Privacy Policy

This Privacy Policy (“Policy”) describes how Kobil Ventures (“KV”, “we”, “us”, “our” and/or “us”) collects, processes, uses and discloses certain Personal Information (defined below) obtained through our website located at https://kobil.com (including all subdomains, the “Site”). This Policy applies only to information collected through the Site and therefore does not apply to data we collect in other contexts. By visiting our Site and/or using the features/services offered to you on the Site (collectively, the “Service”), you agree to the terms of this Policy.

Our Service is designed to help you. We do not sell or share your personal information with any party except as set forth in this Privacy Policy. We never share your personal information with third parties for their own marketing purposes.

By accessing or using our Service, you declare that you have read, understood and accepted our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.

KV will process your personal data within the personal data processing conditions and purposes specified in the relevant legislation (i) in accordance with the law and good faith, (ii) by maintaining the accuracy and the most up-to-date version of the personal data you share, (iii) for specific, explicit and lawful purposes, (iv) in connection with, limited to and proportionate to the purpose for which they will be processed, (v) within the conditions and purposes stipulated in the relevant legislation or required for the purpose for which they are processed.

Collection of Personal Data, Personal Data Processed and Purpose

1. Collection. We collect personal data from you when you provide it to us directly through the Site. We may also automatically collect certain information from you, your computer, smartphone or other device when you use, access or interact with the Service.

2. Personal Data processed through the Site. We may collect the following personal data about you: (i) identifiers and similar information, such as your name, address, e-mail address, online identifiers or other similar identifiers; (ii) characteristics of classifications protected under applicable law; (iii) commercial information, including your marketing preferences; (iv) Internet or other electronic network activity information, including information about the browser or device you use to access the Site, your IP address and cookie preferences; (v) geolocation information, such as information about your location or the location of your device, (vi) occupational or employment information, such as when a person applies for a job; and (vii) audio, electronic, visual or other similar information, such as when you request assistance with the Site or other matters.

3. Personal information collected through the online platform. If you accept the invitation to become a member of the online community platform within our portfolio, we will collect information related to the creation and maintenance of the platform. This may include information about creating your account (such as your name and email address) and any information you disclose through the platform.

4. Site logs. When you use the Service, we automatically receive and record certain information from your computer (or other device) and browser. This may include data such as your IP address and domain name, the pages you visit while receiving the Service, the date and time of your visit, the files you download, the URLs of websites you visit before and after you go to the Service, your software and hardware specifications (including device IDs), your general geographic location (for example, your city, state or metropolitan area), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and collect information about its online activity.

5. Cookies. We also use cookies for the Service. Cookies are small files stored on your computer by your web browser. A cookie enables the Service to recognize whether you have visited before and may store user preferences and other information. For example, cookies may be used to collect or store information about your use of the Service during your current session and over time (including the pages you view and files you download), your computer's operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website you visited before the Service, and the link you use to leave the Service. If you are concerned about having cookies on your computer, you can set your browser to reject all cookies or to indicate when a cookie is set and allow you to decide whether or not to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Service may not function properly.

6. Third party plugins. The Service may include plug-ins from other companies, including social media companies (for example, a “Like” button). These plug-ins may collect information, such as information about the pages you visit, and share it with the company that created the plug-in, even if you do not click on the plug-in. These third-party plug-ins are subject to the privacy policies and terms of the companies that created them.

7. Third party online tracking. We may also partner with certain third parties to collect, analyze and use some of the Personal Information described in this Policy. For example, we may allow third parties to set cookies or use web beacons on the Service or in email communications from us. This information may be used for various purposes, including online website analytics or interest-based advertising.

8. Aggregated and de-identified information. From time to time, we may also collect and share aggregate or de-identified information about our users, such as by publishing a report on trends in the use of the Site. Such aggregated or de-identified information will not identify you personally.

We use the information we collect for various purposes. These purposes include, for example:

• Providing the Service to you;

• responding to your questions or requests regarding the Service;

• To fulfill the terms of any agreement you have with us;

• Sending you information about the Service and other matters that may be of interest to you, including newsletters, updates or other communications, including promotional emails;

• transmit confirmations, account information, notifications and similar operational communications;

• To improve your user experience and the quality of our products and the Service;

• To comply with corporate governance, audit, reporting, legal and/or regulatory requirements;

• Collect and de-identify information

• Analyze how visitors use the Service, including counting and recognizing visitors to the Service;

• Create new products and the Service; and

• Managing business processes.

• Conducting credit checks and criminal background checks as required;

Transfer of Personal Data

1. Service providers. We may share your personal information with third-party service providers or business partners who help us provide or improve our Service or perform services on our behalf, such as marketing, processing payments, sending mail, providing back office services, or measuring Service traffic. We may aggregate or de-identify information from personally identifying characteristics and then share this aggregated or anonymized information with third parties.

2. Affiliates. We may share with other companies and brands owned or controlled by KV and other companies owned or under common ownership with KV, including our affiliates (i.e., any entity we own or control) or our ultimate holding company (i.e., any entity that owns or controls us) and its affiliates. These companies will use your personal information in the same way we may use it under this Privacy Policy.

