Privacy & Cookie Policy

1. Introduction

2. What personal data do we collect and how do we use It?

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?

7. Changes to this policy

1. Introduction

This Privacy and Cookies Policy (“Policy”) has been prepared in accordance with the GDPR and other applicable data protection laws (“Law”), with the aim of informing you about how your personal data is processed through the website www.etiinternational.com (the “Website”).

The entities which are responsible with the processing of your personal data within the Website, as data controllers, are:

ETi EUROPEAN FOOD INDUSTRIES S.A. (a Romanian company having the sole registration code 32187285 and the registered office at Sat Gherceşti, Comuna Gherceşti, Str. Aviatorilor nr. 10, Parc Industrial Craiova, U1/PIC/EI, Județul Dolj, Romania), and
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),

collectively referred to as “ETi” or “we” or “us” in this Privacy and Cookies Policy.

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

Please read carefully this Privacy and Cookie Policy, and for any question or clarification you may contact us through the e-mail address [email protected].

2. What Personal Data Do We Collect and How Do We Use It?

PROCESSING PURPOSE	LEGAL BASIS	Categories of 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 functional cookies, – Managing advertising upon user interests, through analytics and/or targeting cookies, – Enhancing visitors’ user experience and website efficiency through the use of performance cookies.	Prior Consent Given Through Cookie Settings GDPR Art. 6/1-(a)	– Transaction Security Information (such as your IP address, device type, device and advertising identifiers, browser type and version, and server log information)
– Contacting you through the contact and complaint areas on our website; in this context, providing information and support regarding our products and services, receiving and finalizing your questions, comments, complaints and/or other requests, – Examining, auditing and reporting our business processes. – To enable core site functions through the strictly necessary cookies.	Legitimate Interests GDPR Art. 6/1-(f)	– Identity Information (Such as your name-surname) – Contact Information (Such as your phone number, e-mail address, address information, city-country information) – Transaction Security Information (such as your IP address, device type, device and advertising identifiers, browser type and version, and server log information) – Transaction Information (Such as your LOT number of the product and visual records of the defected product, information about content of your message and written message)
– In cases where authorized institutions or organizations request us or where it is foreseen that we will notify these institutions to fulfill our legal obligations.	Legal Obligation GDPR Art. 6/1-(c)	– Identity Information (Such as your name-surname) – Contact Information (Such as your phone number, e-mail address, address information, city-country information) – Transaction Security Information (such as your IP address, device type, device and advertising identifiers, browser type and version, and server log information) – Transaction Information (Such as your LOT number of the product and visual of the defected product, information about content of your message and written message) – Legal Transaction Information (Such as legal documents, and correspondence with official authorities related to our product and service)

3.Which cookies do we use within the Website?

We do not store information or cookies and we do not access the information stored in your terminal equipment (computer, phone, tablet etc.), except with your prior consent or 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.

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.

Website uses the following cookies:

Name of the Cookie	Issuer (Eti or a third party)	Purpose	Information stored and accessed by the cookie	Life span	Prior consent necessary (Yes/No)
Strictly Necessary Cookies
ASP.NET_SessionId	ETİ	Maintaining an anonymised user session	General purpose platform session cookie, used by sites written with Microsoft .NET based technologies. Usually used to maintain an anonymised user session by the server.	Session	No
OptanonConsent	OneTrust	Cookie Consent	This cookie is set by the cookie compliance solution from OneTrust. It stores information about the categories of cookies the site uses and whether visitors have given or withdrawn consent for the use of each category. This enables site owners to prevent cookies in each category from being set in the users' browser when consent is not given. The cookie has a normal lifespan of one year and contains no information that can identify the visitor.	1 Year	No
Performance Cookies
_ga	Google	Tracking Site Usage	This cookie name is associated with Google Universal Analytics – which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the site’s analytics reports. By default, it is set to expire after 2 years.	2 Years	Yes
_clck	ETİ	Tracking Site Usage	This cookie is related to Microsoft Clarity analytics service. It is used to collect information about how visitors interact with the website, which helps in creating reports and improving the site.	364 Days	Yes
Functional Cookies
Yes
Targeting Cookies
Yes

For the use of the cookies in respect of which your prior consent is necessary, we ask for your consent in a 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 the “Privacy and Cookies” section of the Website.

In addition, you can delete or manage cookies through your browser settings. Below are links to guidance on cookie management for commonly used browsers:

4. To whom we may disclose your personal data?

Your personal data collected within the Website are processed by the data controllers 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 controllers.

Thus, we may use data processors for the maintenance of the Website (for instance, providers of IT services) or for the processing of the personal data collected through the forms in the “Contact” and “Complaint” section of the Website (for instance, providers of contact center services).

In order to find out the identity of the data processors used by us, you may send us a request in this respect, either through the form in the “Contact” section of the Website, or through the e-mail address or any of the postal addresses indicated in section 1 above or section 6 below.

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, 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 European Economic Area. 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 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, which is a country outside the European Economic Area and for which there is no decision of the European Commission regarding the adequacy of the level of data protection. Therefore, there is a risk that your personal data will not benefit from the same level of protection as in the European Economic Area and you should consider this aspect when you give your consent to the processing of your personal data within the Website.

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” and “Complaint” sections 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 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 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?

You have several rights under applicable data protection laws. Your rights under GDPR are as below:

Right to Access à You have the right to know how your personal data has been collected and processed, what data exists in our systems, and for what purposes it has been processed. This information may be accompanied by a copy of the requested data.
Right to Correction (Rectification) à You have the right to request a correction on incorrect or incomplete personal data of yours.
Right to Erasure (Right to Be Forgotten) à You have the right to have your personal data permanently deleted. But this is not an absolute right to require all personal data to be deleted. We will consider each erasure request in accordance with the requirements of applicable laws.
Right to Restriction of Processing à You have the right to block or suppress your personal data being processed.
Right to Data Portability à You have the right to move, copy, or transfer personal data from one data controller to another, in a safe and secure way, in a commonly used and machine-readable format.
Right to Object to Processing à You have the right to object to being subject to processing your data based upon the lawful basis of legitimate interest. You also have the right to stop your personal data from being included in direct marketing databases.
Right to Not Be Subject to Automated Decision Making à You have the right not to be subject to a decision which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you.

You also have the right to complain to a Data Protection Authority about our use and collection of your personal data. For more information, please contact the relevant Data Protection Authority in your country.

E-mail: [email protected].

Address: ETi EUROPEAN FOOD INDUSTRIES S.A. - Sat Gherceşti, Comuna Gherceşti, Str. Aviatorilor nr. 10, Parc Industrial Craiova, U1/PIC/EI, Județul Dolj, Romania),

ETi GIDA SANAYI VE TICARET A.S.- Hoşnudiye Mahallesi, Kızılcıklı Mahmut Pehlivan Caddesi No:11 - Tepebaşı ESKISEHIR / TURKEY

7. Changes to this policy

From time to time, we may change this Cookie Policy. If there any significant changes we will post on our website, applications or let you know by email.