partners, suppliers, collaborating employees, and dealers; (iii) authorized public institutions and organizations, where required by applicable legislation; (iv) hosting service providers whose servers are located domestically and/or abroad; and (v) domestic and foreign third parties from whom we receive support for operational activities.

In connection with transactions such as a merger, acquisition, division, transfer of assets, or a change in the control or ownership structure of Sanus, personal data of website users may be shared with the relevant third parties.

Data Subject Rights under the Law (Article 11)

Pursuant to Article 11 of the Law, data subjects have the right to:

You have the right to claim compensation for damages if you suffer harm due to the unlawful processing of your personal data. However, according to Article 28, paragraph 1 of the Law, the rights listed above cannot be asserted in the following cases:

Retention, Deletion, Destruction, and Anonymization of Personal Data

You have the right to set your preferences regarding the processing of your personal data and to update them at any time.

In this context

Your personal data are stored for the periods stipulated in the relevant legislation.

In cases where no retention period is stipulated in the law regarding the retention of personal data, it is processed at data controller’s discretion and in accordance with commercial practices for as long as necessary. Upon expiration of this period, personal data are deleted, destroyed, or anonymized.

Personal data whose processing purpose has ended, or which you have requested to be deleted or anonymized, may be retained for purposes such as serving as evidence in potential disputes, asserting a right, or establishing a defense, provided that the retention periods stipulated in the law have also expired.

Even if processed in accordance with the provisions of the legislation, if the reasons requiring its processing cease to exist, personal data will be deleted, destroyed, or anonymized upon Sanus’ decision or your request.

You may submit your requests using one of the application methods listed on the Data Subject Application Form page.

Requests will be concluded as soon as possible and/or within 30 (thirty) days. However, if fulfilling your request incurs additional costs, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board.

If any provision of this Privacy Policy is deemed invalid, unenforceable, or void by a competent court or administrative authority, such determination shall not affect the validity and enforceability of the remaining provisions of the Privacy Policy. In such a case, the invalid or unenforceable provision shall be replaced by applicable legal provisions that most closely reflect the intent of the parties and the purpose of the relevant provision.

For the purpose of resolving disputes, you may apply to mediation in accordance with the relevant legislation. Initiating mediation does not prevent the parties from exercising their other legal rights and remedies arising under the law.

Where it is necessary to apply to judicial authorities depending on the nature of the dispute, you may bring your claims before the competent and authorized courts.

Sanus reserves the right to update this Privacy Policy unilaterally if required by law.