1. Identity of data manager
Considering personal data handling relating to service, the data manager is the operator, no data processor is used. Personal data is solely handled by the operator, only its employees can learn about it. Data of service users are stored on the operator’s servers.
2. Information on data management
2.1 Registration and related data management
Using the service in some cases (not completely) is possible without registration (providing identifiable information) but in other cases availability of certain services is subject to registration namely providing personal information. During registration, the operator clearly indicates the mandatory and optional information to be supplied. The mandatory information is required for the safe and legal service provision and use. The mandatory data mainly as follows:
(iii) e-mail address
The user, of course, may refuse to give certain information but in this case the user may not be permitted to use certain services. In terms of registration data service is voluntary, the legal basis of data management is prior consent of the user. In case of service use without registration, the operator records certain data, sometimes considered as personal data, associated with users as provided in 2.2 of this policy.
2.2 Site hits data management
In order to ensure proper management of the service, certain data of the user computers, IP addresses and generating website hits data are logged. These data are in some cases considered as personal data. Statistics is made from log files and these log files will be stored up to maximum one year in the operator’s server. The IP addresses of users are not bound to any other data that make the user’s personality identifiable.
2.3 Placing and objective of ‘Cookies’ and ‘Web beacons’
The operator installs cookies (small size data files not directly related to the user) to the user’s computer for several purposes including data record, user identification, facilitating user’s further hits, increasing the efficiency of service or for the purpose of user targeted advertising or other targeted content delivery, or for market research.
As a result of the use of data files, the operator does not connect these data to the user’s identity data. The so-called session cookies will automatically be deleted by the deadline set in the cookies. Regarding cookies, in the user’s browser the user has the following options:
(i) the user may set up to receive notifications in case the operator intends to place a cookie on the user’s computer.
(ii) the user can forbid to be sent cookies at any time.
It has to be pointed that non-acceptance of cookies will result that certain page or functions may not work properly and it is possible that the user will not be entitled to access to certain information.
Beyond the cookies placed by the operator, third parties can also install data files on the user’s computer. These cases may include if the user visits another website within the service.
For these purposes the operator may insert web beacons (web bug) from a third party. A web beacon is an image embedded in a web page that helps keep track of hits to the sites. This information is also called ‘clickstream data’. These data are necessary to analyze visitor habits in order to improve the quality of the website or in the context of the ads. Functionally, web beacons are similar to cookies, they are used to track the online movement of the users. The main difference between the two is that beacons are not visible on the page. In addition, the user is not allowed to disable download web bugs (unlike cookies) in the browser.
3. The objective of data management
In connection with the service the objective of data processing made by the operator is as follows:
– the efficient provision of services
– identification of registered users
– dispute settlement related to the use of service
– troubleshooting operational problems
– direct marketing. This is made by the operator based on the contribution to data management exclusively during the period or until withdrawal of consent.
4. Data transfer, data process of third parties
In lack of statutory provision the operator is allowed to give over personally identifiable data to a third party with user’s consent. The same refers to data files processed by the operator. Disclosing personal data to third parties may also take place in the following cases:
(i) The username of registered users is public, so is accessible to anyone. Activities made under registered users service can be retrieved by anyone with username. These can be concluded as personal data, however it is possible that the user himself reveals his own personal identity. In addition, users can make their own email addresses and other data available on the website. The disclosure of such information is made solely to the discretion of the user, this way it is considered a voluntary disclosure of personal data. In this case of disclosure users shall be aware that anyone may abuse the published data. The operator is not able to prevent it.
(ii) Regarding suspicious or illegal activities in the service the operator is entitled to send or publish notices or announcements using data up to the individual user.
(iii) Specific parts of the service (such as display advertising, creating hits statistics) may be carried out by contractual partners (subcontractors) if operator decides. In such cases, some user information may be transferred to subcontractors. However, the contractual partner is bound to obligation of confidentiality.
(iv) The operator cooperates with the investigative powers to bodies and the courts in order to detect and sanction offenses (such as fraud, intellectual property rights violation) within the service and comply with the regulatory provisions based on data requests.
It is the sole responsibility of the users to use their personal identifiers and passwords, including all activities associated with the use of identifier and password. It is therefore recommended to keep the fact connected to user identifier and password associated with the username confidential. In case the user discloses this information to a third person, consequently may lose the disposal of option over the data managed by the operator in the service.
6.1 Google Adsense
– Google’s use of the DART cookie enables its partners to serve ads to users based on their hits to this site and/or other sites on the Internet.
6.2 Google Analytics
7. Final provisions
7.1 Exercise of rights, remedies
The users are entitled to request information on use and management of their personal data via email.
Data amendment, deletion
Within the service registered users can amend and improve the data they provide and this function can be reached by logging in their personal account.
In a letter or via email registered users can request to remove their data or cancel their account.
In case the user feels that the operator has violated his right to protection of personal data, he can validate claim before civil court or request the assistance of the data protection commissioner. Legal regulations on the related obligations of data controllers and protection of personal data are included in law LXIII, 1992 on publicity of public data.
The operator excludes all liability regarding stored, published and sent information by the users within the service.