Coşku Varlıkay

İÇİNDEKİLER

  • 1. Kapsam
  • 2. Hakkınızda Hangi Kişisel Verilere Sahibiz
  • 3. Kişisel Bilgileri Açıklama Zorunluluğu Yoktur
  • 4. Hangi Kişisel Verileri Topluyoruz
  • 5. Kişisel Verilerin İşlenmesinin Hukuki Dayanağı ve Gerekçeleri
  • 6. Kişisel Verilerin Üçüncü Taraflara Aktarılması
  • 7. Üçüncü Taraflara Ait Çerezler ve Hizmetler
  • 8. Kişisel Verilerin Saklanması
  • 9. Uluslararası Transferler
  • 10. Kişisel Verilerin Güvenliği
  • 11. Üçüncü Taraf Web Sitelerine Köprü Bağlantıları
  • 12. Bu Politikada Yapılacak Değişiklikler
  • 13. Haklarınız

Gizlilik Politikası

Son güncelleme: 09.06.2026

We (also referred to as "We", "Us", or "Our") are committed to protecting your Personal Data and privacy. This Privacy Policy explains how we collect and store the information you provide through the Coşku Varlıkay website (the "Website").

We want you to be in a position to make informed decisions about how your Personal Data is used and processed. We rely on a range of methods and procedures to keep you informed. Where we determine that you require specific details, we will provide them at a date and time convenient to you. We are glad to answer any questions you may have regarding limitations imposed by law.

By using our Website, you confirm that you have read and accepted this Privacy Policy. For any questions, contact us at: support@cosku-warlikay.com

1. Kapsam

1.1 This policy explains the types of Personal Data the Company collects about individuals, how it processes that data, how it shares the data with third parties, how it secures its processing operations, and related matters.

1.2 This Policy covers information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified directly, or indirectly by combining additional information that we hold or can access.

1.3 Bu Politika, "işleme" işlemini Kişisel Verilerin kullanılmasını veya toplanmasını gerektiren bir süreç olarak tanımlar. Buna Kişisel Verilerin yönetimi, yapılandırılması ve saklanması dahildir.

1.4 Our Services are intended for general audiences and are not designed for use by anyone under the age of 18. We do not knowingly request or collect information from anyone under 18, nor do we knowingly permit such individuals to use our Services. If we learn that we have collected any information from a child, we will delete it as soon as possible.

2. Hakkınızda Hangi Kişisel Verilere Sahibiz

2.1 We collect your Personal Data when you access the Services and channels or visit our website. In certain cases, we may request your Personal Data directly.

2.2 In other cases, we collect your Personal Data by analyzing how you use our Services or service channels, or by obtaining your information from our third-party business partners.

3. Kişisel Bilgileri Açıklama Zorunluluğu Yoktur

3.1 You are not required to provide us with any Personal Data. However, withholding such information may prevent us from delivering our Services or granting you access to the website.

4. Hangi Kişisel Verileri Topluyoruz

4.1 This includes information about your record of online activity, along with traffic data such as:

  • IP adresi
  • Erişim tarihi ve erişim saati
  • Kullandığınız dil
  • Yazılım çökme kayıtları
  • Kullanılan tarayıcı türü
  • Kullandığınız cihaza ilişkin bilgiler

4.2 The information we collect is not private in nature and cannot be used to identify you.

4.3 Personal Data we collect from you: any personal data you choose to provide to Us when you use Us to connect to a third party's online trading platform.

4.4 Personal information you provide directly to third-party platforms to facilitate transactions: This includes your full name, address, phone number, and email address.

5. Kişisel Verilerin İşlenmesinin Hukuki Dayanağı ve Gerekçeleri

5.1 Your Personal Data is processed by the company for the purposes described in this section and in accordance with the applicable legal grounds.

5.2 The Company may not use your Personal Data without a lawful basis. The legal grounds on which the Company may process your Personal Data are as follows:

  • You have consented to the processing of your personal data for one or more purposes. This applies when you submit your personal data to us through the Website so that we may transfer it to a third-party trading platform.
  • The Company or a third party may process data to serve their legitimate interests. For example, such processing may be necessary to improve our Services or to defend against legal claims.
  • İşleme, yasal bir yükümlülüğü yerine getirmelidir.

