This Sabancı Arf Website Privacy Statement provides information on the principles followed by Hacı Ömer Sabancı Holding Anonim Şirketi (“Sabancı Holding”) while processing personal data as per the Law No. 6698 on Personal Data Protection Law (“KVKK”) and how to use your rights under the Article 11 of KVKK.
1. 1. Purposes of Use of Data, Legal Reasons and Collection Methods
As per the principles of Article 4 of the KVKK and in connection with the purposes and legal reasons stated below, Sabancı Holding collects data through essential and non-essential cookies, application form, newsletter registration form and other areas of the Web Site and further process (automated and non-automated means), stores and secures the data in Sabancı Holding’s physical and electronic systems.
1.1. Sabancı ARF Parties
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Personal Data Category |
Purpose of Processing |
Legal Reasons |
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Information provided on the Application Form (“Application Form Information”) either filled out directly by yourself or one of your team members while registering the Sabancı Arf (“Program”) |
Evaluation of applications, maintenance of investment process, communication purposes |
Processing of personal data belonging to parties of an agreement is required, providing that it is directly related to establishment or performance of an agreement (Article 5/2-c KVKK).
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Name-surname, contact information (e-mail, mobile phone) company information |
Public entities and authorities who are legally authorized to get information |
It is a legal requirement for performance by Sabancı Holding of its legal obligations (Article 5/2-ç KVKK). |
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Application Form Information and other information you would like to share with Sabancı Holding during the Program (requests, questions, suggestions, and other personal information) |
Assessment of the startup and management of investment process.
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Data processing is necessary for the establishment, exercise or protection of any right (Article 5/2-e KVKK). Data processing is necessary for the legitimate interests of Sabancı Holding (Article 5/2-f KVKK).
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Application Form Information and other personal data which are necessary for the transactions following the Program. |
Execution and completion of legal proceedings (such as company establishment, share transfer, partnership agreement) if you are awarded an investment from Sabancı Holding. Preventing disputes, taking necessary legal actions, providing necessary information and documents in case of being involved in legal processes. |
Processing is expressly provided for by the laws (Article 5/2-a KVKK). Processing of personal data belonging to parties of an agreement is required, providing that it is directly related to establishment or performance of an agreement (Article 5/2-c KVKK). Data processing is necessary for the establishment, exercise or protection of any right (Article 5/2-e KVKK).
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Third-party personal data provided on the Application Form will also be processed under this Privacy Statement. Applicants should inform these third parties before registering for the Program. It is your responsibility to share the personal data of these third parties with Sabancı Holding in accordance with KVKK.
Sabancı ARF may obtain services from external suppliers within the scope of the Program. In such cases where the data transfer is not made directly by Sabancı Holding, external suppliers may process, store and transfer your personal data abroad. Accordingly, external suppliers are responsible to take actions such as providing Privacy Statement or collecting explicit consent in accordance with KVKK.
Website Visitors
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Personal Data Category |
Purpose of Processing |
Legal Reasons |
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Web traffic (IP address, port number, start and end time of the service provided, type of service used, amount of data transferred, member identification information). |
Law No. 5651 on Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publication |
Processing is expressly provided for by the laws (Article 5/2-a KVKK). It is a legal requirement for performance by Sabancı Holding of its legal obligations (Article 5/2-ç KVKK). |
2. Transfer of Personal Data
2.1. Sabancı ARF Parties
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Transferees |
Personal Data Transferred |
Purpose |
Legal Reasons |
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Omtera Bilişim Teknolojileri ve Ticaret Şirketi (Asana Solutions Partner) |
Name-surname, contact information (e-mail, mobile phone) of entrepreneur and mentor |
Data is transferred for the purpose of bringing the entrepreneurs and mentors on the platform |
Data processing is necessary for the legitimate interests of Sabancı Holding (Article 5/2-f KVKK). |
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Luckeye Bilgisayar Tanıtım Hizmetleri Yayıncılık ve Ticaret A.Ş. |
Name-surname, title, Linkedin profile, photograph |
Introduction of the mentors |
Data processing is necessary for the legitimate interests of Sabancı Holding (Article 5/2-f KVKK). |
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Mentors, instructors, consultants, Sabancı Group Companies (“Business Partners”). |
Application Form Information and other information you would like to share with Sabancı Holding during the Program (requests, questions, suggestions, and other personal information) |
Data is transferred for the purpose of effective execution and management of the Program processes, website functioning, evaluation of your startup. |
Data processing is necessary for the legitimate interests of Sabancı Holding (Article 5/2-f KVKK). |
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Public entities and authorities |
Application Form Information and other information you would like to share with Sabancı Holding during the Program (requests, questions, suggestions, and other personal information) |
Preventing disputes, taking necessary legal actions, providing necessary information and documents in case of being involved in legal processes. Receiving information/document requests from public entities and authorities.
