1. General provisions

This policy of personal data processing is compiled in accordance with the requirements of the Federal Law dated July 27, 2006 No. 152-FZ "On Personal Data" (hereinafter - the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by Etraa International (hereinafter - the Operator).
1.1. The Operator sets compliance with human and citizen rights and freedoms in the processing of their personal data, including protection of the rights to privacy, personal and family secrets, as its main goal and condition in carrying out its activities.
1.2. This Operator's policy on personal data processing (hereinafter - the Policy) applies to all information that the Operator may receive about visitors of the website https://etraa.com.tr/en.

1. Key terms used in the Policy

2.1. Automated personal data processing - processing of personal data using computer technology.
2.2. Blocking of personal data - temporary suspension of the processing of personal data (except in cases where processing is necessary for clarifying personal data).
2.3. Website - a set of graphic and informational materials, as well as programs for computers and databases that provide their availability on the Internet at the network address https://etraa.com.tr/en.
2.4. Personal data information system - a set of personal data contained in databases, and ensuring their data processing using information technology and technical means.
2.5. Depersonalization of personal data - actions that make it impossible to determine the belonging of personal data to a specific User or another personal data subject without using additional information.
2.6. personal data processing - any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, refinement (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator - a state body, municipal body, legal or natural person, acting independently or jointly with other persons, organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://etraa.com.tr/en.
2.9. Personal data permitted for distribution by the personal data subject - personal data for which an unlimited number of persons have access, provided by the personal data subject by giving consent to the processing of personal data allowed for distribution in the manner prescribed by the Personal Data Law (hereinafter - personal data permitted for distribution).
2.10. User - any visitor to the website https://etraa.com.tr/en.
2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain group of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite number of persons (transmission of personal data) or acquainting an unlimited circle of persons with personal data, including disclosure of personal data in the media, placement in information and telecommunications networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign government body, foreign individual, or foreign legal entity.
2.14. Destruction of personal data - any actions resulting in the irretrievable destruction of personal data with the impossibility of further restoring the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.
3.Basic rights and obligations of the Operator
3.1. The Operator has the right to:

• receive from the personal data subject reliable information and/or documents containing personal data;
• in case of revocation by the personal data subject of consent to the processing of personal data, as well as the submission of a request to terminate the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject in cases provided by the Personal Data Law;
• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and normative legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the personal data subject with information upon his/her request regarding the processing of his/her personal data;
• organize the processing of personal data in accordance with the current legislation of the Russian Federation;
• respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the necessary information to the authorized body for the protection of the rights of personal data subjects upon request of this body within 10 days from the date of receipt of such request;
• publish or otherwise provide unlimited access to this Policy on the processing of personal data;
• take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other illegal actions with respect to personal data;
• terminate the transfer (distribution, provision, access) of personal data, terminate the processing and destroy personal data in the manner and cases provided by the Personal Data Law;
• fulfill other obligations provided by the Personal Data Law.

4.Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:

• receive information regarding the processing of their personal data, with the exception of cases provided by federal laws. The information is provided to the personal data subject in an accessible form and should not contain personal data related to other personal data subjects, except in cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;
• request from the operator the clarification, blocking or destruction of his/her personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained or unnecessary for the stated processing purposes, as well as take measures provided by law to protect their rights;
• set a condition for obtaining prior consent for the processing of their personal data for the purposes of promoting goods, works, and services on the market;
• revoke consent to the processing of personal data, as well as submit a request to terminate the processing of personal data, as well as appeal to the authorized body for the protection of the rights of personal data subjects or in court for unlawful actions or inaction of the Operator regarding the processing of their personal data;
• exercise other rights provided by the legislation of the Russian Federation.

4.2. Personal data subjects are obliged to:

• provide the operator with reliable information about themselves;
• inform the operator about the clarification (updating, changing) of their personal data.

4.3. Persons who have provided false information about themselves to the operator, or information about another personal data subject without his/her consent, are responsible in accordance with the legislation of the Russian Federation.