5.3 To learn more about the processing activities necessary to protect legitimate interests, contact us by email.

5.4 Below are the reasons we may use the information you provide, along with the legal bases for doing so:

Kapsam

Yasal Dayanak

1. With your consent, we may request Personal Data from you to share with third-party companies in order to provide access to digital trading.
Should you make such a request, we may collect Personal Data from you to forward to third-party companies.

Kişisel Verilerinizin bir veya birden fazla amaçla işlenmesine onay verdiniz.

2. To respond to your requests, questions, or concerns
Personal Data is necessary to help us answer questions you may have about the Services.

Şirketin meşru menfaatleri veya bir üçüncü tarafın menfaatleri işlenmesi gerekmektedir.

3. Personal Data is processed to fulfil legal obligations or to meet administrative, judicial, or legal requirements.

Yasal yükümlülüklere uyumu sağlamak için işleme yapılması gereklidir.

4. To improve our Services
We may use Personal Data to improve our Services. This includes, among other things, the crash or error reports we collect in connection with the Services.

Şirketin meşru menfaatlerinin veya üçüncü bir tarafın menfaatlerinin işlenmesi gerekmektedir.

5. Dolandırıcılığı ve Hizmetlerimizin kötüye kullanımını önlemek için.

Şirketin meşru menfaatlerinin veya üçüncü bir tarafın menfaatlerinin işlenmesi gerekmektedir.

6. Carrying out and managing operations aligned with the needs of our Services
These activities include back-office functions, business development, strategic decision-making, audit mechanisms, and similar processes.

Şirketin meşru menfaatlerinin veya bir üçüncü tarafın menfaatlerinin işlenmesi gerekmektedir.

7. To carry out analyses such as statistical analysis
We use various analytical techniques, including statistical ones, to make decisions on different matters.

Şirketin meşru menfaatlerinin veya bir üçüncü tarafın menfaatlerinin işlenmesi gerekmektedir.

8. To protect our assets, rights, and interests, and those of third parties
We may process Personal Data to protect our rights, interests, and assets, or those of third parties, in accordance with applicable laws, regulations, or contracts and any terms, conditions, or policies.

Şirketin meşru menfaatleri veya bir üçüncü tarafın menfaatlerinin işlenmesi gerekmektedir.

6. Kişisel Verilerin Üçüncü Taraflara Aktarılması

6.1 The Company may also share Personal Data, IP address information, and user experience analytics with third party companies that provide services to us, such as hosting and storage providers.

6.2 You may also request that we share certain of your Personal Data with third-party trading platforms. In such cases, we will transfer the Personal Data you have provided to those third-party trading platforms. The use of your Personal Data will then be governed by the privacy policies of those platforms. Your Personal Data may be shared with more than one trading platform.

6.3 The Company may share Personal Data with relevant organizations or business partners. This may provide the Company with the resources needed to develop and improve the products and services offered to its customers.

6.4 Where necessary to protect the rights or assets of third parties, the Company may share Personal Data with regulatory, local, or other official authorities.

6.5 In addition, if such a transaction takes place (including the transfer or sale of assets belonging to the Company or any company within the group), or as part of a merger, restructuring, consolidation, or bankruptcy of the Company or any business within the group, we may share Personal Data relating to you with potential investors or buyers, or with institutions that provide credit to the Company or any company within the group.

7. Üçüncü Taraflara Ait Çerezler ve Hizmetler

7.1 Our website may use third-party services, such as advertising providers or analytics companies. These companies may also use cookies or other technologies.

7.2 Cookies are small text files placed on your device each time you visit or access the website. They collect information about your preferences and browsing habits to improve user experience, track your settings, and personalize products and services that may interest you. Cookies are also used for statistical and analytical purposes.

7.3 Some of the cookies we use are session cookies. These are downloaded to your device temporarily and remain there only until you close your browser. Others are persistent cookies, which stay on your device for a period of time after you close your browser. Persistent cookies help the Website recognize you as a returning user and support users coming back to the site.

