Karub Enerji Sanayi ve Ticaret A.Ş.
Effective Date: [•]
Last Updated: [•]
Version: 1.0
Covered Domain: karub.com (including all language versions and subdomains)
As Karub Enerji Sanayi ve Ticaret A.Ş. ("Karub", the "Company" or "we"), we attach the utmost importance to the privacy and the protection of the personal data of the persons ("User", "you") who visit our website at karub.com (the "Website").
This Cookie Policy (the "Policy") has been prepared to explain which data are collected on our Website through cookies and similar tracking technologies, for which purposes and on which legal grounds, with whom such data are shared, for how long they are retained, and how Users can manage their preferences in this respect.
This Policy has been drawn up on the basis of the provisions of;
This Policy is an integral part and supplement of our Company's Policy on the Processing and Protection of Personal Data and the Privacy Notice for Website Visitors. In matters not regulated in this Policy, the aforementioned texts and the provisions of the relevant legislation shall apply.
Pursuant to Article 3 of the KVKK, the details of the organisation acting as the data controller are as follows:
| Corporate Name | Karub Enerji Sanayi ve Ticaret A.Ş. |
| Address (Istanbul Office) | Galataport J4 Blok, Beyoğlu / Istanbul |
| R&D Office | Yıldız Technical University Campus, Sarıyer / Istanbul |
| Telephone | 444 55 72 |
| info@karub.com | |
| Registered E-mail (KEP) | [•] |
| MERSİS No | [•] |
| Trade Registry No | [•] |
| VERBİS Registration No | [•] (where a registration obligation exists) |
| Website | https://karub.com |
Although our Company has offices in London (United Kingdom) and Dubai (UAE), the data controller in respect of visits made from Türkiye is Karub Enerji Sanayi ve Ticaret A.Ş.
| Term | Description |
|---|---|
| Explicit Consent | Consent relating to a specific subject, based on being informed and expressed by free will. |
| Cookie | A small text file, generally consisting of letters and numbers, placed on the User's terminal device (computer, tablet, smartphone, etc.) when a website is visited. |
| Terminal Device | The electronic device through which the User accesses the Website. |
| Data Subject | The natural person whose personal data are processed (User/Visitor). |
| Personal Data | Any information relating to an identified or identifiable natural person. |
| Processing of Personal Data | Any operation performed on personal data. |
| Data Controller | The person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. |
| Data Processor | The person who processes personal data on behalf of the data controller, based on the authority granted by the data controller. |
| First-Party Cookie | A cookie placed directly by the visited domain (karub.com). |
| Third-Party Cookie | A cookie placed by a domain other than the domain being visited. |
Cookies are small text files saved on your terminal device via your browser when you visit the Website. As a rule, cookies can be read on your subsequent visits by the domain that placed them.
Cookies typically contain the following elements: the name of the cookie, the domain that placed the cookie, the validity period of the cookie and a randomly generated unique value (ID).
Cookies are used for purposes such as ensuring the technical operation of the site, maintaining session security, remembering your language and display preferences, measuring site performance and understanding visitor behaviour.
Cookies on their own do not directly reveal the User's identity (name, surname, etc.). However, since data collected through cookies, such as IP address, device identifier and browser information, may — on their own or in combination with other data — make the data subject identifiable, they constitute personal data within the meaning of the KVKK and are processed within the framework of the principles set out in this Policy.
