Cookie Disclosure Text

1. PURPOSE AND SCOPE

This Cookie Disclosure Text has been prepared by Güven Air Aviation Industry and Trade Joint Stock Company (hereinafter referred to as “Güven Air”) to outline the general definitions of cookie data related to website visitors, specify their types, and explain the principles and procedures regarding the processing and management of cookie data in compliance with the Law No. 6698 on the Protection of Personal Data (KVKK) and the “GUIDE ON COOKIE PRACTICES” published by the Personal Data Protection Authority.

This disclosure text covers the processing of personal data through cookies; cookies that are not used for personal data processing are excluded from this scope. It applies to desktop and mobile websites, as well as web applications operated by Güven Air.

We may update this disclosure text when necessary. Therefore, please make sure to access the most recent version available at the time you use our web and mobile services.

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2. DEFINITION OF COOKIES

A cookie is a type of text file placed on the user’s device by website operators and transmitted as part of an HTTP(S)3 (Hypertext Transfer Protocol) request. When a user visits a webpage, cookies allow certain information about the user to be stored on their terminal device in small, formatted text files.

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3. TYPES OF COOKIES

Cookies are categorized based on their duration, purpose of use, and source. Below are the types and descriptions of cookies:

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3.1. According to Their Duration

Session Cookies:
Also called temporary cookies, these are used to maintain session continuity. They are deleted when the user closes the browser.

Persistent Cookies:
These cookies remain stored even after the browser is closed and are automatically deleted after a set date or duration. Persistent cookies transfer data to the server each time the user visits the website. They may also be used to remember login details or for long-term tracking (e.g., by advertisers to analyze browsing habits).

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3.2. According to Their Purpose of Use

Strictly Necessary Cookies (Mandatory Cookies):
These are essential for the website to function properly and to provide a service explicitly requested by the user (e.g., logging in, filling forms, or remembering privacy preferences). Blocking these cookies may cause parts of the website to malfunction.

Functional Cookies:
Used to remember preferences or personalize website experiences (including desktop, mobile, or IoT applications). In cases where functionality is not explicitly requested by the user, explicit consent is required.

Performance/Analytics Cookies:
Used for statistical purposes to analyze user behavior and improve the site (including measuring ad performance). They help estimate visitor numbers, track navigation, and identify keywords leading to visits.

Advertising/Marketing Cookies:
Used to track online activities to determine personal interests and display targeted ads. Behavioral advertising involves tracking, profiling, and displaying relevant ads to users based on their preferences.

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3.3. According to Their Source

First-Party Cookies:
Placed directly by the website the user visits (e.g., the URL displayed in the browser’s address bar — guvenair.com).

Third-Party Cookies:
Placed by third parties from domains different from the one the user visits.

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4. PERSONAL DATA PROCESSING CONDITIONS REGARDING COOKIES

Güven Air processes cookie data either based on explicit consent or within the scope of other legal bases defined in Articles 5 and 6 of the Law.

If processing relies on a legal ground other than consent, explicit consent is not required. Güven Air first determines whether the purpose of processing falls under one of these legal bases; if not, consent is sought.

Users’ explicit consent is obtained for cookies other than mandatory cookies, and they are provided with the ability to modify their preferences at any time via the cookie management panel.

Mandatory cookies are processed under Article 5/2(f) of the KVKK — “where processing is necessary for the legitimate interests of the data controller, provided that such processing shall not violate the fundamental rights and freedoms of the data subject.”

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4.1. Use of Cookies Based on Explicit Consent

Examples of cookies requiring explicit consent include:

• Social Plugin Tracking Cookies: Used by social networks to monitor user behavior for analytics or advertising purposes. Since such tracking is not strictly necessary for the requested service, these cookies require explicit consent.

• Behavioral Advertising Cookies: Used for targeted marketing and analytics purposes such as ad frequency tracking or fraud detection. As they are unrelated to essential website functions, explicit consent is mandatory.

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4.2. Use of Cookies Without Explicit Consent

Examples of cookies that may be used without explicit consent:

• Load Balancing Session Cookies: Used to distribute web traffic among multiple servers to ensure consistency and system stability. These are necessary for communication and do not require consent.

• Security Cookies: Used to protect website functionality (e.g., limiting requests per user session via a firewall). Processed under the lawful basis of legitimate interest.

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5. COOKIES WE USE

Mandatory Cookies

These are required for the proper functioning of our website and for delivering requested services. Processed under Article 5/2(f) of the KVKK.

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Analytical Cookies

Used only with your explicit consent to analyze visitor data and improve website functionality.

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6. COOKIE WALLS

“Cookie walls” block access to website content unless all cookies are accepted. Güven Air avoids using cookie walls that would interfere with obtaining valid consent in accordance with the law.

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7. RESPONSIBILITIES OF THE PARTIES

When third-party cookies are used on the website, both Güven Air and the third party are responsible for providing clear information and obtaining valid consent from users regarding these cookies.

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8. TRANSFER OF PERSONAL DATA

Your personal data may be transferred in compliance with Article 8 of the KVKK to domestic or foreign service providers for purposes such as ensuring commercial security, secure data storage, electronic or physical data backup, and system maintenance.

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9. MANAGING COOKIES

You can manage cookie settings in commonly used browsers via the following links:

• Google Chrome – Enable or disable cookies

• Google Analytics Opt-Out Browser Add-on

• Mozilla Firefox – Delete cookies stored by websites

• Safari (Mac) – Delete cookies

• Safari (iPhone) – Clear history, cache, and cookies

• Opera Web Settings

• Microsoft Edge – Manage cookies (view, allow, block, delete)

• Facebook Privacy Policy

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CONTACT INFORMATION

As a data subject, you may apply to Güven Air to exercise your rights under the KVKK, including:

• Learning whether your personal data are processed,

• Requesting information about your data,

• Learning the purpose of processing and its compliance,

• Knowing third parties to whom data are transferred,

• Requesting correction, deletion, or destruction of data,

• Objecting to unfavorable outcomes due to automated analysis,

• Requesting compensation for damages due to unlawful processing.

Requests may be submitted in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. Güven Air will respond free of charge within 30 (thirty) days, unless the process requires additional cost, in which case the official tariff fee may apply.

GÜVEN AIR AVIATION INDUSTRY AND TRADE JOINT STOCK COMPANY

Address: Esenboğa Center, Özal Boulevard No: 325 D:79, 06146 Çubuk/Ankara
Phone: +90 533 135 78 11
E-mail: [email protected]
KEP Address: [email protected]