Cookie Policy

MADDE 1 – Purpose, Scope, and Nature of the Policy

1.1. Purpose of the Policy

This DigiPestControl Cookie Policy (“Policy”) has been prepared to provide clear and comprehensible information to visitors and users regarding the cookies and similar technologies used by DigiPestControl.

The Policy specifically aims to explain:

• which types of cookies and similar technologies may be used;
• for which purposes these technologies may be utilized;
• which cookies are strictly necessary for the Service;
• which cookies depend upon user choice;
• first-party and third-party cookies;
• the lifespans of cookies;
• the legal bases applicable where personal data is processed;
• data sharing that may be carried out with third parties;
• circumstances where cross-border data transfers may arise;
• how users can manage their cookie preferences

aims to explain.

1.2. Digital Services Covered by the Policy

This Policy covers, to the extent applicable, the following DigiPestControl digital services:

• the DigiPestControl website;
• the DigiPestControl web application;
• user and customer dashboards;
• registration and subscription pages;
• support and contact pages;
• other DigiPestControl services accessed via an internet browser;
• other DigiPestControl digital environments where cookies or similar storage/access technologies are utilized.

1.3. Mobile Applications and Similar Technologies

In mobile applications, distinct from traditional web browser cookies, device identifiers, in-app storage, SDKs, push notification tokens, and similar technologies may be utilized.

To the extent that these technologies yield functional and data processing effects similar to cookies, they may be described within the scope of this Policy or separately within relevant mobile application privacy disclosures.

Permission and privacy controls offered by mobile device operating systems may additionally apply.

MADDE 2 – Identity of the Data Controller

Seçkiner Teknoloji ve Kimya San. ve Tic. A.Ş. acts as Data Controller / Controller with respect to personal data processing activities conducted via cookies or similar technologies used across its own website and digital services where it determines the purposes and means of processing.

With respect to independent personal data processing activities where third-party service providers determine their own purposes and means, such third parties may additionally act as independent Data Controllers.

MADDE 3 – What Are Cookies and Similar Technologies?

3.1. Cookie

A cookie refers to small data fragments that can be stored on a user's browser or device, or allow access to previously stored information, when a website or online service is visited.

Cookies can be used for diverse purposes, including maintaining user sessions, remembering preferences, ensuring security, measuring performance, or understanding user interactions with the website.

3.2. Similar Technologies

In this Policy, unless the context requires otherwise, the term “cookies” also encompasses the following technologies functionally used for similar purposes:

• local storage;
• session storage;
• web beacon or pixel technologies;
• SDK-based identifiers;
• device or application identifiers;
• tags and similar tracking technologies;
• other technical mechanisms that store information on, or access information from, the user's terminal equipment.

The legal assessment of any technology is based not merely on its technical naming, but on whether it stores or accesses data on the device, whether it processes personal data, and its concrete operational purpose.

MADDE 4 – Basic Classification of Cookies

Cookies utilized or potentially utilized by DigiPestControl can be classified based on diverse criteria such as operational purpose, provider, and lifespan.

4.1. Strictly Necessary Cookies

Strictly necessary cookies are cookies essential for providing a digital service explicitly requested by the user, or for enabling the secure, basic technical operation of the website and related systems.

These cookies are utilized specifically for the following purposes:

• creating and maintaining user sessions;
• performing user authentication;
• executing security functions;
• reducing unauthorized use or abuse risks;
• recording the user's cookie preference selections;
• ensuring form or transactional security;
• running the core technical functions of the website or SaaS service.

4.2. Functional / Preference Cookies

Functional or preference cookies may enable remembering preferences previously selected by the user and presenting the digital service more suitably to the user.

For example, they may be used for the following purposes:

• remembering language preferences;
• storing display or interface preferences;
• remembering regional or other user choices;
• running optional user experience features.

The legal status of these cookies is evaluated based on whether the function they provide is mandatory for the service explicitly requested by the user.

4.3. Analytical / Performance Cookies

Analytical or performance cookies may assist in understanding how visitors interact with the DigiPestControl website or digital services, measuring technical performance, and improving services.

Where these cookies are utilized, they may assist in analyzing information such as:

• pages visited;
• visit durations;
• frequency of using pages or features;
• technical error or performance data;
• overall traffic and interaction measurements;
• statistical insights helping to improve user experience.