Çerez türü

Çerezler kesinlikle gereklidir

Kapsam

These cookies are necessary for you to access the features you request and navigate our website. They are used to deliver the information, products, and services you ask of us.
They enable your device to download and stream data, allowing you to browse the website, use its features, and return to pages you have visited before.

Ek Bilgiler

Cookies collect Personal Data such as your username and last login date to confirm that you are signed in to the site. These cookies are deleted when you close your web browser (session Cookies).

Çerez türü

İşlevsellik Çerezleri

Kapsam

Cookies allow us to recognize you each time you visit our site and to remember your preferences.

Ek Bilgiler

Geçerlilik tarihine kadar saklanır ve tarayıcı kapatıldıktan sonra dahi korunur.

Çerez türü

Performans için çerezler

Kapsam

Cookies collect statistical data on the site's performance and help us improve it. They also enable us to carry out analytics on our website.

Ek Bilgiler

Çerezler, kimliği belirli veya belirlenebilir bir gerçek kişiyle ilişkilendirilemeyen anonim veriler saklar. Bazı çerezler tarayıcınızı kapattığınızda silinir; diğerlerinin ise süresiz geçerliliği vardır.

7.4 Blocking or removing cookies. To block or remove cookies, adjust your browser settings. The links below will help you do this in several of the most widely used browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

7.5 If you choose to do so, please note that certain features and functions of the Website may not work as expected.

Çevrimiçi İzleme Bildirimi: Bu hizmet şu anda izlememe sinyallerini desteklememektedir.

8. Kişisel Verilerin Saklanması

8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing Personal Data described in this Policy, or for longer periods where permitted by applicable laws, regulations, policies, and valid orders.

8.2 We will share your information with third-party trading platforms for a period of 12 months. If you consent, we will continue sharing your data for an additional 12 months.

8.3 We regularly review the Personal Data we hold to confirm it is still required.

9. Uluslararası Transferler

9.1 Your personal data may be transferred to other countries, meaning it could be sent to a third country or to international organisations. The Company takes all necessary measures to protect the Personal Data you provide and to ensure that data users can assert their rights and access effective legal remedies.

These protections and security measures are available to anyone residing within the EEA (European Economic Area):

  • Pursuant to Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 ("GDPR"), transfer to a third country or international organisation that the EU Commission has determined provides an adequate level of protection for the Personal Data transferred to it.
  • The transfer is carried out under Article 46(2)(a), pursuant to a legally binding and enforceable agreement between public authorities or bodies.
  • The transfer is carried out in accordance with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR.

9.3 The Company can provide information about the security measures it applies to protect your Personal Data transferred to third countries or international organizations. Send an email to: support@cosku-warlikay.com

10. Kişisel Verilerin Güvenliği

10.1 We have implemented appropriate organizational and technical measures to protect Personal Data. These measures are designed to prevent the accidental or unlawful destruction, loss, or alteration of Personal Data.

10.2 We cannot guarantee or warrant that the security of your Personal Data will be protected without fault. Nor can we be held liable for any non-material, incidental, or indirect damages arising from the use or disclosure of Personal Data. This includes, but is not limited to, Personal Data disclosed through transmission errors, unauthorized access by a third party, or any other cause beyond our control.

10.3 In the event of legal obligations or other requirements beyond our control, we may need to provide your Personal Data to third parties such as public authorities. In such cases, we cannot control the security provided to your Personal Data by those third parties.

10.4 Personal Data cannot be transmitted over the web with complete security. The Company cannot guarantee the security of any Personal Data you send to Us via the internet.

11. Üçüncü Taraf Web Sitelerine Köprü Bağlantıları

11.1 The website contains links to third-party sites and applications that are not under the Company's control. We are not responsible for the collection or processing of Personal Data by these sites or applications. This Policy does not apply to any activities carried out through them.

11.2 Before accessing any third-party website or application, we recommend reviewing its privacy policy before you decide to access or use it, as well as before providing your Personal Data.

12. Bu Politikada Yapılacak Değişiklikler

12.1 We may update this Policy at any time. If we make changes, we will notify you by publishing the updated Policy on our website.

