SONAY YATIRIM ANONİM ŞİRKETİ
WEBSITE COOKIE POLICY AND DISCLOSURE NOTICE
1. Purpose and Scope
This Website Cookie Policy and Disclosure Notice (the "Cookie Policy") has been prepared in order to inform the visitors, users and third parties (the "Data Subject") of the website at https://sonayyatirim.com/tr (the "Website"), operated by Sonay Yatırım Anonim Şirketi (the "Company") in its capacity as data controller, about the collection, processing and transfer of personal data through cookies and similar tracking technologies used in the operation of the Website, and about their rights of choice regarding such technologies, in full compliance with Article 10 of the Personal Data Protection Law No. 6698 ("KVKK") and the principles of the Guidelines on Cookie Practices published by the Personal Data Protection Board.
This Policy aims to ensure the transparency of the cookie practices carried out through the Website and to safeguard the privacy of visitors' personal data.
2. What is a Cookie?
Cookies are small text files consisting of letters and numbers that are saved by the website server, through browsers (Google Chrome, Safari, Mozilla Firefox, Microsoft Edge, etc.), onto users' computers, smartphones, tablets or other terminal devices when a website is visited.
Cookies cause no damage to visitors' terminal devices and contain no viruses or malware. These text files enable the website to operate more efficiently, the services offered to be personalised according to user preferences, session security to be ensured, visit statistics to be produced and the performance of the website to be improved.
3. Purposes of Using Cookies
Cookies are generally used on the Website for the following corporate and technical purposes:
Ensuring the uninterrupted operation of the Website's basic functions and information society services,
Ensuring the session security of visitors and detecting and preventing cyber security risks,
Improving the performance, speed and browsing quality of the Website,
Optimising the user experience by remembering users' on-site preferences (language selection, regional settings, etc.),
Improving the architecture of the Website by compiling analytical data such as visitor numbers, page view frequency, time spent on the site and click activity in anonymised or aggregate form.
4. Types of Cookies Used on the Website and Their Legal Grounds
The cookies used on the Website are classified as follows according to their duration, the party placing them and their purpose:
4.1. Cookies by Duration
Session cookies (temporary cookies): Temporary cookies that are valid for the duration of the user's visit to the Website and are automatically deleted when the browser is closed. They are used to ensure the continuity and security of the session.
Persistent cookies: Cookies that remain on the user's terminal device after the browser is closed, for a predetermined retention period or until manually deleted by the user. They allow the user's preferences to be remembered on a subsequent visit.
4.2. Cookies by Party
First-party cookies: Cookies placed on the terminal device through the Website servers operated directly by Sonay Yatırım Anonim Şirketi and read only by the Company.
Third-party cookies: Cookies placed and managed through the Website by external service providers (for example analytics providers or external infrastructure partners).
4.3. Cookies by Purpose and Their Legal Grounds under Article 5 of the KVKK
Strictly necessary cookies: Cookies that are essential for the Website to operate properly, for basic pages to be displayed, for security to be established and for a requested information society service to be provided. Disabling these cookies causes some sections of the Website to stop working. Legal ground: Article 5/2(f) of the KVKK — "processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject" — and Article 5/2(c) of the KVKK — "processing of personal data of the parties to a contract is necessary, provided that it is directly related to the conclusion or performance of that contract". Explicit consent is not required for these cookies.
Functional / preference cookies: Cookies that allow the Website to be presented in a more personalised way by remembering users' past preferences (in particular language selection and interface preferences). Legal ground: Article 5/2(f) legitimate interest where preferences are set directly by an active choice of the user; and "explicit consent" under Article 5/1 of the KVKK for functionality that goes beyond the user's request.
Performance and analytics cookies: Cookies that optimise the operation of the Website by analysing how visitors use it, which pages are visited, error reports and traffic volume. These cookies may be first-party or third-party. Legal ground: In line with the principles of the Personal Data Protection Board, cookies used for statistical and analytical purposes are, as a rule, operated on the basis of the data subject's "explicit consent" under Article 5/1 of the KVKK.
Targeting and advertising/marketing cookies: Cookies used to present content and advertisements according to visitors' interests and to measure the effectiveness of marketing campaigns. Legal status: The use of cookies for targeting and behavioural advertising is not a priority on the corporate website of Sonay Yatırım Anonim Şirketi; should such cookies be activated, they will be based solely on the data subject's "explicit consent" under Article 5/1 of the KVKK.