Where analytical or performance technologies are not necessary for providing the mandatory service, prior user choice or consent may be required under applicable legislation.

4.4. Advertising and Marketing Cookies

Where advertising or marketing cookies are utilized, these technologies may be used for purposes such as measuring advertising efficiency, evaluating campaign performance, constructing advertising profiles linkable to user interactions across different websites, or delivering more relevant promotional content.

Such cookies are not deemed strictly necessary for technically delivering the service. Where applicable legislation requires, these cookies are not activated before the user makes the requisite choice or grants valid consent.

4.5. Personalization Cookies

Where personalization technologies are deployed, they may assist in adapting content, features, or user experience in accordance with past interactions or preferences of the user.

Depending on the nature of personalization and the data utilized, whether the relevant cookies are strictly necessary and whether they require consent is evaluated separately.

MADDE 5 – User Choice and Consent Principles Regarding Cookies

5.1. Default State of Non-Essential Cookies

All non-essential cookies (analytical, performance, marketing, functional, and personalization) are disabled by default. They are activated only after the user actively grants affirmative explicit consent.

Continuing to browse the website or closing the notification banner without making an affirmative selection does not constitute valid consent.

5.2. Characteristics of Valid Consent

Under KVKK, GDPR, and UK GDPR, consent must satisfy the following criteria:

• freely given: granted without coercion or negative detriment;
• specific: relating to clearly defined, distinct processing purposes;
• informed: preceded by transparent, understandable information;
• unambiguous affirmative action: demonstrated through an active, verifiable user gesture (e.g., clicking an explicit acceptance button);
• withdrawable: capable of being withdrawn as easily as it was given.

Consent records are documented in accordance with evidentiary standards.

5.3. Separation of Contract Acceptance from Cookie Consent

Acceptance of the SaaS Service and License Agreement does not automatically constitute consent for optional cookies.

Cookie consent is managed independently through dedicated preference interfaces.

5.4. Separation of Privacy Disclosures from Consent

Presenting privacy notices (information layer) is legally distinct from obtaining consent for non-essential tracking.

Information is provided to all users transparently, while non-essential tracking occurs only upon explicit opt-in.

5.5. Prohibition of Cookie Walls

Access to DigiPestControl basic website information, public tools, or standard subscription services is not made conditional upon accepting non-essential advertising or analytics cookies (“Cookie Wall prohibition”).

Users who reject non-essential cookies retain access to core platform services.

MADDE 6 – Cookies Classified by Lifespan

6.1. Session Cookies

Session cookies are temporary cookies created when a user opens a browser window and automatically deleted when the browser is closed.

They are primarily used to maintain user authentication and carry state across pages during an active session.

Common functional uses of session cookies include:

• keeping the user logged in across multiple application screens;
• preventing session drops during wizard calculations;
• maintaining CSRF tokens;
• securing temporary form submissions;
• preserving temporary transient state in the application.

When the browser is terminated, session cookies are erased immediately.

6.2. Persistent Cookies

Persistent cookies remain stored on the user's terminal equipment for a specified expiration period or until manually deleted by the user.

They allow the website to recognize the user on return visits and remember saved interface settings or consent preferences.

Persistent cookies are used for:

• remembering cookie banner consent states;
• preserving selected language configurations;
• storing UI density or table pagination choices;
• retaining analytics identifiers subject to explicit consent;
• maintaining secure persistent login tokens where supported.

All persistent cookies expire automatically upon reaching their predetermined expiration period.

MADDE 7 – First-Party and Third-Party Cookies

7.1. First-Party Cookies

First-party cookies are cookies placed or managed directly by the DigiPestControl internet domain or relevant DigiPestControl digital service visited by the user.

First-party cookies may specifically be used for purposes such as:

• session management;
• security;
• authentication;
• user preferences;
• recording cookie preferences;
• limited performance or statistical measurement under appropriate conditions.

First-party cookies are not accessible to external third-party domains.

7.2. Third-Party Cookies

Third-party cookies are cookies placed or accessed by a third-party domain or service provider distinct from the DigiPestControl domain visited by the user.

Depending on the actual services utilized, third-party technologies may be used for purposes such as:

• analytics and performance measurement;
• mapping or embedded content services;
• video or media content;
• customer support tools;
• security services;
• advertising measurement;
• advertising or marketing.

activities.

