1. Introduction

2. For which purposes and on what basis do we process your personal data?

3. Which cookies do we use within the Website?

4. To whom we may disclose your personal data?

5. How long do we keep your personal data?

6. Which rights do you have with respect to your personal data?

1. Introduction

This Privacy and Cookies Policy explains how your personal data are processed within the Website www.etiinternational.com (hereinafter referred to as the “Website”).

The entity which is responsible for the processing of your personal data within the Website, as data controller, is ETi GIDA SANAYI VE TICARET A.S. (a Turkish company, having the sole registration code 3810026750 and the registered office at Hoşnudiye Mahallesi, Kızılcıklı Mahmut Pehlivan Caddesi No:11 - Tepebaşı ESKISEHIR / TURKEY), referred to as “ETi” or “we” or “us”  in this Privacy and Cookies Policy.

Your personal data processed by us within the Website are either provided by you when you fill in a form in a “Contact Us” (https://www.etiinternational.com/eti-contact-info or https://www.etiinternational.com/eti-customer-complaint) section of the Website or when you contact us through the other available means of contact posted on the Website, or collected by us through the cookies of the Website.

We do not access the information stored in your terminal equipment (computer, phone, tablet etc.), except under the conditions described in section 3 below.

Providing your data is not necessary. However, if you fail to provide them, we will not be able to answer your messages, complaints or requests or perform other purposes as mentioned in section 2 of this policy. 

Please read carefully this Privacy and Cookie Policy, and for any question or clarification you may contact us through the e-mail address dataprotection@etiinternational.com.

2. For which purposes and on what basis do we process your personal data?

We collect, within the Website, the personal data which are necessary for the following purposes:

• analysing the use of the Website by its visitors, through analytics cookies, including counting visits and improvement of performance of a Website;

• managing advertising upon user interests and interactions with our website, through analytics cookies and/or social media plugins (eg. Facebook’s pixel);

• giving answers to the messages, complaints or requests received through the form in the “Contact Us” section of the Website or by e-mail;

As regards the forms in the “Contact Us” section of the Website, the lines which are indispensable for the purposes of handling and responding your questions are marked with an asterisk and in the absence of their filling in, we will not be able to give course to your requests or applications. On the other hand, you are not obliged to fill in the lines which are not marked with an asterisk.

Section applicable only to individuals that are in the European Economic Area: Please note that our legal basis for collecting and using your personal information will depend on the nature and circumstances on the processing. The processing of your personal data within the Website is based either on your consent (in line with Article 6 paragraph 1 point a of the European General Data Protection Regulation no 2016/679; ‘GDPR’) with respect to cookies which require a consent or under our legitimate interest (in line with Article 6 paragraph 1 point f of the GDPR) with respect to (i) cookies which are necessary to operate the Website, and (ii) processing made to answer your contact request or address your complaint. You have the right to withdraw your consent at any time or object to processing of your personal data made under our legitimate interest, by sending us a request in this respect, either through the form in the “Contact Us” section of the Website, or through the e-mail address dataprotection@etiinternational.com or to any of the postal addresses indicated in section 1 above. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

We are not processing your data in an automated way (eg. by implementing automated decision-making). 

We may, however, perform certain profiling operation on your data collected from social media pixels and analytics cookies. For example, we may use your data to assign you to a user category (e.g. if you visited our chocolate product page, we may assign you to a segment of users potentially interested in chocolates). We may also use your data for retargeting purposes (e.g. on Facebook) and for the purpose of enhancing our user category segments in Facebook and Google Advertising tools to improve website traffic and our media (advertising) effectiveness. Please note that data we collect from social media pixels and analytics cookies is limited to device identifiers and other identifiers consisting of a random series of letters and numbers. We don’t have your name, contact information or any other information that directly identifies you as an individual, unless you provide them to us.

3. Which cookies do we use within the Website?

We do not access the information stored in your terminal equipment (computer, phone, tablet etc.), except (i) with your prior consent or (ii) in reference to cookies required to operate a Website (when such operations are made for the sole purpose of carrying out the transmission of a communication over an electronic communications network or are strictly necessary in order to provide an information society service explicitly requested by you).

Our website may also display content from a third party website or service (eg. social media plug-ins), which may result in cookies (or similar solutions, such as Facebook pixel) from third parties being stored on your terminal equipment or third parties having access to information about how you use our Website. We do not control the storage and use of these cookies by these third parties and you should refer to the privacy policies of the relevant third parties for more information.

A “cookie” is a small file, consisting of letters and numbers, which can be stored in a user's terminal equipment (computer, phone, tablet etc.) when the user accesses an online service through the internet navigation application (the “browser”). The cookie file allows its issuer to identify the terminal equipment in which the cookie file was stored, during the lifespan of that cookie file.

The Website uses the following cookies: 

For the use of the cookies in respect of which your prior consent is necessary (which are not necessary to run our Website), we ask for your consent in a cookie banner displayed on the entry page of the Website. Such cookies are set by default as inactive. If you give your consent, you can withdraw it at any time, by changing the cookies settings in our Privacy Preference Centre.

You can also always manage settings of, reject or delete cookies on your terminal equipment (computer, phone, tablet etc.) by changing your browser settings. Where these settings can be found depends on the type of browser you are using. If you do change the settings, please be aware that some functions and services of the Website can be limited or inactive.

