Legal Notice

Effective Date: 22.05.2025

This privacy policy explains how personal data of users who visit and use the Behem Stratejik Yönetim ve Dış Ticaret A. Ş. website (www.behem.com.tr) is collected, used, shared, and protected. As Behem Stratejik Yönetim ve Dış Ticaret A. Ş., we prioritize the privacy and security of your personal data.

1. Personal Data Collected

When you visit our Website or interact with us, we may collect the following types of personal data:

• Identity Information: Your first name, last name, company (if specified), position (if specified).

• Contact Information: Your email address, phone number (if specified).

• Technical Information: Your IP address, browser type and version, time zone and location settings, browser plug-in types and versions, operating system and platform, and other device identifiers.

• Usage Information: Information about how you use our Website, the pages you visit, the links you click, downloaded documents, and other usage data.

• Marketing and Communication Information: Whether you are subscribed to our newsletters or other marketing communications and your communication preferences.

• Other Information: Any other information you voluntarily provide to us via contact forms, emails, or other means.

2. Methods of Personal Data Collection

We may collect your personal data through the following methods:

• Direct Interactions: When you fill out contact forms on our Website, subscribe to our newsletter, or contact us via email or phone.

• Automated Technologies or Interactions: When you use our Website, we may automatically collect your technical and usage information through cookies, server logs, and other similar technologies. You can find more information about cookies in our Cookie Policy.

• Third Parties: We may receive personal data to a limited extent through analytics providers (e.g., Google Analytics), social media platforms (if integrated), and other third-party service providers.

3. Purposes of Using Personal Data

We may use the personal data we collect for the following purposes:

• To manage and operate our Website, ensure its security, and improve it.

• To provide you with the information, services, or materials you request (e.g., information about our consulting services, brochures, case studies).

• To respond to your questions, requests, and feedback.

• If you have subscribed to our newsletters or other marketing communications, to send you relevant updates and information.

• To analyze usage trends and measure and improve the performance of our Website.

• To manage and improve our customer relationships.

• To fulfill our legal obligations.

4. Sharing of Personal Data

We may share your personal data with the following third parties:

• Service Providers: Third-party companies that provide services such as website hosting, data analysis, email sending, customer relationship management (CRM), and other services. We have necessary agreements with these companies to ensure they keep your data confidential and use it only to provide services to us.

• Business Partners (If Any): Our business partners with whom we conduct joint projects or offer services together. In this case, we may share limited information necessary for the provision of relevant services.

• Legal Authorities: When we are required to provide information to authorized authorities to comply with applicable laws, regulations, or legal processes.

• Behem Stratejik Yönetim ve Dış Ticaret A. Ş. Group Companies (If Any): Limited information may be shared with other companies within our group for the purpose of managing internal processes and providing services.

5. International Transfer of Personal Data

The personal data we collect may be transferred to and processed in countries outside of Turkey. Data protection laws in these countries may differ from the laws in your country. When transferring your personal data internationally, we take necessary measures in accordance with applicable legal regulations to ensure that your data is processed securely.

6. Retention of Personal Data

We retain your personal data for the period necessary for our collection purposes (an average of 3 years). The retention period may vary depending on the type of data, the purpose of processing, and our legal obligations. Data collected through contact forms is generally retained for a reasonable period for the fulfillment and follow-up of the request. Data collected for newsletter subscriptions is retained as long as your subscription continues. When no longer necessary, we securely delete or anonymize your personal data.

7. Your Rights as a Personal Data Subject

Under applicable data protection laws, you may have the following rights:

• Right to Access: The right to learn whether your personal data is being processed, and if so, to request access to the data.

• Right to Rectification: The right to request the correction of your inaccurate or incomplete personal data.

• Right to Erasure ("Right to Be Forgotten"): The right to request the deletion of your personal data in certain circumstances.

• Right to Restriction of Processing: The right to request the restriction of the processing of your personal data in certain circumstances.

• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and the right to transfer it to another data controller.

• Right to Object: The right to object to the processing of your personal data for certain purposes (e.g., direct marketing).

• Right to Withdraw Consent: The right to withdraw your consent to our processing of your personal data at any time (in cases where consent is required).

To exercise these rights, please contact us using the contact information below. We will evaluate your request and respond in accordance with applicable laws.

8. Data Security

We take reasonable technical and organizational measures to ensure the security of your personal data. These measures aim to prevent unauthorized access, use, disclosure, alteration, or destruction. These measures may include firewalls, encryption technologies, and access controls. However, please note that no data transmission over the internet is completely secure.

9. Cookies and Other Tracking Technologies

Our Website may use cookies and other tracking technologies. These technologies can be used to enhance website functionality, analyze usage patterns, and improve the user experience. For more information on cookies, please refer to our Cookie Policy, which will also be provided separately on our Website.

10. Links to Other Websites

Our Website may contain links to other websites that may be of interest to you. We are not responsible for the privacy practices of these websites. We recommend that you read the privacy policies of the websites we link to.

11. Changes to the Privacy Policy

We may update this privacy policy from time to time to adapt to changes in our business processes or legal regulations. In the event of any significant changes, we will publish a prominent notice on our Website or inform you through other appropriate methods. Therefore, we recommend that you regularly review this policy to stay informed of updates. The latest update date will be indicated at the bottom of this page.

12. Contact

If you have any questions, concerns, or requests regarding this privacy policy or the processing of your personal data, please contact us using the contact information below:

Behem Stratejik Yönetim ve Dış Ticaret A. Ş.

Esentepe Mah. Inonu Cad. Kartalkule No: 147-70 Kartal - Istanbul - Turkey Tel: 0216 353 45 35

E-mail: sales@behem.com.tr