MADDE 8 – Categories of Data Processed via Cookies

Information processed through cookies and similar technologies may vary depending on the nature of the specific cookie or technology used. The full scope of data categories listed below is not processed for every individual user.

8.1. Online Identifiers

• cookie ID;
• session ID;
• technical identifiers associated with device or browser;
• other online identifiers depending on technology used.

8.2. Technical Device and Connection Data

• IP address;
• browser type and version;
• operating system;
• device type;
• screen resolution or display properties;
• language and regional settings;
• connection and technical session information.

8.3. Usage and Interaction Data

• pages visited;
• date and time of visit;
• time spent on pages;
• features and tools used;
• screen navigation and page transitions;
• technical error and performance logs;
• referral URLs or traffic sources;
• other technical metrics relating to user interaction.

8.4. Preference Information

• language preferences;
• cookie choices;
• user interface or display settings;
• other technical or functional preferences selected by the user.

8.5. Security and Session Data

• session state;
• authentication status;
• security-related technical tokens;
• abuse or automated bot detection metadata;
• other technical data ensuring secure transaction processing.

8.6. Advertising and Campaign Interaction Data

Where advertising or marketing technologies are utilized and required user choices have been provided, the following data may be processed:

• campaign referral source;
• ad clicks or impressions;
• conversion or marketing performance metrics;
• other interaction information depending on the nature of the advertising technology.

8.7. Special Categories of Personal Data

DigiPestControl is not designed to systematically collect special categories of personal data (sensitive data) through cookies or web technologies, nor to profile users based on sensitive personal data.

Should any new processing activity arise due to a specific third-party integration that could affect this assessment, that technology is subjected to separate legal and technical privacy reviews.

MADDE 9 – Detailed Purposes of Using Cookies

9.1. Session and Account Management

Cookies are used to enable secure login to the DigiPestControl account, sustain user sessions, facilitate access to authorized dashboard modules, and protect session integrity.

9.2. Security and Abuse Prevention

Cookies and technical session tokens are utilized to prevent unauthorized access, ensure session confidentiality, identify automated bot traffic, and mitigate fraud or cyber abuse risks.

9.3. Storing Cookie Preferences

A persistent preference record is stored to remember which non-essential cookie categories a user has accepted or rejected.

This preference record prevents the user from being prompted repeatedly on every page visit and enforces previously selected choices consistently.

9.4. Remembering User Preferences

Functional storage technologies are utilized to retain the user's chosen language, UI theme, table pagination size, or other interface preferences.

9.5. Performance and Statistical Measurement

Subject to satisfying technical and legal conditions, cookies are used for statistical measurement to understand how the website or digital Service is navigated and to optimize performance.

This specifically includes:

• measuring visitor and session counts;
• identifying most and least frequently used pages;
• detecting technical performance issues;
• improving user experience;
• generating overall service performance statistics.

activities.

The legal assessment accounts for whether analytics are first-party or third-party, whether cross-site tracking occurs, whether data is utilized for third-party purposes, and whether data subjects are identifiable.

9.6. Product and User Experience Development

Subject to applicable data protection rules, technical usage data is utilized to enhance user experience, refine software features, detect UI glitches, and optimize responsiveness.

9.7. Advertising and Campaign Measurement

Where digital marketing tools are deployed and legal requirements are met, cookies are used to assess the reach, conversions, and effectiveness of promotional campaigns.

9.8. Behavioral Marketing and Profiling

Technologies enabling tracking of user browsing habits across different websites or constructing marketing profiles are treated separately from essential service functions.

Where applicable law mandates consent or opt-out rights, no behavioral profiling is conducted without first implementing the requisite privacy mechanisms.

MADDE 10 – Legal Bases for Processing Personal Data via Cookies

10.1. Legal Bases under KVKK (Law No. 6698)

Where KVKK applies to cookie-based personal data processing, data is processed relying upon the appropriate personal data processing conditions set forth in Article 5 and other applicable provisions of KVKK:

10.1.1. Strictly Necessary Cookies

With respect to cookies technically necessary to deliver the Service explicitly requested by the user (such as session management, authentication, cybersecurity, form processing, or cookie consent storage), non-consent legal processing conditions are evaluated, including:

• processing being necessary for the establishment or performance of a contract (KVKK Art. 5/2-c);
• processing being mandatory for the legitimate interests of DigiPestControl, provided that it does not harm the fundamental rights and freedoms of the data subject (KVKK Art. 5/2-f).

