Cookie Policy and Cookie Privacy Notice

Effective Date: 26.08.2026
Last Updated: 26.08.2026
Version: 1

This is an English translation provided for convenience only. In the event of any discrepancy between this translation and the Turkish original, the Turkish text prevails.

1. Introduction

Acting in the capacity of data controller under Law No. 6698 on the Protection of Personal Data (the "KVKK"), SAME YAZILIM VE DANIŞMANLIK ANONİM ŞİRKETİ ("SameUp" or the "Company") has prepared this Cookie Policy and Cookie Privacy Notice (the "Cookie Policy") in order to inform you about the personal data processed through cookies and similar technologies used during your visit to our website at sameup.co (the "Site").

This Cookie Policy explains the types of cookies used on the Site, their purposes, the personal data processed through cookies, the methods and legal bases of collection, the parties to whom such data may be transferred, and how you can manage your cookie preferences.

For detailed information on the Company's personal data processing activities other than cookies, please refer to the "Privacy Notice on the Protection and Processing of Personal Data" published on our Site. This Cookie Policy is not an explicit consent form; your preferences regarding cookies that require explicit consent are obtained separately through the cookie management panel on the Site.

2. What Is a Cookie?

Cookies are small text files stored on your device (computer, tablet, smartphone) through your browser when you visit a website. Cookies are widely used for purposes such as ensuring the proper and secure functioning of the site, remembering your preferences, analysing site usage, and personalising content and advertisements.

Cookies do not by themselves directly reveal your identity; however, in certain cases they may acquire the character of personal data when combined with other data. For this reason, our use of cookies is assessed within the scope of the KVKK.

In addition to cookies, our Site may also use similar technologies such as pixels, web beacons and local storage. The term "cookie" in this policy also covers these technologies.

Through cookies, data such as the following may be processed: IP address, cookie or session identifier, device and browser information, operating system, approximate location information, referring website, pages visited, click and navigation activity, date and duration of visit, traffic source, language and display preferences, and cookie preference records. Such information constitutes personal data to the extent that it can be associated, directly or indirectly, with an identified or identifiable natural person.

Your personal data is obtained in electronic form by wholly or partly automated means, through your device, your browser and the cookies and similar technologies integrated into the Site during your visit.

3. Categories of Cookies

3.1. By Retention Period

Session cookies: valid only for the duration of your browser session and automatically deleted when you close your browser.

Persistent cookies: remain on your device for a set period or until you delete them. They enable your preferences to be remembered on repeat visits.

3.2. By Source

First-party cookies: cookies placed by SameUp directly, or on SameUp's behalf, via the Site's domain.

Third-party cookies: cookies placed by our business partners, such as analytics, advertising and social media services.

3.3. By Purpose

Essential cookies are those necessary for the operation of the Site, ensuring its security, carrying out network and session management, providing a service expressly requested by the user, and recording cookie preferences. Personal data processing carried out through these cookies relies, depending on the specific purpose of the cookie, on the legal grounds of being directly related to the conclusion or performance of a contract under Article 5(2)(c) of the KVKK and/or being necessary for SameUp's legitimate interests, provided that your fundamental rights and freedoms are not harmed, under Article 5(2)(f) of the same paragraph; explicit consent is not required for these cookies. If they are blocked through browser settings, certain sections or functions of the Site may not work as intended.

Preference and functionality cookies are used to remember preferences such as language, region and appearance, and to personalise the user experience. Personal data processed through these cookies, where they are not necessary for the performance of a function expressly requested by the user, is processed on the basis of your explicit consent under Article 5(1) of the KVKK. For preference cookies that are necessary to provide a function expressly requested by the user, Article 5(2)(c) or (f) of the KVKK may be relied upon, depending on the specific processing activity.

Statistics and analytics cookies are used to understand how the Site is used, measure visit and traffic information, identify performance issues and improve the Site. Personal data processed through these cookies is processed on the basis of your explicit consent under Article 5(1) of the KVKK, and these cookies are not activated before you give explicit consent for the relevant category.

Marketing and advertising cookies are used to build profiles based on users' online behaviour and interests, to deliver personalised advertising or content, to limit the frequency of advertisements and to measure the effectiveness of advertising campaigns. Personal data processed through these cookies is processed on the basis of your explicit consent under Article 5(1) of the KVKK, and these cookies are not activated before you give explicit consent for the relevant category.

