---------- Forwarded message ---------
Gönderen: ~MQ~ <mqdc@protonmail.com>
Date: 16 Haz 2022 Per, 13:41
Subject: ASG Site / 2. Privacy Policy
To: edi@edimedya.com <edi@edimedya.com>
Cc: edigentr@gmail.com <edigentr@gmail.com>, ugur akkus <aswarsems@gmail.com>

Our approach to privacy

A&S Global IT Digital Technology Inc is a company registered in the United States with its registered address in Delaware and for purpose of this page will refer company as ("ASGIDTI")  "we," "our," or "us").

A&S Global IT Digital Technology Inc..  is committed to protecting and respecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies.

Who is responsible for the use of your personal information? 

A&S Global IT Digital Technology Inc collects personal information that you voluntarily submit directly to us when you use the ("ASGIDTI") Website, such as the following:

1. If you would like to contact us via the ("ASGIDTI") Website, we’ll need to collect:
   • Your first and last name
   • Your email address
   • Company Name
   • Information you input in the “Nature of enquiry” field
   • Your marketing preferences
   • Information you send us by email, post or over the phone
2. You can optionally volunteer the following information via the ("ASGIDTI") Website “Contact Us” form:
   • Phone Number
   • Information you input in the “Nature of enquiry” field
3. Information you provide to us when you communicate with us, e.g. when you call, email or send us post.

How do we collect your data?

We collect data and process data when you:

• Use the “Contact Us” form.
• Sign up to receive news and updates from us.
• Voluntarily complete a customer survey or provide feedback via email.
• Email us.
• Phone us.
• Write to us. ("ASGIDTI") Website, as well as the legal basis which we rely on to process the personal information and recipients of that personal information.

  How will we use your personal information?

• Use or view the ("ASGIDTI") Website via your browser’s cookies.

If you choose not to provide such personal information, we may not be able to respond to your requests.

The table at Annex 1 below sets out in detail the categories of personal information we collect about you and how we use that information when you use the ("ASGIDTI")

We collect your personal information so that we can:

• Get in touch with you after you’ve asked us to.
• Respond to your enquiries.
• Send you news, updates and other marketing communications that you have signed up to received.
• Improve the ("ASGIDTI") Website, products/services, marketing or customer relationships.
• Recommend products or services which may be of interest to you.
• Understand how you arrived at the ("ASGIDTI") Website.

Information we collect about you automatically

We also automatically collect personal information indirectly about how you access and use the ("ASGIDTI") Website, and information about the device you use to access the ("ASGIDTI") Website when you visit the ("ASGIDTI") Website, read our emails, or otherwise engage with us. We use this information to provide you the features and functionality of the ("ASGIDTI") Website, to monitor and improve the ("ASGIDTI") Website and to develop new products and services. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar tracking technologies.

The table at Annex 2 below sets out in detail the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and recipients of that personal information. For more information on cookies and other tracking technologies we use, please see the section on cookies below.

We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.

We may anonymized and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Website and developing new products and features. We may also share such anonymized and aggregated information with others.

How do we store your personal information?

We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. ("ASGIDTI") securely stores your personal information in our Cloud Storage solution provided by Microsoft.

We process your personal information on any forms you use in the United States. We do not transfer your personal information outside the United States..

If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy.

How long will we store your personal information?

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.

Recipients of personal information

We may share your personal information with the following:

• Service providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.
  We have listed examples of specific service providers that we use in Annexes 1 and 2.
• Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.
• Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Website Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of ("ASGIDTI"), its users or others.

Marketing would like to send you information about products and services of ours that we think you might like.

If you have agreed to receive marketing, you may always opt out at a later date.

You have the right at any time to stop ("ASGIDTI") from contacting you for marketing purposes.

If you no longer wish to be contacted for marketing purposes, please send us an e-mail to support@asglobaldigital.com

What are your data protection rights?

("ASGIDTI") would like to make sure you are fully aware of your data protection rights. Under certain circumstances, you have the following rights under data protection laws in relation to your personal information:

• The right to access – You have the right to obtain access to your personal information along with certain related information..
• The right to rectification – You have the right to request that ("ASGIDTI")correct any information you believe is inaccurate. You also have the right to request ("ASGIDTI") to complete the information you believe is incomplete.