4.4. Table of Cookies Used on the Website
| Cookie Name | Category | Purpose | Provider / Party | Retention Period | Legal Ground |
|---|---|---|---|---|---|
| PHPSESSID / SESSION_ID | Strictly necessary | Starting the session and ensuring browsing continuity and session security. | First party (sonayyatirim.com) | Session (deleted when the browser is closed) | KVKK Art. 5/2(f) legitimate interest |
| __cf_bm / Security_Token | Strictly necessary | Blocking malicious bot traffic and ensuring the cyber security of the Website. | First party / infrastructure provider | 30 minutes | KVKK Art. 5/2(f) legitimate interest |
| cookie_consent | Functional | Recording and remembering the visitor's cookie preferences and consent. | First party (sonayyatirim.com) | 1 year | KVKK Art. 5/2(f) legitimate interest |
| site_lang | Functional | Remembering the visitor's preferred language setting (Turkish/English) on the next visit. | First party (sonayyatirim.com) | 6 months | KVKK Art. 5/2(f) legitimate interest |
| _ga | Analytics | Used by Google Analytics to distinguish unique users and produce aggregate visit statistics. | Third party (Google LLC) | 2 years | KVKK Art. 5/1 explicit consent |
| _ga_* | Analytics | Used to maintain session state and measure page interactions anonymously. | Third party (Google LLC) | 1 year | KVKK Art. 5/1 explicit consent |
5. Transfer of Personal Data Obtained Through Cookies
Personal data processed through cookies may be transferred to:
Information technology suppliers and technical service providers that operate the Website's technical infrastructure, hosting and security services,
Third-party providers of analytics services, where the data subject has given explicit consent,
Authorised public institutions and judicial/administrative authorities, in order to fulfil a legal obligation or resolve a legal dispute,
in accordance with the data processing conditions and rules set out in Articles 8 and 9 of the KVKK. Data processed through the cookies of third-party analytics providers resident abroad are transferred abroad only where the data subject has given explicit consent.
6. Managing Cookie Preferences and Disabling Cookies
Data subjects may accept or reject the use of non-essential cookies (analytics, functional or marketing) at any time, or update their preferences, through the cookie information panel that appears on their first visit to the Website.
In addition, visitors have the right to block or restrict the use of cookies, or to delete cookies already stored on their devices, by changing their browser settings. The steps for managing cookies in each browser are set out below:
Google Chrome: Click the three dots in the top right corner of your browser. Adjust your preferences under Settings > Privacy and security > Third-party cookies.
Mozilla Firefox: Click the menu button in the top right corner of your browser. Configure your settings under Settings > Privacy & Security > Cookies and Site Data.
Apple Safari: Go to Preferences > Privacy and use the "Block all cookies" option or manage website data.
Microsoft Edge: Click the three dots in the top right corner of your browser. Follow Settings > Cookies and site permissions > Manage and delete cookies and site data.
Important notice: If strictly necessary cookies are completely disabled through browser settings, some sections of the Website may partially or entirely lose functionality, browsing performance may decline and the information society services offered may not be used properly.
7. Rights of the Data Subject under Article 11 of the KVKK and How to Apply
All visitors whose personal data are processed through cookies have the right, pursuant to Article 11 of the KVKK, to apply to the Company:
To learn whether their personal data are processed,
To request information if their personal data have been processed,
To learn the purpose of processing and whether the data are used in accordance with that purpose,
To know the third parties in Türkiye or abroad to whom the personal data are transferred,
To request rectification of personal data where they are processed incompletely or inaccurately,
To request erasure or destruction of personal data within the conditions set out in Article 7 of the KVKK,
To request that rectification, erasure and destruction be notified to the third parties to whom the data have been transferred,
To object to a result arising against them as a consequence of the analysis of the processed data exclusively by automated systems,
To claim compensation where they suffer damage due to the unlawful processing of personal data.
Data subjects may submit their requests regarding these rights, in accordance with the Communiqué on the Principles and Procedures for Applications to the Data Controller:
Physical address: In writing in person, together with documents evidencing identity, or through a notary public, to Funda Sok. No:1 Levent Mah. Beşiktaş / İstanbul,
E-mail: To info@sonayyatirim.com, using the e-mail address registered in the Company's system.
The Company will conclude the requests contained in the application as soon as possible and in any case within thirty (30) days, free of charge as a rule, depending on the nature of the request. However, if the process requires an additional cost, the fee set out in the tariff determined by the Personal Data Protection Board may be charged.
8. Effectiveness and Updates
This Cookie Policy enters into force as of the date it is published on the Website. The Company reserves the right to update this Cookie Policy in line with changes in legislation, decisions of the Personal Data Protection Board or technical infrastructure updates to the Website. Updates take effect as of the moment they are announced on the Website.
This English text is a courtesy translation. In the event of any inconsistency, the Turkish version shall prevail.
Sonay Yatırım Anonim Şirketi
14 September 2026