4. To whom we may disclose your personal data?

Your personal data collected within the Website are processed by the data controller indicated in section 1 above, which may disclose your personal data to certain entities (data processors), for the processing of the personal data by such entities on behalf of and based on the instructions of the controller.

To answer your contact request or to handle your complaint, we may also share your personal data with other companies from ETi’s group, namely with:

• ETi EUROPEAN FOOD INDUSTRIES S.A. (a Romanian company with its registered office at Sat Gherceşti, Comuna Gherceşti, Str. Aviatorilor nr. 10, Parc Industrial Craiova, U1/PIC/EI, Județul Dolj, Romania)

• ETI EUROPEAN FOOD INDUSTRIES S.A. Oddział w Polsce (a Polish branch of our Romanian company with its registered office in Warsaw, ul. Postępu 18B, 02-676, Warsaw, Poland).

Thus, we may use data processors for the maintenance of the Website (for instance, providers of IT services, such as website content management or technical development agency) or for the processing of the personal data collected through the forms in the  “Contact Us” section of the Website (for instance, providers of contact centre services / call centre).

On the other hand, as regards the cookies issued by third parties, your personal data will also be accessed by those third parties, mentioned in the table from section 3 above (for instance, Google, which is a U.S. company). Since such third parties may be located outside the European Economic Area (EEA), there is a risk that your personal data collected through the cookies used by the Website will not benefit from the same level of protection as in the EEA. Therefore, you should consider this aspect when you give your consent for the cookies used by the Website.

We shall not disclose your personal data to other third parties, except if you give us your consent, we have a legitimate interest in sharing those data (eg. If we share information regarding your request with our affiliates – list of which can be found above in this point 4.) or if we are obliged to do so by the authorities or by the applicable legal provisions.

For the purposes indicated in section 2 above, your personal data may be processed by the data controller ETI GIDA SANAYI VE TICARET A.S. (and by its data processors) in Turkey.. 

Where we transfer personal data outside the EEA (specifically by using non-EEA data processors), to a country that is not subject to a decision of the European Commission regarding the adequacy of the level of data protection, we ensure that such transfer is adequately protected by other appropriate safeguards being in place, such as contractual safeguards, including standard contractual clauses approved by the decision of the European Commission (see at https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en for further information). A copy of applied safeguards can be obtained by writing to us on the e-mail address or any of the postal addresses indicated in section 1 above. 

In order to find out the identity of data recipients used by us, you may send us a request in this respect, either through the form in the “Contact Us” section of the Website, or through the e-mail address dataprotection@etiinternational.com or to any of the postal addresses indicated in section 1 above.

5. How long do we keep your personal data?

Except for the cases in which the applicable legal provisions set out or oblige us otherwise, we will keep your personal data for no longer than is necessary for the purposes for which the personal data are processed. 

Thus:

• as regards the forms in the “Contact Us” section of the Website or the correspondence received through the means of contact posted on the Website (e-mail), we will keep your personal data for the period which is necessary in order to answer to your messages, complaints or requests and to prove the correspondence with you, as well as, in certain cases, like the existence of a litigation, for the period of the dispute settlement procedures before the courts of law or before other authorities with specific competences related to resolving the dispute in question; 

• as regards the personal data collected through the cookies of the Website, such data will be processed during the lifespan of the cookies (as indicated in section 3 above).

In any case, if you will withdraw your consent, we will cease the processing of your personal data and erase them, except for the cases in which the applicable legal provisions set out or oblige us otherwise.

6. Which rights do you have with respect to your personal data?

Section applicable only to individuals who are in the European Economic Area:

Under the conditions set forth by the legal provisions on personal data protection (specifically by the GDPR), you have several rights regarding your personal data:

• the right of access – allows you to obtain confirmation as to whether your personal data are being processed by us and, if affirmative, the relevant details of such processing activities, as well as a copy of your personal data;

• the right to rectification – allows you to obtain the rectification of your personal data, if inaccurate;

• the right to erasure (“the right to be forgotten”) – allows you to obtain the erasure of your personal data in certain cases under the conditions and limits brought forth by the law (for example, if you have withdrawn your consent and your consent was the only legal basis for processing your personal data); 

• the right to restriction of processing – allows you to request us not to use your personal data, except to store them, when: (i) you contest the accuracy of your personal data (until the accuracy thereof will be verified); (ii) you are opposed to the erasure of your personal data, in case of unlawful processing thereof; (iii) you request us to provide you with certain data for the establishment, exercise or defence of a legal claim; (iv) you object to the processing of your data, under specific conditions;

• the right to object to the processing – allows you to object to the processing of your personal data, under the conditions and limits brought forth by the law;

• the right to data portability – allows you to receive your personal data you have provided to us, in a structured, commonly used and machine-readable format or to transmit this personal data to another data controller.

Where the processing is based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You may exercise your abovementioned rights, by sending us a request in this respect, either through the form in the “Contact Us” section of the Website, by sending us a letter to our postal address indicated in section 1 of this policy or through the e-mail address dataprotection@etiinternational.com. 

Last but not least, you have the right to lodge a complaint with a data protection supervisory authority in country of your habitual residence, place of work or seat of the data controller. You can find contact details for your national supervisory authority here: https://edpb.europa.eu/about-edpb/board/members_en.