• The right to erasure – You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified..
• The right to restrict processing – You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you..
• The right to object to processing – You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case.  You can object to marketing activities for any reason.
• The right to data portability – You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
• The right to withdraw consent – If you have provided consent for the processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.

If you would like to exercise any of these rights, please contact us at our email:

 
Write to us at: legal@asglobaldigital.com

You also have the right to lodge a complaint to your local data protection authority – further information on how to do this is set out at the end of this Privacy Policy.

What are cookies?

The ("ASGIDTI") Website uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together "cookies") to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse the ("ASGIDTI") Website and also allows us to monitor and analyze how you use and interact with the ("ASGIDTI") Website so that we can continue to improve the ("ASGIDTI") Website. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements.

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit the ("ASGIDTI") Website, we may collect information from you automatically through cookies or similar technology.

Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

For further information, visit allaboutcookies.org.

How do we use cookies?

("ASGIDTI") uses cookies in a range of ways to improve your experience on the ("ASGIDTI") Website, including:

• Keeping you signed in
• Understanding how you use the A&S Global Digital Technology Inc Website

What types of cookies do we use?

There are a number of different types of cookies, however, the (("ASGIDTI") Website uses:

• Strictly necessary cookies. These are cookies that are required for the operation of the("ASGIDTI") Website.
• Functionality – ("ASGIDTI") uses these cookies so that we recognize you on the ("ASGIDTI") Website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising – ("ASGIDTI") uses these cookies to collect information about your visit to the ("ASGIDTI") Website, the content you viewed, the links you followed and information about your browser, device, and your IP address. We may also share this information with third parties who provide a service to us for this purpose.
• Analytical/performance cookies – they allow us to recognize and count the number of visitors and to see how visitors move around the ("ASGIDTI") Website when they are using it. This helps us to improve the way the ("ASGIDTI") Website works, for example, by ensuring that users are finding what they are looking for easily.
• Third party cookies – please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on the ("ASGIDTI") Website. These third parties are responsible for setting out their own cookie and privacy policies.

Please see Annex 3 for more information about the cookies we use on the ("ASGIDTI") Website.

How to manage your cookies

The cookies we use are designed to help you get the most from the ("ASGIDTI") Website but if you do not wish to receive cookies, in most cases, you can set your browser not to accept cookies. However, depending on your mobile device and operating system, you may not be able to delete or block all cookies. Please note that if you choose to refuse all cookies, some of the ("ASGIDTI") Website features may not function as a result.

These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.

• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookies settings in Safari web and  iOS.

If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative's online sources at www.networkadvertising.org. We and our third-party partners may also use cookies and tracking technologies for advertising purposes.

Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

Tracking technologies used in our emails

Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you.

Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display "remote images", "remote content" or "images" by default.

Some browsers also give you the option of downloading and installing extensions that block pixels and other tracking technologies.

Privacy policies of other websites

The ("ASGIDTI") Website may contain links to other websites. Our Privacy Policy applies only to the ("ASGIDTI") Website, so if you click on a link to another website, you should read their privacy policy. We do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

Our policy towards children

The ("ASGIDTI")

 Is directed at persons under 18. We do not knowingly collect or solicit personal information from any persons under the age of 13. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible.  If you believe that we might have any information from a child under 13, please contact us at 

legal@asglobaldigital.com

GDPR Compliances

[A&S Global IT Digital Technology Inc] is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection.  We follow in mission the principals of GDPR:

• Lawfulness, fairness and transparency.
• Purpose limitation.
• Data minimization.
• Accuracy.
• Storage limitation.
• Integrity and confidentiality (security)
• Accountability.

If you have any questions related to our GDPR compliance, please contact our Data Protection Officer or make a Data Subject Access Request.

compliance@asglobaldigital.com

Changes to our Privacy Policy

A&S Global IT Digital Technology Inckeeps its Privacy Policy under regular review and places any updates on this web page so you should review this page periodically.

This Privacy Policy was last updated on October 18th, 2021.

Changes to this Privacy Policy are effective when they are posted on this page.

Notice to you

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the ("ASGIDTI") Website. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.

How to contact us

If you have any questions about ("ASGIDTI") Privacy Policy, the personal information we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at:  legal@asglobaldigital.com