The following technologies, which do not technically fall within the definition of a cookie but serve a similar function, may also be used on our Website. In this Policy, the term "cookie" is used so as to also cover the technologies below:
| Technology | Description |
|---|---|
| Local Storage / Session Storage | Storage areas on the browser used to store data, with higher capacity than cookies and not automatically sent to the server. |
| Pixel Tag / Web Beacon | A small, usually invisible image embedded in a page or e-mail; it detects whether the page or message has been viewed. |
| Software Development Kit (SDK) | Software components that collect device and usage data, in a manner similar to cookies, within mobile applications or embedded content. |
| Scripts / Tag Managers | Pieces of code that run on the page to provide measurement and functionality. |
| Device Fingerprinting | Recognition of the device by combining parameters such as browser, operating system, screen resolution and installed fonts. |
| Embedded Content (iFrame) | Placement of third-party content, such as maps, video players and social media feeds, within the site. |
| Type | Description |
|---|---|
| Session Cookies | Valid for the duration of the User's visit to the Website; they are automatically deleted when the browser is closed. They are temporary and are generally used for technical necessities. |
| Persistent Cookies | They remain on the terminal device until deleted by the User or until the validity period defined on the cookie expires. They are used for remembering preferences, measurement and advertising purposes. |
| Type | Description |
|---|---|
| First-Party Cookies | Cookies placed directly by karub.com and readable only by our Company. |
| Third-Party Cookies | Cookies placed by service providers other than our Company (analytics, advertising, content delivery network, social media platforms, etc.). In respect of these cookies, the privacy and cookie policies of the relevant third party also apply. |
a) Strictly Necessary / Technical Cookies
These are cookies that are strictly necessary for the Website to function and for the services requested by the User to be provided. They perform functions such as load balancing, session management, security verification (CSRF/bot protection), language selection and saving cookie preferences.
These cookies cannot be disabled; if they are disabled, the basic functions of the Website will not work. Pursuant to the Guideline on Cookie Practices of the Turkish Personal Data Protection Authority, explicit consent is not required for these cookies.
b) Functionality and Preference Cookies
They provide a more personalised experience by remembering the User's preferences such as language, region, display format and video player settings. Although not mandatory, they provide ease of use. These cookies are subject to explicit consent.
c) Performance and Analytics Cookies
They enable the measurement and improvement of the Website's performance by collecting information such as which pages are visited and how often, the time spent on the page, error messages and traffic sources, in an aggregated and anonymised form. These cookies are subject to explicit consent.
d) Targeting and Advertising Cookies
They are used to display advertisements relevant to the User's interests, to prevent the same advertisement from being shown repeatedly, and to measure the effectiveness of advertising campaigns. They are generally placed by third-party advertising networks and may enable cross-site tracking. These cookies are subject to explicit consent.
e) Social Media Cookies
These are cookies placed via sharing buttons or embedded content belonging to social media platforms. They enable content to be shared and measurement to be performed on the relevant platforms. These cookies are subject to explicit consent.
The table below contains information on the cookies used on our Website. The table is updated in line with changes made to the technical infrastructure; the current and complete list can always be viewed via the Cookie Preference Panel on our site.
| Cookie Name | Party | Type | Purpose | Duration |
|---|---|---|---|---|
| [session_id] | First party | Session | Maintaining the user session and preserving session integrity when navigating between pages | Session duration |
| [csrf_token] | First party | Session | Security verification against cross-site request forgery (CSRF) | Session duration |
| [lang / locale] | First party | Persistent | Remembering the language version selected by the User (TR/EN/RU/TK/ZH/FR/AR) | 12 months |
| [cookie_consent] | First party | Persistent | Storing the User's cookie preferences and consent record | 12 months |
| [load_balancer] | First party | Session | Server load balancing and connection continuity | Session duration |
| Cookie Name | Party | Type | Purpose | Duration |
|---|---|---|---|---|
| [video_pref] | First party | Persistent | Remembering sound/playback preferences for on-site video content | 6 months |
| [ui_pref] | First party | Persistent | Remembering display and interface preferences | 6 months |
| Cookie Name | Party | Type | Purpose | Duration |
|---|---|---|---|---|
| _ga | Third party (Google Analytics) | Persistent | Distinguishing visitors and generating site usage statistics | 24 months |
| _ga_[ID] | Third party (Google Analytics 4) | Persistent | Monitoring session state | 24 months |
| _gid | Third party (Google Analytics) | Persistent | Distinguishing visitors | 24 hours |
| Cookie Name | Party | Type | Purpose | Duration |
|---|---|---|---|---|
| li_sugr, bcookie, lidc | Third party (LinkedIn) | Persistent | Redirection to our corporate LinkedIn page, campaign measurement and browser identification | 3 – 24 months |
| [advertising_cookie] | Third party | Persistent | Interest-based advertising and conversion measurement | Up to 12 months |
Note: The cookie names shown in square brackets in the tables above and the third-party service providers may vary depending on the technical configuration of the Website. Where the relevant technology is not used on our site, that row does not apply.
