We take your privacy seriously. This Privacy Policy explains what personal information we collect and how we use it. We encourage you to read this policy thoroughly. To make it easier, we’ve broken it up into sections and longer sections have a heading and summary.
The policy: This privacy policy is for this website; www.path.com.tr , www.pathdevelop.com and served by Bay Plaza İçerenköy Çayıryolu Sok. No:5 34752 Ataşehir / Istanbul Turkey, and governs the privacy of its users who choose to use it. It explains how we comply with the GDPR (General Data Protection Regulation), the DPA (Data Protection Act) [pre GDPR enforcement] and the PECR (Privacy and Electronic Communications Regulations).
This policy will explain areas of this website that may affect your privacy and personal details, how we process, collect, manage and store those details and how your rights under the GDPR, DPA & PECR are adhered to. Additionally, it will explain the use of cookies or software, and the download of any documents, files or software made available to you (if any) on this website. Further explanations may be provided for specific pages or features of this website in order to help you understand how we, this website and its third parties (if any) interact with you and your computer/device in order to serve it to you. Our contact information is provided at the bottom of this page if you have any questions.
This policy sets out the different areas where user privacy is concerned and outlines the obligations & requirements of the users, the website and website owners. Furthermore, the way this website processes, stores and protects user data and information will also be detailed within this policy.
2a. Your personal data – what is it?
Personal data relates to a living individual who can be identified from that data. Identification can be by the information alone or in conjunction with any other information in the data controller’s possession or likely to come into such possession. The processing of personal data is governed by [the General Data Protection Regulation 2016/679 (the “GDPR”)1].
2b. Who are we?
Path is the data controller (contact details at the bottom of this page). This means it decides how your personal data is processed and for what purposes.
2c. How do we process your personal data?
Path complies with its obligations under the GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
2d. We use your personal data for the following purposes:
2e. What is the legal basis for processing your personal data?
These fall under either GDPR Article 6 or Article 9 – dealt with separately below.
GDPR Article 6 Processing
GDPR Article 9 Processing
2f. Sharing your personal data
Your personal data will be treated as strictly confidential. We do not sell our clients’ or this websites’ users’ private personal information.
We share information about you in the limited circumstances spelt out below and with appropriate safeguards on your privacy.
2g. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes:
If we do not do business with you for a period of 4 consecutive years, we will archive your data and if no further business relationship for another 6 years, we will notify you of the possible deletion of your data.
2h. Your rights and your personal data
Unless subject to an exemption [under the GDPR], you have the following rights with respect to your personal data:
2i. Automated Decision Making
No automated decisions are being carried out.
2j. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Protection Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
This website and its owners take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience.
This website uses cookies – small text files that are placed on your machine to help the website provide a better user experience. In general, cookies are used to retain user preferences, store information about the user’s interactions and usage of the website and provide anonymised tracking data to third party applications like Google Analytics and Google Ads. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser.
Where applicable, this website uses a cookie control system allowing the user on their first visit to the website to agree to the use of cookies on their computer/device. This complies with legislation requirements for websites to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer/device.
Users are advised that if they wish to deny the use and saving of cookies from this website onto their computer hard drive/device they should take necessary steps within their web browser security settings to disable/block all cookies from this website and its external serving vendors.
To allow us to keep track of traffic to our website we use cookies. The cookies tell us if you have previously visited our website so we can get more accurate figures for Returning Vs New Visitors. The software used for this is Google Analytics. Google Analytics uses cookies to track visitor usage. The software will save a cookie to your computer/device hard drive in order to track and monitor your engagement and usage of the website but does not store, save or collect personal data. For further information you can read Google’s privacy policy here: https://www.google.com/privacy.html
Other cookies may be stored to your computer/device hard drive by external vendors when this website uses referral programs, sponsored links or adverts such as Google Ads. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
We may also set cookies during your visit to our website to be used for remarketing purposes i.e. to show you Path products and services based on what you appear to be interested in. This means that you may see Path adverts and content on other websites. The cookies will enable us to monitor whether you see adverts, click on them and access our website as a result.
Any downloadable documents, files or media made available on this website are provided to users at their own risk. While all precautions have been undertaken to ensure only genuine downloads are available users are advised to verify their authenticity using third party anti-virus software or similar applications. We accept no responsibility for third party downloads and downloads provided by external third-party websites and advise users to verify their authenticity using third party anti-virus software or similar applications.
Users contacting this website and/or its owners do so at their own discretion and provide any such personal details requested at their own risk. Your personal information is kept private and stored securely, as detailed in the General Data Protection Regulation. Every effort has been made to ensure a safe and secure form to email submission process but advise users using such form to email processes that they do so at their own risk.
The website of Path contains information that enables a quick electronic contact to Path which also includes a general address of electronic mail (e-mail address). If you contact Path by e-mail or via the online contact form, the personal data transmitted by the data subject are automatically stored. Your personal information is kept private and stored securely until a time it is no longer required or has no use.