These legal bases permit processing without separate consent where statutory requirements are met.

10.1.2. Functional Cookies

If a functional cookie is genuinely required to deliver a specific feature explicitly requested by the user, non-consent legal bases may be evaluated.

Beyond that, functional cookies that solely personalize user experience and are not essential for the core Service may require explicit consent under KVKK Art. 5/1.

10.1.3. Analytical and Performance Cookies

The legal assessment of analytical cookies is conducted based on the technical characteristics of the technology utilized.

The following elements are specifically considered:

• whether the analytics tool is first-party or third-party;
• whether data is used solely to produce limited statistics;
• whether cross-site user tracking is conducted across different websites;
• whether the third party uses information for its own purposes;
• whether user profiles are constructed;
• the level of identifiability of data subjects.

Where no appropriate non-consent processing ground is available, explicit consent is obtained for analytical cookies.

10.1.4. Advertising and Marketing Cookies

With respect to cookies used for behavioral advertising, user tracking, advertising profiling, or similar non-essential marketing activities, explicit consent or other valid user choice mechanisms are applied as required by applicable legislation.

10.2. European Union / EEA Users

In the European Union or European Economic Area, the use of cookies and similar technologies is evaluated jointly under applicable national electronic privacy rules and the GDPR.

Where user consent is required for storing information on, or accessing information from, the user's device, the relevant technology is not activated without obtaining valid consent.

Where personal data is obtained via cookies or similar technologies, subsequent personal data processing activities require a valid legal basis under GDPR.

Depending on the specific processing activity, the following legal bases may be evaluated:

• GDPR Article 6(1)(a) – consent;
• GDPR Article 6(1)(b) – performance of contract;
• GDPR Article 6(1)(f) – legitimate interests.

These legal bases are evaluated strictly based on the concrete nature of the processing activity.

10.3. United Kingdom Users

For users in the United Kingdom, cookies and other storage or access technologies are evaluated under UK GDPR together with applicable UK electronic privacy rules (PECR).

Under applicable legislation, where necessary conditions are met, the following exceptions may specifically be evaluated:

• technologies necessary for the transmission of communication;
• technologies strictly necessary for the service requested by the user;
• certain technologies aimed solely at statistical collection and service enhancement;
• certain technologies adapting the appearance or function of the service to user preferences;
• other applicable statutory exceptions.

Where specific statistical or appearance/preference exceptions apply, providing clear and comprehensive information to the user and offering an easy, free objection method where required by law is taken as the baseline principle.

10.4. Changes to Legal Bases

If a cookie's purpose, provider, technical operation, or data processing scope changes, whether the existing legal basis remains valid for the new use is re-evaluated. If the new use requires consent, usage for that purpose is not initiated without obtaining the necessary new choice.

MADDE 11 – DigiPestControl Cookie Inventory

The table below identifies the primary cookies utilized across DigiPestControl digital platforms:

11.1. Currency of the Inventory

This inventory is reviewed and updated periodically as new tools, features, or integrations are introduced.

The table reflects standard production deployments of DigiPestControl.

Inventory updates are documented in version changelogs:

• new cookies added;
• deprecated cookies removed;
• duration modifications;
• provider changes;
• classification updates;
• transfer destination updates;
• technical security tag modifications.

11.2. Limiting Cookie Lifespans

Persistent cookies are programmed with lifespans strictly proportional to their functional purpose, not exceeding 12–24 months.

MADDE 12 – Cookie Preference Center

DigiPestControl may provide a Cookie Preference Center or functionally equivalent preference management mechanism to enable users to manage their preferences regarding non-essential cookies and similar technologies.

The Cookie Preference Center aims to enable the user to evaluate non-essential cookie categories separately and to determine preferences on a category basis to the extent permitted by applicable legislation.

12.1. Strictly Necessary Cookies

Strictly necessary cookies are always active in the preference center and cannot be toggled off because the website and service cannot function without them.

Whether each cookie is truly necessary for the service explicitly requested by the user or for basic technical and security functions is continually evaluated.

12.2. Functional Cookies

For functional or preference cookies not strictly necessary for the core Service, a separate choice option is provided to the user where required by the applicable legal framework.

12.3. Analytical and Performance Cookies

Analytical and performance technologies can be managed subject to user choice depending on the nature of the technology used and applicable regional legislation.