The following personal data may be processed through cookies:
| Data Category | Example Data |
|---|---|
| Transaction Security Information | IP address, session ID, cookie ID, security logs, access date and time |
| Device and Connection Information | Device type, operating system and version, browser type and version, screen resolution, language setting, internet service provider |
| Usage/Traffic Information | Pages visited, time spent on the page, click and navigation movements, source of entry to the site (referrer), exit page, error records |
| Location Information | Approximate location (at city/country level) based on IP address |
| Marketing Information | Advertising ID, interest segments, campaign interaction and conversion data |
| Preference Information | Selected language version, interface preferences, cookie consent record |
No special categories of personal data are collected through cookies.
| Cookie Category | Processing Purposes | Legal Ground (KVKK) |
|---|---|---|
| Strictly Necessary / Technical | Operation of the Website, session management, conduct of information security processes, provision of the requested service, prevention of fraud and misuse, fulfilment of legal obligations | Art. 5/2-(c) being directly related to the establishment or performance of a contract, Art. 5/2-(ç) fulfilment of a legal obligation, Art. 5/2-(f) legitimate interest of the data controller |
| Functionality / Preference | Remembering user preferences, improving the user experience | Art. 5/1 explicit consent |
| Performance / Analytics | Measuring site performance, statistical analysis, development of content and infrastructure | Art. 5/1 explicit consent |
| Targeting / Advertising | Conduct of advertising, campaign and promotion processes, interest-based marketing, measurement of campaign effectiveness | Art. 5/1 explicit consent |
| Social Media | Social media integration, content sharing, measurement of brand awareness | Art. 5/1 explicit consent |
All cookies other than strictly necessary cookies are placed only in line with the explicit consent given by the User via the Cookie Preference Panel. Unless explicit consent is given, these cookies are not placed on your device; withholding consent does not prevent you from benefiting from the essential functions of the Website.
You can view, change or withdraw your cookie preferences at any time via the "Cookie Settings" link located at the bottom of every page of our Website.
You can also manage, delete or block cookies via your browser settings:
| Browser | Path |
|---|---|
| Google Chrome | Settings → Privacy and security → Third-party cookies / Site settings |
| Mozilla Firefox | Settings → Privacy & Security → Cookies and Site Data |
| Safari (macOS) | Safari → Settings → Privacy → Manage cookies and website data |
| Safari (iOS/iPadOS) | Settings → Safari → Privacy & Security |
| Microsoft Edge | Settings → Cookies and site permissions |
| Opera | Settings → Privacy & security → Cookies and other site data |
| Android (Chrome) | Chrome → Settings → Site settings → Cookies |
You can also use your browser's incognito/private browsing mode to ensure that cookies are automatically deleted at the end of the session.
There is not yet a uniform industry standard regarding browsers' "Do Not Track (DNT)" and "Global Privacy Control (GPC)" signals. On our Website, cookie preferences are managed primarily through the Cookie Preference Panel, and the extent to which these signals are supported may be updated in line with developments in our technical infrastructure.
Data obtained through cookies may be transferred — solely for the purposes set out in this Policy and within the framework of Article 8 of the KVKK — to our information technology service providers, hosting and infrastructure providers, agencies and consultants, audit and legal service providers; and, within the scope of the fulfilment of our legal obligations, to authorised public institutions and organisations.
Some analytics, advertising and content delivery services used on our Website are provided by service providers whose servers are located abroad. In this context, your personal data may be transferred abroad within the framework of Article 9 of the KVKK:
In addition, as our Company's headquarters are located in the United Kingdom and one of its offices in the United Arab Emirates, limited transfers may take place within the scope of intra-group reporting and IT infrastructure management. These transfers are also carried out within the legal framework set out above.