4. Cookies Used on Our Site

You can access an up-to-date list of all cookies used on our Site — including cookie name, provider, purpose, type, retention period and, where applicable, recipient country — through the cookie declaration table below.

The list above is reviewed and updated whenever the cookies used on the Site change. When an update is made, the last update date and version number shown at the beginning of this text are revised.

5. Transfer of Personal Data

Personal data obtained through cookies may be transferred, limited to the purposes of operating the Site and ensuring its security, carrying out usage and performance analyses, managing user preferences and, where explicit consent has been given, conducting marketing activities, to suppliers providing IT infrastructure, hosting, content delivery network, cookie management, analytics, advertising and marketing services, in accordance with the conditions set out in Article 8 of the KVKK. Information on the providers used and the relevant cookies is shown in the cookie declaration table above.

The legal status of third-party service providers in personal data processing activities may vary — as data processor, independent data controller or joint data controller — depending on the nature of the service provided and the processing activity. SameUp fulfils its obligations under the KVKK in respect of processing activities carried out within the framework of the purposes and means it determines.

Where personal data is transmitted to a data controller or data processor located abroad, or made accessible by such persons, the transfer is carried out in accordance with the conditions set out in Article 9 of the KVKK. Prior to the transfer abroad, in addition to the existence of one of the processing conditions set out in Article 5 of the KVKK for the relevant data, an applicable mechanism is established from among an adequacy decision, appropriate safeguards, or the exceptional transfer situations provided for under the Law.

To request detailed information on the providers to which personal data obtained through cookies is transferred, the recipient countries and the mechanism relied upon for each transfer, you may contact the Company through the channels set out in Section 9.

6. Managing Your Cookie Preferences

Cookies other than essential cookies are not used before you give explicit consent for the relevant category in the cookie management panel displayed on your first visit to the Site. Non-essential cookie categories are not presented as pre-selected in the cookie management panel; you can set your preferences on a category basis and accept or reject all non-essential cookies.

Through the Site: You can change or withdraw the explicit consent you have given at any time using the "Cookie Settings" link made permanently accessible on the Site. The withdrawal of explicit consent does not affect the lawfulness of processing carried out up to the moment of withdrawal. After withdrawing your preference, you may need to delete existing cookies through your browser settings in order to remove the relevant cookies from your device entirely.

Through your browser: You can delete or block cookies through your browser settings, or set your browser to warn you when a cookie is placed.

If you block essential cookies through your browser settings, certain sections or functions of the Site may not work as intended.

7. Your Rights Under the KVKK

Pursuant to Article 11 of the KVKK, in relation to your personal data you have the right to:

• learn whether your personal data is processed,

• request information if it has been processed,

• learn the purpose of processing and whether the data is used in accordance with that purpose,

• know the third parties to whom the data is transferred in Türkiye or abroad,

• request rectification if the data has been processed incompletely or inaccurately,

• request erasure or destruction within the conditions set out in the legislation,

• request that rectification, erasure and destruction be notified to third parties to whom the data has been transferred,

• object to a result to your detriment arising from analysis carried out exclusively by automated systems,

• claim compensation for damage suffered as a result of unlawful processing.

You may submit applications relating to these rights to SameUp using one of the methods described in the "Data Subject Application Form" published on the Site. Detailed information on application channels and the process is also available in the "Privacy Notice on the Protection and Processing of Personal Data".

8. Updates

This Cookie Policy may be updated in line with changes in legislation, decisions of the Personal Data Protection Board, the technologies used, or changes in SameUp's data processing operations. The current text is published on the Site; the effective date and last update date are shown at the beginning of the text. If the purpose or scope of processing based on explicit consent changes, explicit consent is obtained again where the existing consent does not cover the new processing.

9. Contact

For questions and requests regarding our use of cookies, you may contact the Company, acting in the capacity of data controller, through the following channels:

Data controller: SAME YAZILIM VE DANIŞMANLIK ANONİM ŞİRKETİ

Address: Kazlıçeşme Mah. 245. Sk. No: 5 Zeytinburnu / İstanbul, Türkiye

MERSİS / Tax No: 7420983795 (Tax No)

Registered electronic mail (KEP): [email protected]

E-mail: [email protected]