Analytical or performance technologies that require consent are not activated before the user grants permission to the relevant category.

12.4. Advertising and Marketing Cookies

Technologies utilized for advertising, behavioral tracking, advertising profiling, or non-essential campaign measurement are not activated without the user's explicit permission where applicable legislation mandates consent.

12.5. Information Provided Within the Preference Center

Within the Cookie Preference Center, the following information may be presented to the user to the extent possible:

• the name of the cookie category;
• the purpose of use of the category;
• whether the category is strictly necessary;
• relevant cookie or technology providers;
• lifespans and retention periods;
• whether third parties are involved;
• current status of the user's choice;
• link to the detailed Cookie Policy.

MADDE 13 – Cookie Banner and Consent Mechanism

13.1. First-Layer Cookie Notification

Upon their initial visit, users are presented with a clear banner explaining cookie usage with direct links to this Policy.

The banner summarizes key cookie categories in clear language.

13.2. Equal Prominence of Accept and Reject Options

The cookie banner provides “Accept All” and “Reject Non-Essential” buttons with equal visual prominence, font size, and color balance.

No deceptive dark patterns or visual steering are used.

13.3. Prohibition of Pre-Ticked Options

In the preference customization modal, all non-essential category checkboxes remain unchecked by default.

Only strictly necessary cookies are locked in an active state.

13.4. Closing the Banner

Closing the banner without making an explicit selection defaults to rejecting all non-essential cookies.

Browsing continuation does not trigger non-essential script execution.

13.5. Granular Category-Level Choice

Users may accept specific categories while rejecting others.

Custom selections are immediately saved to client storage.

Preference confirmation takes effect across subsequent page requests.

MADDE 14 – Modifying Cookie Preferences and Withdrawing Consent

14.1. Right to Withdraw Consent

Users may withdraw or modify previously granted cookie consent at any time, easily and free of charge.

Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

The withdrawal process is designed to be as simple as granting consent.

14.2. Accessibility of Settings

A persistent “Cookie Preferences” link is available in the footer of every page on the website.

Clicking this link re-opens the preference customization modal.

14.3. Technical Effect of Preference Updates

When a category is disabled, future execution of scripts associated with that category is halted immediately.

Where technically feasible, cookies associated with disabled categories are removed or invalidated.

Browser-side cookies may also be purged manually via browser settings.

MADDE 15 – Cookie Preference and Consent Records

15.1. Logged Information

To prove compliance with statutory data protection rules, the following anonymous metadata is recorded:

• anonymized consent token or identifier;
• exact timestamp of consent (date and time UTC);
• the specific categories accepted or rejected;
• the version number of the Cookie Policy in effect;
• truncated IP address;
• browser user-agent hash.

15.2. Purpose of Consent Logs

These logs are maintained strictly for legal compliance verification and audit readiness.

They serve as documented evidence of valid consent under KVKK and GDPR.

Consent records are retained for statutory audit limitation periods.

MADDE 16 – Managing Cookies via Browser and Device Settings

In addition to the Cookie Preference Center provided by DigiPestControl, users may also utilize the privacy and storage controls offered by their internet browser or device.

16.1. Browser Controls

Most modern internet browsers may allow users to:

• view existing cookies;
• delete cookies;
• block new cookies;
• restrict third-party cookies;
• configure distinct cookie preferences for specific websites;
• clear specific data upon browser closing.

possibilities.

16.2. Blocking Strictly Necessary Cookies

If all cookies are blocked at the browser or device level, all or part of the login, security, user authentication, or other basic functions of the DigiPestControl website or SaaS platform may not operate properly.

This situation may result directly from the technical blocking implemented at the user's browser level.

MADDE 17 – Third-Party Services and Cookie Technologies

17.1. Third-Party Service Categories

DigiPestControl may integrate trusted third-party providers for web traffic analytics, mapping features, payment processing, and security verification.

Categories of third parties include:

• cloud hosting and data center providers;
• web traffic measurement engines;
• online payment and fraud prevention providers;
• mapping and geolocation tile services;
• embedded video hosting platforms;
• customer communication and support chat widgets;
• security firewall and bot mitigation networks;
• push notification gateways;
• digital advertising networks.

17.2. Roles of Third Parties

Third parties acting as Data Processors are bound by strict contractual data protection agreements.

They are authorized to process data strictly under documented instructions.