In respect of cookies subject to explicit consent, the transfer of the relevant data abroad is additionally covered by the information provided within the scope of the consent obtained via the Cookie Preference Panel.
In respect of third-party cookies, the relevant service provider may qualify as an independent data controller within the framework of the purposes and means it determines itself. Our Company has limited control over the data processing activities of these parties.
We therefore recommend that you review the privacy and cookie policies of the relevant service providers:
| Service Provider | Policy Link |
|---|---|
| Google (Analytics / Ads) | https://policies.google.com/technologies/cookies |
| https://www.linkedin.com/legal/cookie-policy | |
| [Other service providers] | [•] |
Cookies are stored on your terminal device for the validity periods specified in the relevant tables. Personal data collected through cookies are retained for the period necessary for the purpose for which they are processed and, in any event, taking into account the periods envisaged in our Company's Personal Data Retention and Destruction Policy and the limitation periods regulated in the relevant legislation.
Upon expiry of the retention period or where the ground for processing ceases to exist, personal data are deleted, destroyed or anonymised ex officio or upon the request of the data subject, in accordance with the provisions of the Regulation on the Deletion, Destruction or Anonymisation of Personal Data.
Where the retention of traffic and access records for a specific period is mandatory under the relevant legislation, such records continue to be retained for the prescribed period.
In order to prevent the unlawful processing of, and unlawful access to, personal data obtained through cookies and to ensure the safekeeping of such data, our Company takes all necessary technical and administrative measures to ensure the appropriate level of security pursuant to Article 12 of the KVKK. These measures include encrypted data transmission via SSL/TLS, access authorisation matrices, firewalls and intrusion detection systems, keeping of log records, confidentiality undertakings and regular awareness trainings.
Pursuant to Article 11 of the KVKK, as a data subject, by applying to our Company you have the right to;
You may submit your requests, in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller, through one of the following methods:
Your application must contain your name and surname, Turkish ID number (for foreigners: nationality, passport number or identity number), residential or workplace address for notification purposes, e-mail address for notification (if any), telephone and fax numbers, and the subject matter of the request, together with any information and documents relating to the matter.
Your requests are concluded free of charge as soon as possible and in any event within thirty (30) days at the latest, depending on their nature. Where the transaction additionally requires a cost, the fee in the tariff determined by the Board may be charged.
If your application is rejected, if the response given is found insufficient, or if no response is given within the prescribed period, you may lodge a complaint with the Personal Data Protection Board within thirty (30) days from the date on which you learn of the response and, in any event, within sixty (60) days from the date of application.
Our Website does not offer services directed at children and does not knowingly collect personal data belonging to children. If it is determined that personal data belonging to a child have been collected without parental/guardian consent, the relevant data are deleted without delay. If you have identified such a situation, please contact us at info@karub.com.
Our Website is published in Turkish, English, Russian, Turkmen, Chinese, French and Arabic. In respect of Users accessing from the European Economic Area and the United Kingdom, to the extent that the relevant legislation (GDPR / UK GDPR and ePrivacy rules) is applicable, cookies other than strictly necessary cookies are likewise placed only on the basis of explicit consent obtained in advance. These Users may exercise their rights of access, rectification, erasure, restriction of processing, data portability and objection through the contact channels set out above.
Our Company reserves the right to unilaterally amend this Policy in line with legislative changes, developments in the technical infrastructure or changes in the scope of services.
The updated Policy enters into force on the date it is published on the Website. In the event of material changes, Users are additionally informed via the Website and, to the extent necessary, their consent is obtained anew. The current version of the Policy can always be accessed at https://karub.com/tr.
In the event of any conflict between the Turkish text of the Policy and its translations into other languages, the Turkish text shall prevail.
For any questions, opinions and requests regarding our cookie practices:
Karub Enerji Sanayi ve Ticaret A.Ş.
Galataport J4 Blok, Beyoğlu / Istanbul
Tel: 444 55 72
E-mail: info@karub.com
This Cookie Policy was last updated on [•].