Fener Değertay

İÇİNDEKİLER

  • 1. Kapsam
  • 2. Hakkınızda Hangi Kişisel Verilere Sahibiz
  • 3. Kişisel Bilgileri Açıklama Zorunluluğu Yoktur
  • 4. Hangi Kişisel Verileri Topluyoruz
  • 5. Kişisel Verilerin İşlenmesinin Hukuki Dayanağı ve Gerekçeleri
  • 6. Kişisel Verilerin Üçüncü Taraflara Aktarılması
  • 7. Üçüncü Taraflara Ait Çerezler ve Hizmetler
  • 8. Kişisel Verilerin Saklanması
  • 9. Uluslararası Transferler
  • 10. Kişisel Verilerin Güvenliği
  • 11. Üçüncü Taraf Web Sitelerine Köprü Bağlantıları
  • 12. Bu Politikada Yapılacak Değişiklikler
  • 13. Haklarınız

Gizlilik Politikası

Son güncelleme: 15.06.2026

We ("We", "Us", or "Our") are committed to protecting your Personal Data and privacy. This Privacy Policy explains how we collect and store the information you provide through the Fener Değertay website (the "Website").

We want you to be in a position to make informed decisions about how your Personal Data is used and processed. We rely on a range of methods and procedures to provide you with the relevant information. Where we believe you require specific details, we will supply that information at a time and date convenient to you. We are happy to answer any questions you may have regarding limitations imposed by law.

By using our Website, you confirm that you have read and accept this Privacy Policy. For questions, contact us at: support@fener-degertay.com

1. Kapsam

1.1 This policy explains the types of Personal Data the Company collects about individuals, how it processes that data, how it shares it with third parties, how it secures its processing activities, and related matters.

1.2 This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly, or by combining additional information we hold or can access.

1.3 Bu Politika, "işleme" terimini Kişisel Verilerin kullanılmasını veya toplanmasını gerektiren bir süreç olarak tanımlar. Bu, Kişisel Verilerin yönetimini, yapılandırılmasını ve saklanmasını kapsar.

1.4 Our Services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly request or collect information from anyone under 18, nor do we knowingly allow such individuals to use our Services. If we learn that we hold any information belonging to a child, we will delete it as soon as possible.

2. Hakkınızda Hangi Kişisel Verilere Sahibiz

2.1 We collect your Personal Data when you access the Services and channels or visit our website. In certain cases, we may request your Personal Data.

2.2 In other cases, we collect your Personal Data by analyzing how you use our Services or service channels, or by receiving your information from our third-party business partners.

3. Kişisel Bilgileri Açıklama Zorunluluğu Yoktur

3.1 You are not required to provide us with any Personal Data. However, withholding such information may prevent us from delivering our Services or granting you access to the website.

4. Hangi Kişisel Verileri Topluyoruz

4.1 This includes information about your online activity records, along with traffic data such as the following:

  • IP adresi
  • Erişim tarihi ve erişim saati
  • Kullandığınız dil
  • Yazılım çökme kayıtları
  • Kullanılan tarayıcı türü
  • Kullandığınız cihaza ilişkin bilgiler

4.2 The information we collect is not private in nature and cannot be used to identify you.

4.3 Personal Data we collect from you: any personal data you choose to provide to Us when you connect through Us to a third party's online trading platform.

4.4 Personal information you provide directly to third-party platforms to facilitate transactions: This includes your full name, address, phone number, and email address.

5. Kişisel Verilerin İşlenmesinin Hukuki Dayanağı ve Gerekçeleri

5.1 Your Personal Data is processed by the company for the purposes described in this section and on the legal grounds applicable to them.

5.2 The Company may not use your Personal Data without a legal basis. The legal grounds on which the Company may process your Personal Data are as follows:

  • You have consented to the processing of your personal data for one or more purposes. This applies when you submit your personal data to us through the Website so that we may transfer it to a third-party trading platform.
  • The Company or a third party may process data to pursue legitimate interests. For example, such processing may be necessary to improve our Services or to defend against legal claims.
  • İşleme, yasal bir yükümlülüğü yerine getirmelidir.