1. Principles of personal data processing

5.1. Personal data processing is carried out on a legal and fair basis.
5.2. Personal data processing is limited to achieving specific, pre-defined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. The combination of databases containing personal data, the processing of which is carried out for incompatible purposes, is not permitted.
5.4. Only personal data that is relevant to the purposes of its processing may be processed.
5.5. The content and scope of processed personal data correspond to the stated purposes of processing. The excessive processing of personal data in relation to the stated purposes of its processing is not allowed.
5.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing personal data are ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows for the identification of the personal data subject for no longer than required to achieve the purposes of processing personal data, unless the federal law or a contract, party to which, beneficiary or guarantor of which is the personal data subject, provide for a different term for storing personal data. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case of the loss of the need to achieve these purposes, unless otherwise provided by federal law.
6.Purposes of personal data processing:

• Purpose of processing: informing the User by sending emails
• Personal data: full name, phone numbers
• Legal basis: Federal Law "On Information, Information Technologies and Protection of Information" dated July 27, 2006 No. 149-FZ
• Types of personal data processing: collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data.

7.Conditions for processing personal data
7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of his/her personal data.
7.2. Processing of personal data is necessary to achieve the purposes provided by an international treaty of the Russian Federation or the law, to perform functions, powers, and duties assigned to the operator by the legislation of the Russian Federation.
7.3. Processing of personal data is necessary for the administration of justice, the execution of a court decision, a decision of another authority or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Processing of personal data is necessary for the performance of a contract, party to which, beneficiary or guarantor of which is the personal data subject, as well as for the conclusion of a contract at the initiative of the personal data subject or a contract for which the personal data subject will act as a beneficiary or guarantor.
7.5. Processing of personal data is necessary to protect the rights and legitimate interests of the operator or third parties, or to achieve socially significant goals on the condition that the rights and freedoms of the personal data subject are not violated.
7.6. Personal data that is accessible to an unlimited circle of persons, granted by the personal data subject or at his/her request (hereinafter - publicly available personal data) is processed.
7.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed.
8.Procedures for collecting, storing, transferring, and other types of personal data processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation on personal data protection.
8.1. The Operator ensures the security of personal data, takes all possible measures to prevent unauthorized access to personal data.
8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the performance of current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party to perform obligations under a civil law contract.
8.3. In case of any inaccuracies in personal data, the User may update them independently by sending a notification to the Operator's email address info@etraa.com.tr, with the subject line "Update of personal data."
8.4. The processing time of personal data is determined by achieving the purposes for which the personal data was collected, unless otherwise provided by the contract or current legislation.
The User may revoke his/her consent to the processing of personal data at any time by sending a notification to the Operator via email at info@etraa.com.tr with the subject line "Revocation of consent to the processing of personal data."
8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User agreement and Privacy Policy. The personal data subject and/or document holders undertake to be familiar with the specified documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this section.
8.6. The prohibitions established by the personal data subject on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data allowed for distribution, do not apply in cases of personal data processing in the public interest, as defined by Russian legislation.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that allows for the identification of the personal data subject for no longer than required to achieve the purposes of processing personal data, unless the federal law or a contract, party to which, beneficiary or guarantor of which is the personal data subject, provide for a different term for storing personal data.
8.9. The termination of personal data processing may be due to achieving the purposes of processing personal data, expiration of the consent period of the personal data subject, revocation of consent by the personal data subject, or a request to stop processing personal data, as well as the identification of unauthorized processing of personal data.
9.List of actions taken by the Operator with the obtained personal data
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides access), depersonalizes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without them.
10.Cross-border transfer of personal data
10.1. Prior to commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subject rights of its intention to carry out a cross-border transfer of personal data (such notification is sent separately from the notification of intention to process personal data).
10.2. Prior to submitting the above-mentioned notification, the Operator must obtain from foreign government authorities, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned, the necessary information.
11.Confidentiality of personal data
The Operator and other persons who have access to personal data are obliged not to disclose and not to disseminate personal data to third parties without the consent of the personal data subject, unless otherwise provided by federal law.
12.Concluding provisions
12.1. The User can obtain any clarifications on matters related to the processing of his personal data by contacting the Operator via email at info@etraa.com.tr.
12.2. Any changes to the policy on personal data processing by the Operator will be reflected in this document. The policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available online at https://etraa.com.tr/en/policy.