12.2 Where we make material changes to this Policy, we will notify you through methods we consider appropriate and post a notice on our website.

12.3 Unless expressly stated otherwise, any changes take effect upon publication of the revised Policy.

13. Haklarınız

13.1 You have the right to ask us to confirm the accuracy of the Personal Data we hold about you, to correct any errors, and to delete any Personal Data we no longer need. You may also limit the scope of how your personal data is processed.

13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you provide regarding your Personal Data. To exercise your rights, you may submit a request by emailing the address below.

13.3 Right of access The Company can confirm whether Personal Data about you is being processed. If it is, you may access that Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. If you request it, the data will be made available electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would harm another person's rights or freedoms, the Company may refuse to fulfil it or limit the extent to which it does so.

13.4 Right to rectification The Company has the right to correct inaccurate Personal Data. Taking the purpose of processing into account, you have the right to request the completion of incomplete Personal Data concerning you.

13.5 Right to Erasure This right applies where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw your consent and there is no other legal basis for processing; (c) you object, on grounds relating to your particular situation, at any time to the processing of Personal Data concerning you that is based on legitimate interests pursued by Us or a third party; (e) the Personal Data has been unlawfully processed; or (f) the Personal Data must be erased to comply with a legal obligation to which the company is subject. This right does not apply where processing is necessary (a) to comply with a legal obligation that requires processing under European Union law or Member State law; or (b) for the establishment, exercise, or defence of legal claims.

13.6 Restrictions on processing If you have concerns about the accuracy of your Personal Data, you may ask the Company to restrict the processing of your Personal Data. Where you request such a restriction, your Personal Data may only be retained with your consent, or for the establishment, exercise, or defense of legal claims, for the protection of another natural person's rights, or for reasons of substantial public interest within the European Union or a Member State.

13.7 Right to data portability Where processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the legal right to review the Personal Data you have provided to the Company. Where technically feasible, you have the right to request that your Personal Data be transferred directly from the Company to another controller. Your rights under the right to erasure are not affected by exercising your right to data portability. The right to data portability does not interfere with the rights or freedoms of any other person.

13.8 Right to object You have the right to object at any time to any use of your Personal Data that relies on legitimate interests pursued by the Company or a third party. This right is not limited to profiling based on those legitimate interests. Where we can demonstrate compelling legitimate grounds for processing your Personal Data, we may continue processing unless you show that your rights, freedoms, or interests, or the exercise, establishment, or defence of legal claims, override those grounds. In the case of direct marketing, you have the right to object at any time to the processing of your Personal Data.

13.9 Right to withdraw consent You may withdraw your consent to our processing of your Personal Data at any time. This does not affect the lawfulness of any processing carried out on the basis of your consent before its withdrawal. You have the right to lodge a complaint with your supervisory authority. Within the European Union, you may raise an objection with a supervisory authority established by a Member State to protect the fundamental rights of individuals in relation to the processing of Personal Data. As detailed in this Section 13, the laws of the European Union and Member States may limit your rights regarding your Personal Data.

13.10 We will provide the information you request under your rights set out in Section 13 of this agreement within one month of receiving your request. Depending on the nature and number of requests, this period may be extended by up to two further months where necessary. We will notify you of any such extension, along with the reasons for it, within one month of receiving your request.

13.11 Sürece ve Yasanın 13. maddesine aykırı olmadığı sürece, 13. madde kapsamındaki haklarınız uyarınca talep ettiğiniz bilgiler ücretsiz olarak sağlanır. Talebin haksız veya aşırı olması, özellikle tekrarlanması halinde, bilgilerin sağlanması veya işlemin yürütülmesine ilişkin idari masrafları karşılamak üzere makul bir ücret talep edebilir ya da işlemi gerçekleştirmeyebiliriz.

13.12 If we have doubts about the identity of the individual making the request, we may ask that person to provide reasonable means of identifying themselves.

Bu Gizlilik Politikası, Kullanım Koşulları ve Risk Bildirimi ile birlikte okunmalıdır.

Coşku Varlıkay 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@cosku-warlikay.com