5.3 To learn more about the processing activities required to protect legitimate interests, contact us by email.

5.4 Below are the reasons and legal bases on which we may use the information you provide:

Kapsam

Yasal Dayanak

1. To share your personal data with third parties so that you can access digital trade
If you request this, we may ask you for Personal Data to pass on to third-party companies.

Kişisel Verilerinizin bir veya birden fazla amaçla işlenmesine onay verdiniz.

2. To respond to your requests, questions, or concerns
Personal Data is required to help us address any questions you may have regarding the Services.

Şirketin meşru menfaatleri veya bir üçüncü tarafın menfaatleri işlenmesi gerekmektedir.

3. Personal Data is processed to fulfill legal obligations or to meet administrative, judicial, or legal requirements.

Yasal yükümlülüklere uyumu sağlamak için işleme yapılması gereklidir.

4. To improve our Services
We may use Personal Data to improve our Services. This includes, among other things, the crash and error reports we collect in connection with the Services.

Şirketin meşru menfaatlerinin veya üçüncü bir tarafın menfaatlerinin işlenmesi gerekmektedir.

5. Dolandırıcılığı ve Hizmetlerimizin kötüye kullanımını önlemek için.

Şirketin meşru menfaatlerinin veya üçüncü bir tarafın menfaatlerinin işlenmesi gerekmektedir.

6. Carrying out and managing operations aligned with the requirements of our Services
These activities include back-office functions, business development, strategic decision-making, audit mechanisms, and similar processes.

Şirketin meşru menfaatlerinin veya bir üçüncü tarafın menfaatlerinin işlenmesi gerekmektedir.

7. Performing analyses such as statistical analysis
We use various analytical techniques, including statistical ones, to make decisions on a range of matters.

Şirketin meşru menfaatlerinin veya bir üçüncü tarafın menfaatlerinin işlenmesi gerekmektedir.

8. To protect our assets, rights, and interests, and those of third parties
We may process Personal Data to protect our rights, interests, and assets, or those of third parties, in accordance with applicable laws, regulations, contracts, and any terms, conditions, or policies.

Şirketin meşru menfaatleri veya bir üçüncü tarafın menfaatlerinin işlenmesi gerekmektedir.

6. Kişisel Verilerin Üçüncü Taraflara Aktarılması

6.1 The Company may also share Personal Data, IP address information, and user experience analytics with third party companies that provide services to us, such as hosting and storage providers.

6.2 You may also request that we share certain Personal Data about you with third-party trading platforms. In these cases, we will transfer the Personal Data you have provided to us to those third-party trading platforms. The use of your Personal Data will be governed by the privacy policies of those platforms. Your Personal Data may be shared with more than one trading platform.

6.3 The Company may share Personal Data with relevant organizations or business partners. This may provide the Company with the resources needed to develop and improve the products and services offered to its customers.

6.4 The Company may share Personal Data with regulatory, local, or other official authorities where necessary to protect the rights or assets of third parties.

6.5 Furthermore, in the event of such a transaction (including the transfer or sale of assets belonging to the Company or any company within the group), or as part of a merger, restructuring, consolidation, or insolvency of the Company or any business within the group, we may share Personal Data relating to you with potential investors or buyers, or with institutions providing credit to the Company or any company within the group.

7. Üçüncü Taraflara Ait Çerezler ve Hizmetler

7.1 Our website may use third-party services, such as advertising or analytics companies. These companies may also use cookies or other technologies.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve your experience, track your settings, and personalize products and services that may interest you. Cookies are also used for statistical and analytical purposes.

7.3 Some of the cookies we use are session cookies. These are downloaded temporarily to your device and remain there for a short time until you close your browser. Other cookies are persistent. Persistent cookies stay on your device for a set period after you close your browser. These cookies help the Website recognize you as a returning user and encourage users to come back to the website.