17.3. Third-Party Privacy Policies

Where third parties act as independent Data Controllers, their respective privacy policies govern their direct data processing.

Links to third-party privacy policies are maintained in our vendor disclosures.

MADDE 18 – Cross-Border Data Transfers via Cookies

Certain third-party cookie, analytics, security, advertising, support, or similar technology providers may be located outside Türkiye or may process personal data through systems situated in different countries.

Therefore, using specific cookies or similar technologies may result in the transfer of personal data abroad.

18.1. Identifying Cross-Border Transfers

In evaluating whether a technology leads to a cross-border data transfer, the following elements may specifically be considered:

• the country where the service provider is established;
• the geographical region where personal data is hosted;
• countries from which data can be accessed remotely;
• sub-processors engaged;
• the technical flow of data.

considerations.

18.2. Transfers under KVKK

In cross-border data transfers where KVKK is applicable, legal mechanisms providing valid transfer pursuant to Article 9 of Law No. 6698 and applicable secondary legislation are evaluated.

Where an adequacy decision, appropriate safeguard, standard contract, or other legal mechanism is required for the transfer, relevant requirements are fulfilled separately.

18.3. Transfers under GDPR and UK GDPR

In international data transfers where GDPR or UK GDPR applies, adequacy decisions, standard contractual mechanisms, or other valid transfer safeguards recognized under the relevant legislation are evaluated.

18.4. Inventory Alignment

In the DigiPestControl cookie inventory, where a cross-border transfer possibility or status exists with respect to a specific cookie or technology, this information is shown on a technology-by-technology basis to the extent possible.

MADDE 19 – Global Privacy Control and Privacy Signals

19.1. California Users and GPC

Where Global Privacy Control (GPC) browser signals are detected from California users, they are recognized as a valid opt-out request under CCPA/CPRA.

Marketing cookies are suppressed automatically upon GPC detection.

19.2. GPC vs General Cookie Consent

GPC signals communicate opt-out preferences for data sale/sharing under CCPA/CPRA.

They operate alongside standard cookie preference controls.

19.3. Do Not Track (DNT) Signals

Standardized privacy signals are respected in accordance with emerging legal frameworks.

Where industry standards become mandatory, automated enforcement is activated.

19.4. Evolving Privacy Protocols

We monitor technical protocol developments to ensure automated privacy compliance.

Platform integrations are updated to align with global privacy standards.

MADDE 20 – Google Analytics and Web Analytics Services

20.1. Purpose of Analytics

Google Analytics is used to measure aggregate site traffic, user flows, and page popularity.

Analytics assist our team in improving software performance and responsiveness.

20.2. Activation Subject to Prior Consent

Google Analytics scripts are loaded only after explicit analytical cookie consent is granted.

If analytical cookies are rejected, no tracking tag is executed.

20.3. IP Anonymization

IP masking and anonymization features are enabled to truncate the last octet of user IP addresses.

Safeguards implemented include:

• IP address truncation before processing;
• disabled data sharing with other Google products;
• enforced data retention expiration limits;
• pseudonymized client identifiers;
• encrypted data transmission via HTTPS;
• contractual EU Standard Contractual Clauses with Google.

MADDE 21 – Advertising, Campaign, and Marketing Technologies

21.1. Marketing Objectives

Used to measure marketing campaign efficiency and display product announcements to interested business professionals.

Marketing technologies evaluate ad conversion metrics.

Marketing campaign tools may evaluate:

• ad impressions and click-through rates;
• registration page conversion milestones;
• campaign channel attribution;
• frequency capping efficiency;
• promotional messaging relevance.

21.2. Prior Explicit Consent Requirement

Marketing cookies and retargeting pixels are never executed without prior explicit consent.

Opt-in must be affirmative and unambiguous.

21.3. Profiling Disclosures

Users have the right to object to commercial profiling at any time.

Profiling is strictly restricted to B2B commercial marketing contexts.

No automated decision-making producing legal effects is conducted.

MADDE 22 – Maps, Video, Chat, and Embedded Third-Party Content

22.1. Embedded Content Cookies

Embedded widgets (such as mapping services or video players) may set third-party cookies.

Such third-party content is governed by relevant provider privacy terms.

We configure embedded widgets in privacy-preserving modes where supported.

22.2. Map and Location Services

Integrated mapping providers process coordinates solely to render facility layout and bait station pins.

Mapping services do not track individual users across unauthorized third-party sites.