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It is a legal requirement for performance by Sabancı Holding of its legal obligations (Article 5/2-ç KVKK); Data processing is necessary for the establishment, exercise or protection of any right (Article 5/2-e KVKK). |
2.2. Website Visitors
1. Purposes of Use of Data, Legal Reasons and Collection Methods
| Transferees | Personal Data Transferred | Purpose | Legal Reasons |
| Mentors, instructors, consultants, Sabancı Group Companies (“Business Partners”). | Application Form Information and other information you would like to share with Sabancı Holding during the Program (requests, questions, suggestions, and other personal information)
| Data is transferred for the purpose of effective execution and management of the Program processes, website functioning, evaluation of your startup.
| Data processing is necessary for the legitimate interests of Sabancı Holding (Article 5/2-f KVKK). |
3. Cookie Applications
Regarding the processing of your personal data obtained automatically through the placement of cookies used on the Website on your device, you can find information below about what types of cookies we use for what purposes and how you can manage these cookies.
3.1. What is a Cookie?
A cookie is a small text file that is saved on your computer or mobile device through your browser when you visit a website. Cookies allow a website to work more efficiently, as well as to provide personalized pages in order to provide a faster and more suitable visit experience for your personal needs. Cookies only contain information about your visit history on the internet and do not collect any information about the files stored on your computer or mobile device.
3.2. Types of Cookies Used on the Website, Purposes of Use and Reasons for Legality
Your personal data collected through these cookies are processed within the scope of subparagraph (c) of paragraph (2) of Article 5 of the Law "Provided that it is directly related to the establishment or performance of a contract, it is necessary to process personal data belonging to 51 parties of the contract" or subparagraph (f) "Provided that it does not harm the fundamental rights and freedoms of the person concerned, it is mandatory to process data for the legitimate interests of the data controller".
3.3. Cookie Type, Purpose, Type and Storage Period
Cookie Type | Purpose of the Cookie | Cookie Type | Cookie Storage Period |
| Mandatory Cookies | Mandatory Cookies are cookies that are necessary for the operation of the Website and are used compulsorily in order to fulfill an information society service (log-in) you have requested. They are actively placed when the page is entered. | First Party Cookies | They are stored for the duration of the session. |
| Mandatory Cookies | Mandatory Cookies Cookies that are necessary for the operation of the website and are used compulsorily in order to fulfill an information society service you have requested (form filling). They are actively placed when the page is entered. | First Party Cookies | They are stored during the session. |
| Mandatory Cookies | Mandatory Cookies Cookies that are necessary for the operation of our website and are used compulsorily in order to fulfill an information society service you have requested (remembering privacy preferences). They are actively placed when the page is entered. | The First Party Cookie | The First Party Cookie is stored for 365 days.. |
| Optional Cookies | This cookie is used for the purposes of counting visitors and measuring traffic on the Website. In this way, we are able to measure and improve the performance of our site. Only anonymous statistics are produced and it is not used for cross-tracking your internet browsing between different websites or applications. If you give explicit consent, it is processed and transferred to our external service provider to serve for the aforementioned purposes. | The First Party Cookie | The First Party Cookie is stored for 180 days. |
3.4. How can you control cookies?
You can change your preferences regarding cookies at any time by clicking the icon on the Website. Turn the buttons on the cookie management panel on or off according to your preference and click the "Save settings" button. Refresh the page to make your settings active.
In addition, partial control can also be provided through browser settings. You can access information on the management of cookies in frequently used browsers via the links below:
Your rights under the Personal Data Protection Law
You may exercise your rights under Article 11 of the KVKK.
You may withdraw your explicit consent at any time.
To exercise your rights under Article 11 of the KVKK, you may use one of the methods given below as per the Communique on the Principles and Procedures for the Request to Data Controller (“Communique”):
i By written application to the following application address: H.Ö. Sabancı Holding A.Ş. 4. Levent, 34330 Istanbul/Türkiye, with reference to the Legal and Compliance Department
ii By an e-mail sent to kvkk@sabanci.com from your e-mail address that you have provided to the Company and have been registered in the Company systems or
iii By an e-mail sent from your registered email address to the following registered e-mail address: sabanci@sabanci.hs02.kep.tr
Where the process requires additional costs, we may charge the fees laid down Article 7 of the Communique.
We may update this Privacy Statement in line with the new personal data processing activities that may occur from time to time. We recommend that you visit our website regularly so that you may follow the changes in this Privacy Statement.
Regards,
Data Controller
Hacı Ömer Sabancı Holding Anonim Şirketi
Sabancı Center 34330 4. Levent, İstanbul, Mersis No: 0454001967900016