Çerez türü

Çerezler kesinlikle gereklidir

Kapsam

These cookies are necessary to access the features you request and to navigate our website. They are used to deliver the information, products, and services you request from us.
They enable your device to download and stream data, allowing you to browse the website, use its features, and return to pages you have previously visited.

Ek Bilgiler

Cookies collect Personal Data such as your username and last login date to verify that you are signed in to the site. These cookies are deleted when you close your web browser (session Cookies).

Çerez türü

İşlevsellik Çerezleri

Kapsam

Cookies allow us to recognize you each time you visit our site and to remember your preferences.

Ek Bilgiler

Geçerlilik tarihine kadar saklanır ve tarayıcı kapatıldıktan sonra dahi korunur.

Çerez türü

Performans için çerezler

Kapsam

Cookies collect statistical data on the site's performance and help us improve it. They also enable us to carry out analytics on our website.

Ek Bilgiler

Cookies store anonymous data that cannot be linked to any identified or identifiable individual. Some are deleted when you close your browser, while others remain valid indefinitely.

7.4 Blocking or removing cookies. To block or remove cookies, adjust your browser settings. The links below will help you do this in several of the most widely used browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 However, please note that if this occurs, some or all of the functions and features of the Website may not work as you expect.

Çevrimiçi İzleme Bildirimi: Bu hizmet şu anda izlememe sinyallerini desteklememektedir.

8. Kişisel Verilerin Saklanması

8.1 The Company will retain your Personal Data for as long as necessary to fulfill the purposes for processing Personal Data described in this Policy, or for longer periods where permitted by applicable laws or regulations, policies, and applicable orders.

8.2 We will share your information with third-party trading platforms for 12 months. If you consent, we will continue sharing your data for an additional 12 months.

8.3 We regularly review the Personal Data we hold to confirm it is still needed.

9. Uluslararası Transferler

9.1 Your personal data may be transferred to other countries (meaning your personal data may be sent to a third country or to international organizations). The Company takes all necessary measures to protect the personal data you provide and to ensure that data subjects can exercise their rights and access effective legal remedies.

These protections and safeguards are available to anyone residing within the EEA (European Economic Area):

  • In accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR"), transfers to a third country or international organisation that the EU Commission has determined ensures an adequate level of protection for the Personal Data transferred to it
  • The transfer is carried out under Article 46(2)(a), pursuant to a legally binding and enforceable agreement between public authorities or bodies.
  • The transfer is carried out in accordance with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR.

9.3 The Company can provide details of the security measures applied to protect your Personal Data transferred to third countries or international organizations. Email us at: support@fener-degertay.com

10. Kişisel Verilerin Güvenliği

10.1 We have implemented appropriate organizational and technical measures to protect Personal Data. These measures help prevent the accidental or unlawful destruction, loss, or alteration of Personal Data.

10.2 We cannot guarantee or warrant that the security of your Personal Data will be protected without fault. We are also not liable for any non-material, incidental, or indirect damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed due to transmission errors, unauthorized access by a third party, or any other cause beyond our control.

10.3 Where required by legal obligations or other circumstances beyond our control, we may need to disclose your Personal Data to third parties such as public authorities. In such cases, we cannot control the security applied to your Personal Data by those third parties.

10.4 Personal Data cannot be transmitted over the internet with complete security. The Company cannot guarantee the security of any Personal Data you send to Us via the internet.

11. Üçüncü Taraf Web Sitelerine Köprü Bağlantıları

11.1 The website contains links to third-party sites and applications. These applications and websites are not under the Company's control. We are not responsible for the collection or processing of Personal Data by these websites or applications. This Policy does not apply to activities carried out through such sites or applications.

11.2 Before accessing any third-party websites or applications, we recommend reviewing their privacy policies before deciding whether to access or use them, and before providing them with your Personal Data.