3. Investors. We may share information about your company's key personnel with investors and potential investors in our fund.

4. Consultants. We may share personal information with professional advisors such as lawyers, auditors, bankers and insurers as necessary in the course of their professional services to us.

5. Your Explicit Consent. We may share your personal data with third parties for the purposes for which you have given your explicit consent. We may also share with these third parties aggregated or de-identified information that cannot reasonably be used to identify you.

Access to Personal Data from Abroad

1. In line with your explicit consent, KV shares your name, surname, e-mail address and phone number with Google Drive, which is located abroad and whose server and cloud service is received. These shares are based on your explicit consent in accordance with Article 9/1 of KVKK.

2. KV corporate e-mail network runs on Google programs. In this case, all e-mail communication you carry out through the KV workplace e-mail address is stored encrypted on Google's servers abroad. KV will encrypt attachments containing personal data that you send in the e-mail attachment. You can withdraw your explicit consent to the transfer of your personal data abroad at any time. Withdrawal of your consent will not affect the lawfulness of the processing carried out on the basis of your consent prior to such withdrawal.

Protection, Storage Period and Destruction of Personal Data 

1. KV is obliged to take all kinds of physical, technical and administrative measures to ensure an adequate level of security in order to prevent unlawful processing of your personal data, unlawful access to your personal data and to ensure the protection of your personal data and takes these measures to the maximum extent.

2. KV strives to maintain appropriate physical, technical and managerial security for its workplaces and information systems, thus preventing the loss, misuse, unauthorized access, disclosure or alteration of personal data. We protect our website and other systems against loss, destruction, unauthorized access, alteration or disclosure of your personal data by unauthorized persons by taking necessary technical and organizational measures. Although we make every effort to protect your personal data when you submit it, no data transmission over the internet or any public network can be guaranteed to be 100% secure. In case of linking to other applications through the Site, KV does not accept any responsibility for the privacy policies and contents of the applications.

3. KV has prepared separate special information texts (clarification text) for its customers, employees, employee candidates, suppliers and managers. These clarification texts have been delivered to each relevant group of persons or access authorization has been granted.

4. The personal data you have shared with KV through the channels mentioned in the Policy will be processed in accordance with the legislation on the protection of personal data and the periods required by other legislation, in any case, as long as the processing purposes specified in the Policy do not disappear.

Your rights

By applying to our company;

• Learn whether your personal data is being processed,

• Request information if your personal data has been processed,

• Withdraw any consent you have previously given us regarding the use of your personal data,

• To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,

• To know the third parties to whom personal data are transferred domestically or abroad

• To request correction of personal data in case of incomplete or incorrect processing

• Request its deletion or destruction, to be considered within the principles of purpose, duration and legitimacy,

• In case of correction, deletion or destruction of personal data, to request notification of these transactions to third parties to whom personal data are transferred,

• In the event that the processed data is analyzed exclusively through automated systems, to object to this result in the event that a result arises against you,

• In the event that personal data is processed unlawfully and you suffer damage for this reason, you have the right to demand the compensation of the damage.

In this context, you can submit your requests regarding your rights mentioned above to KV by filling out the application form on the Site with information and documents identifying your identity or by creating your own request. Please confirm the current application methods and application content conditions from the legislation beforehand. 

California Consumer Privacy Act (“CCPA”) Disclosure

If you are a California resident, you may have the right to request access to categories or specific pieces of Personal Information KV has collected about you, to request that KV delete or correct your Personal Information, and to opt out of the sale and/or sharing of your Personal Information. Although California residents have the right to opt out of the sale and sharing of personal data, KV does not sell or share Personal Information, where the terms “sell” and “share” are used under the CCPA, to third parties, including but not limited to Personal Information of minors, and we have not sold or shared such Personal Information in the past 12 months. The CCPA prohibits KV from discriminating against you for exercising your applicable CCPA rights. If you wish to exercise any of the rights described in this CCPA disclosure section, please contact us at legal@kobil.com. To respond to a request, you will be required to provide a valid form of identification as a security measure. Depending on the sensitivity of the information in question, we may request additional proof of identity. We will not disclose or delete any information until the identity of the individual has been verified. If an agent makes a request on your behalf, they will need to verify the request by submitting your written authorization and we may still ask you to verify your identity with us before proceeding with the request. We will not fulfill any requests from agents until authorization has been verified. We will keep records of consumer requests made under the CCPA and how we respond to those requests in accordance with the CCPA.

Policy Changes

1. 12.1.Each time you use the Site, you will be subject to the Privacy Policy then in effect and you should review this text each time you visit the Site to ensure that you accept the terms. KV may make changes to the Policy from time to time. The current Policy will be effective as of the moment it is published on the Site.

2. 12.2.If you have any questions regarding this Policy or any problems not addressed herein, please contact KV through the contact channels in this Policy.

Identity of the Data Controller 

Kobil Ventures is the Data Controller in terms of your personal data that you share through the channels described under this section.