22.3. Media Players

Embedded training videos utilize privacy-enhanced mode where supported.

Tracking cookies from media players are blocked until user playback activation.

MADDE 23 – Mobile Application SDKs, Device Identifiers, and Tracking Technologies

23.1. Mobile Application Permissions

Mobile apps request runtime operating system permissions (camera, storage, location) strictly for operational features (barcode scanning, photo attachments, visit geostamps).

Permissions can be managed or revoked via device system settings.

Mobile operating system permissions include:

• camera access for QR/barcode scanning;
• storage access for offline data synchronization;
• location access for technician visit geoverification;
• push notification permissions for dispatch alerts;
• network state access for connection monitoring;
• biometric authentication permissions where enabled;
• Bluetooth access for IoT trap sensor pairing.

23.2. Mobile SDK Inventory

SDKs utilized in mobile apps are governed by the same data minimization and consent standards as web cookies.

Only SDKs necessary for crash reporting, security, and notification delivery are deployed.

MADDE 24 – Children's Privacy and Tracking Technologies

DigiPestControl services are directed exclusively to commercial businesses and professional pest control operators and are not intended for children under 18 years of age.

We do not knowingly place tracking cookies on devices of children or process children's personal data.

If we become aware that personal data of a minor has been collected inadvertently, such data will be deleted immediately.

Parents or guardians may contact us to request the removal of any inadvertently submitted data.

MADDE 25 – Security of Cookie Data

25.1. Protection of Cookie Data

Sensitive authentication tokens and session identifiers are protected using HttpOnly, Secure, and SameSite=Strict/Lax security flags to mitigate XSS and CSRF risks.

Plaintext passwords, financial details, and special category personal data are never stored in cookies.

Technical safeguards implemented include:

• HTTPS encryption for all cookie transmission in transit;
• HttpOnly flag preventing client-side JavaScript access to session cookies;
• Secure flag restricting cookie transmission exclusively over encrypted TLS connections;
• SameSite=Strict or SameSite=Lax preventing cross-site request forgery;
• cryptographic entropy for session identifiers;
• automatic token invalidation upon user logout;
• rate-limiting on authentication endpoints.

Session tokens are rotated periodically to enhance security.

Administrators continuously monitor for potential cookie manipulation attacks.

MADDE 26 – Rights of Data Subjects

26.1. Rights under KVKK (Law No. 6698, Art. 11)

Data subjects may inquire about cookie data processing, request rectification, demand erasure, object to automated profiling, and claim compensation for unlawful processing.

Statutory rights under KVKK Art. 11 remain fully guaranteed.

26.2. Rights under GDPR and UK GDPR (Articles 15–22)

Data subjects possess rights of access, rectification, erasure (right to be forgotten), restriction of processing, data portability, right to object, and right to lodge complaints with lead Data Protection Authorities.

Data subjects may also lodge complaints with the relevant Supervisory Authority.

26.3. Exercising Rights

To exercise data protection rights, data subjects may submit written requests to info@digipestcontrol.com.

MADDE 27 – Policy Updates and Version Management

This Cookie Policy may be updated due to changes in technologies used, addition of new cookies or third-party services, changes in purposes of existing cookies, legislative updates, or enhancements to DigiPestControl digital services.

27.1. Technical Updates

Specifically, the cookie inventory and Policy must be re-evaluated following:

• installing a new analytics tool;
• introducing Google Ads, Meta, or similar advertising services;
• adding a new chat or customer support service;
• engaging a new map, video, or embedded content provider;
• modifying the session or authentication infrastructure;
• adding a new SDK to mobile applications;
• commencing use of an existing technology for a new data processing purpose.

27.2. Re-Consent for Material Changes

If a new data processing purpose or technology is added that materially alters the scope of a previously obtained user choice, whether the existing choice remains sufficient is re-evaluated.

If the new activity requires separate user consent, the relevant technology is not enabled for that purpose without obtaining the requisite new choice.

27.3. Current Version

The effective current version of the Cookie Policy is published accessibly on the DigiPestControl website.

27.4. Version History

MADDE 28 – Contact Information

For any questions regarding this Cookie Policy, cookie preferences, or personal data processing activities conducted via cookies, the following contact information may be used.

The detailed application procedure regarding the exercise of data subject rights is explained in the DigiPestControl Global Privacy, Personal Data Protection, and Security Policy.