12. Bu Politikada Yapılacak Değişiklikler

12.1 We may update this Policy at any time. If we make changes, we will notify you by publishing the updated Policy on our website.

12.2 Furthermore, when we make significant changes to this Policy, we will seek to notify you through methods we deem appropriate and publish a notice on our website.

12.3 Unless otherwise stated, any changes take effect once the revised Policy is published.

13. Haklarınız

13.1 You have the right to request that we confirm the accuracy of the Personal Data collected about you, correct any errors, and delete any Personal Data we no longer require. You may also limit the scope of how your personal information is processed.

13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you have provided regarding your Personal Data. To exercise the rights available to you, submit a request by emailing the address below.

13.3 Access rights The Company can confirm the accuracy of the Personal Data processed about you. If this data is being processed, you may access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. If you request it, the data will be made available electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request harms another person's rights and freedoms, the Company may refuse to fulfil it or limit its capacity to do so.

13.4 Right to rectification The Company has the right to rectify inaccurate Personal Data. Taking the purposes of processing into account, you have the right to request that incomplete Personal Data concerning you be completed.

13.5 Right to Erasure The following grounds apply: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no other legal basis for the processing; (c) for reasons specific to your situation, you object at any time to the processing of Personal Data concerning you that is based on legitimate interests pursued by Us or a third party; (e) the Personal Data is processed unlawfully; or (f) the Personal Data must be erased to comply with the company's legal obligation. This right does not apply where the processing is necessary (a) to fulfil a legal obligation that requires processing under European Union law or Member State law; or (b) for the establishment, exercise, or defence of legal claims.

13.6 Restrictions on processing If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict its processing. Where you request such a restriction, your Personal Data may only be retained with your consent, or for the establishment, exercise, or defence of legal claims, for the protection of another natural person's rights, or for reasons of substantial public interest within the European Union or a Member State.

13.7 Right to data portability Where processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the legal right to receive the Personal Data you have provided to the Company. Where technically feasible, you have the right to request that your Personal Data be transmitted directly from the Company to another controller. Your rights under the right to erasure are not affected by exercising your right to data portability. The right to data portability does not adversely affect the rights or freedoms of others.

13.8 Right to object You have the right to object at any time to any use of your Personal Data based on the legitimate interests pursued by the Company or a third party. This right is not limited to profiling based on those legitimate interests. If we can demonstrate compelling legitimate grounds for processing your Personal Data, we may continue processing it unless you can show that your rights, freedoms, or interests override those grounds, or that the processing is necessary for the exercise, establishment, or defense of legal claims. In relation to direct marketing, you have the right to object at any time to the processing of your Personal Data.

13.9 Right to withdraw consent You may withdraw your consent to our processing of your Personal Data at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. Within the European Union, you may object to a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to the processing of Personal Data. As detailed in this Section 13, the laws of the European Union and its Member States may limit your rights regarding your Personal Data.

13.10 Talebinizde, bu sözleşmenin 13. bölümü kapsamındaki haklarınıza dayanarak istediğiniz bilgileri, talebinizi aldığımız tarihten itibaren bir ay içinde size sunarız. Bu süre, talebin niteliğine ve talep sayısına bağlı olarak gerektiğinde iki aya kadar uzatılabilir. Böyle bir uzatma söz konusu olduğunda, uzatmayı ve gerekçelerini talebinizi aldıktan sonraki bir ay içinde size bildiririz.

13.11 Provided that it does not conflict with the provisions of Article 13 of the Law, the information you request under your rights set out in Article 13 will be provided free of charge. If a request is unfounded or excessive, particularly where it is repetitive, we may charge a reasonable fee to cover the administrative costs of providing the requested information or carrying out the action. Alternatively, we may decline to act on the request.

13.12 If we have doubts about the identity of the individual making the request, we may ask that person to provide reasonable means of identification.

Bu Gizlilik Politikası, Kullanım Koşulları ve Risk Bildirimi ile birlikte okunmalıdır.

Fener Değertay 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@fener-degertay.com