6a. Online Contact Form
We request information from you in our online contact form only so that we may answer you. To respond to your enquiry effectively we ask for your name, email address and other personal details that need to be supplied for the services or the advice you may require. Such personal data transmitted on a voluntary basis by you to Path are stored for the purpose of contacting you. This personal data will never be sold to third parties and you may request that we delete this data at any time.
The online website form has a code embedded from Google Tag Manager. You can read Google’s privacy policy on Tag Manager here: https://www.google.com/analytics/tag-manager/use-policy This code enables Path to see from where a person has arrived on the website when the online form is submitted. The purpose is to see which of Path’ online marketing activities are working best. For example, if a user arrives, for example, from clicking on Google Ads we will have information that this advertisement is performing for us.
6b. Chat Software
Our website contains chat software to enable visitors to communicate with us live online, or offline by submitting a name and email address. When users use this chat software, we may collect some or all the following information: your email address, first name, last name, location, and any other information you willingly choose to provide to us. You should limit provided information that is only necessary to answer your questions. This personal data will never be sold to third parties and you may request that we delete this data at any time.
We operate an email newsletter mailing list programme, used to inform subscribers about products, services and/or news we supply/publish. Users can subscribe through an online automated process where they have given their explicit permission. Subscriber personal details are collected, processed, managed and stored in accordance with the regulations named in point #1 ‘The policy’ above. Subscribers can unsubscribe at any time as detailed in the footer of sent marketing messages. The type and content of marketing messages subscribers receive are clearly outlined at the point of subscription.
Email marketing messages may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored subscriber data. Based on the embedded tracking pixel, Path may see if and when an e-mail was opened by a subscriber, and which links in the e-mail were clicked on. This allows a statistical analysis of the success or failure of individual email newsletters.
Our email marketing service provider is MailChimp. Read their privacy policy
MailChimp Corporate Office Address is The Rocket Science Group, LLC, 675 Ponce De Leon Ave. NE 5000 Atlanta, GA 30308, United States.
The email newsletter is sent to those who have subscribed through the opt-in procedure, and to those based on our legitimate interests in line with the Information Commissioner’s Office guidance on B2B marketing. Subscribers are at any time entitled to revoke the declaration of consent and anyone receiving the newsletter based on our legitimate interests has the right to opt-out at any time. Each email newsletter Path sends contains an unsubscribe link through which you may easily opt out of receiving future email newsletters from us. If you do not wish to receive email newsletters from Path, simply click the unsubscribe link and follow the instructions to unsubscribe your e-mail address or to change your preferences.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us at the address at the bottom of this page. We will promptly correct any information found to be incorrect.
Although we only look to include quality, safe and relevant external links, users are advised to adopt a policy of caution before clicking any external web links mentioned throughout this website. (External links are clickable text/banner/image links to other websites)
Path is not responsible for the privacy practices or the content of any third-party websites. The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Customers and visitors who link to other third-party websites from this website should check the privacy and security policy statements of such third-party websites to understand the policies and practices of such third-party websites as we are not responsible for those policies and practices. Customers and visitors who access a linked site may be disclosing their private information to the owner of such third-party websites. It is your responsibility to keep such information private and confidential.
Users should, therefore, note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.
Communication, engagement and actions taken through external social media platforms that this website participates on are subject to the terms and conditions as well as the privacy policies held with each social media platform respectively.
Users are advised to use social media platforms wisely and communicate/engage upon them with due care and caution in regard to their own privacy and personal details. This website will never ask for personal or sensitive information through social media platforms and we encourage users wishing to discuss sensitive details to contact us by telephone or email.
This website uses social sharing buttons that help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.
9a. Social Media Widgets
This website includes social media features, such as the Twitter ‘Follow’ widget/button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the company providing it:
Twitter: Twitter is a service of Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, UNITED STATES. If you live outside the United States, the data controller responsible for your information is Twitter International Company, an Irish company with its registered office at One Cumberland Place, Fenian Street, Dublin 2 D02 AX07 Ireland.
Each time the Path website receives an access request equipped with a Twitter component, the component prompts your browser to download an image of this from Twitter. Through this process, Twitter is informed which page of our website is being visited. We have no control over the data that Twitter collects in this process, or over the extent of the data that Twitter collects. Further information may be obtained from the Twitter data privacy policy here: https://twitter.com/privacy
You may change your Twitter data privacy settings in your account settings here: https://twitter.com/account/settings
Facebook: Facebook is a service of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, UNITED STATES.
If you wish to prevent the transfer to and storage of data by Facebook about you and your interaction with our website, you must first log out of Facebook before visiting the Path website. The data protection policies of Facebook provide additional information about the collection and use of data by Facebook, your rights in this regard, and the options available to you for protecting your privacy: https://www.facebook.com/about/privacy/ An overview of Facebook plugins is available here: https://developers.facebook.com/docs/plugins/
LinkedIn: LinkedIn is a service of LinkedIn Corporation, LinkedIn Headquarters 2029 Stierlin Ct. Ste. 200 Mountain View, CA 9404, UNITED STATES.
We have no control over the data that LinkedIn collects thereby, nor over the extent of the data that LinkedIn collects. Nor do we have any knowledge of the content of data transferred to LinkedIn. Details on data collection by LinkedIn as well as your rights in this regard and your browser setting options may be obtained from the LinkedIn data privacy policy, which may be accessed here: https://www.linkedin.com/legal/privacy-policy
There are tools freely available on the market that can be installed to block social media plug-ins with add-ons from being added to commonly used browsers.
You use social sharing buttons at your own discretion and accept that doing so may publish content to your social media profile feed or page.
9b. Shortened Social Media Links
This website and its owners through their social media platform accounts may share web links to relevant web pages. Shortened URL’s; URL shortening is a technique used on the web to shorten URL’s (Uniform Resource Locators) to something substantially shorter. This technique is especially used in social media and looks similar to this example: https://bit.ly/2uWRkmO. Users should take caution before clicking on shortened URL links and verify their authenticity before proceeding.
Users are advised to take caution and good judgement before clicking any shortened URLs published on social media platforms by this website and its owners. Despite the best efforts to ensure only genuine URLs are published many social media platforms are prone to spam and hacking and therefore this website and its owners cannot be held liable for any damages or implications caused by visiting any shortened links.
Path has integrated Google Analytics on this website. Google Analytics is a web analytics service. Web analytics is the collection, gathering, and analysis of data about the behaviour of visitors to websites. A web analysis service collects data about the website from which a person has come (the referrer), which sub-pages were visited, or how often and for what duration a sub-page was viewed. Web analytics are mainly used for the optimisation of a website and in order to carry out a cost-benefit analysis of digital advertising.
Google Analytics is a service and component of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
The purpose of the Google Analytics component is to analyse the traffic on our website. Google uses the collected data and information to evaluate the use of our website and to provide online reports, which show the activities on our websites, and to provide other services concerning the use of our Internet site for us.
Google Analytics places a cookie on the information technology system of the data subject. The definition of cookies is explained above. With the setting of the cookie, Google is enabled to analyse the use of our website. With each call-up to one of the individual pages of this website, which is operated by Path and into which a Google Analytics component was integrated, the Internet browser on the information technology system of the data subject (you) will automatically submit data through the Google Analytics component for the purpose of online advertising and the settlement of commissions to Google. During the course of this technical procedure, the enterprise, Google gains knowledge of personal information, such as the IP address of the data subject, which serves Google to understand the origin of visitors and clicks, and subsequently create commission settlements.
The cookie is used to store personal information, such as the access time, the location from which the access was made, and the frequency of visits of our website by the data subject. With each visit to our Internet site, such personal data, including the IP address of the Internet access used by the data subject, will be transmitted to Google in the United States of America. These personal data are stored by Google in the United States of America. Google may pass these personal data collected through the technical procedure to third parties.
The data subject may prevent the setting of cookies through our website at any time by means of a corresponding adjustment of the web browser used and thus permanently deny the setting of cookies. Such an adjustment to the browser used would also prevent Google Analytics from setting a cookie on the information technology system of the data subject. In addition, cookies already in use by Google Analytics may be deleted at any time via a web browser or other software programs.
In addition, the data subject has the possibility of objecting to a collection of data that are generated by Google Analytics, which is related to the use of this website, as well as the processing of this data by Google and the chance to preclude any such. For this purpose, the data subject must download a browser add-on under the link https://tools.google.com/dlpage/gaoptout and install it. This browser add-on tells Google Analytics through a JavaScript, that any data and information about the visits of Internet pages may not be transmitted to Google Analytics. The installation of the browser add-on is considered an objection by Google. If the information technology system of the data subject is later deleted, formatted, or newly installed, then the data subject must reinstall the browser add-ons to disable Google Analytics. If the browser add-on was uninstalled by the data subject or any other person who is attributable to their sphere of competence, or is disabled, it is possible to execute the reinstallation or reactivation of the browser add-ons.
Further information and the applicable data protection provisions of Google may be retrieved under https://www.google.com/intl/en/policies/privacy/ and under https://www.google.com/analytics/terms/us.html Google Analytics is further explained under the following link https://www.google.com/analytics/
Additionally, we also track and record calls, forms and Live Chats that come through our website through WhatsApp Business.
Their privacy policy is as follows https://www.whatsapp.com/legal/?lang=en
The information you provide will be kept confidential and will be used only to support your customer relationship with Path Inc; information will not be sold to any outside organisation or third party without your prior consent.
We hope that you are satisfied with the measures we employ to help ensure we secure your personal privacy and that you remain confident about the safety of your online information.
You have choices available when it comes to information about you:
We and this website complies with the DPA (Data Protection Act 1998) and already complies with the GDPR (General Data Protection Regulation) which comes into effect from May 2018. We will update this policy accordingly after the completion of the UK’s exit from the European Union.
Privacy laws and practices are constantly developing. Our policies and procedures are therefore under continual review. Any changes we may make to our privacy policy in the future will be posted on this page.
We may update this privacy policy to reflect changes to our information practices. Your continued use of this website and/or services constitutes consideration and your acceptance to any such changes. We encourage you to periodically review this page for the latest information on our privacy practices.