This Cookie Policy explains how Benjis E-Ticaret Danışmanlık Ltd. Şti. ("Benji's Digital", "we", "us" or "our") uses cookies and similar tracking technologies on benjisdigital.com (the "Website"). It describes what these technologies are, why we use them, the types of cookies we use, and how you can control your preferences.
This Policy applies in conjunction with our Privacy Policy and Terms of Use. It is designed to comply with Turkish Law No. 6698 on the Protection of Personal Data ("KVKK"), the Turkish Personal Data Protection Authority's "Guidelines on Cookie Practices" (June 2022), Law No. 5809 on Electronic Communications, and—to the extent applicable to visitors located in the European Economic Area ("EEA"), the United Kingdom or other jurisdictions with similar regimes—the EU General Data Protection Regulation ("GDPR"), the UK GDPR and the ePrivacy Directive (Directive 2002/58/EC).
1. What Are Cookies?
Cookies are small text files placed on your device (computer, tablet, smartphone, etc.) by websites you visit. They are widely used to make websites work, improve user experience, remember preferences, analyse usage and deliver personalised advertising. Similar technologies (such as web beacons, pixels, local storage and SDKs) function in comparable ways and are covered by this Policy.
2. How We Categorise Cookies
2.1. By Duration
- Session cookies: Temporary cookies deleted automatically when you close your browser.
- Persistent cookies: Cookies that remain on your device for a defined period or until you delete them.
2.2. By Origin
- First-party cookies: Set directly by Benji's Digital through the Website.
- Third-party cookies: Set by third-party providers (e.g. Google, Meta, LinkedIn) through scripts or content embedded on the Website. These are governed by the respective provider's own privacy policy.
2.3. By Purpose
a) Strictly Necessary Cookies: Essential for the Website to function (e.g. session management, security, load balancing, storing your cookie preferences). Under KVKK Art. 5(2), these cookies do not require your consent and are processed on the basis of contractual necessity and our legitimate interests. Under GDPR Art. 6(1)(f) and the ePrivacy Directive, they fall within the "strictly necessary" exemption from consent. They cannot be disabled through our Website.
b) Functional Cookies: Enable enhanced functionality and personalisation (e.g. remembering language, region or display preferences). Subject to your consent.
c) Performance / Analytics Cookies: Help us understand how visitors interact with the Website by collecting pseudonymised information about page visits, click patterns and traffic sources (e.g. Google Analytics 4). IP addresses and other identifiers processed via these cookies are treated as personal data under both KVKK and GDPR. Subject to your consent.
d) Marketing / Advertising and Targeting Cookies: Used to show ads relevant to your interests, measure ad performance, build audience profiles and run remarketing campaigns (e.g. Meta Pixel, Google Ads, LinkedIn Insight Tag). Subject to your consent.
3. Cookies We Use
| Cookie / Provider | Type | Purpose | Duration |
|---|---|---|---|
| PHPSESSID, wordpress_* | Strictly necessary | Session management and security | Session |
| benjis_cookie_consent (Benji's Digital CMP) | Strictly necessary | Stores your cookie preferences and consent records | 12 months |
| Google Tag Manager | Tag management (auxiliary) | Tag management system; does not set cookies on its own, but manages other measurement scripts | — |
| Google Analytics (_ga, _ga_*, _gid) | Analytics | Pseudonymised measurement of Website traffic and user behaviour | 1 day – 2 years |
| Google Ads (_gcl_au, NID) | Marketing | Conversion tracking, ad performance, remarketing | 3 – 13 months |
| Meta Pixel (_fbp, fr) | Marketing | Facebook & Instagram ad measurement, targeting and profiling | 3 months |
| LinkedIn Insight Tag (li_sugr, bcookie) | Marketing / Analytics | LinkedIn ad conversion tracking and audience targeting | 3 months – 1 year |
The list above reflects the principal cookies in use. The detailed and most current list is available through the Cookie Consent Banner on our Website.
4. Personal Data Processed Through Cookies
Cookies and similar technologies may process the following categories of personal data:
- Identity data: name, surname (only when you log in)
- Contact data: e-mail address (when you submit a form)
- Technical and security data: IP address, browser type and version, operating system, session identifiers, device identifiers
- Location data: approximate geographic location derived from your IP address
- Usage data: pages visited, click behaviour, time on site, referring URL, device fingerprint elements, and—where deployed—heatmaps and session recordings
5. Legal Bases for Processing
We rely on the following legal bases:
- Strictly necessary cookies — Performance of a contract and our legitimate interests (KVKK Art. 5(2)(c) and (f); GDPR Art. 6(1)(b) and (f); ePrivacy Directive Art. 5(3) "strictly necessary" exemption).
- Functional, analytics and marketing cookies — Your consent (KVKK Art. 5(1); GDPR Art. 6(1)(a); ePrivacy Directive Art. 5(3)).
6. Withdrawing Your Consent
You may withdraw your consent at any time, free of charge and without giving reasons, by using the "Cookie Settings" link in the footer of the Website. Withdrawal will not affect the lawfulness of processing carried out before withdrawal. Refusing or withdrawing consent will not restrict your access to the Website; only those features that depend on optional cookies will be unavailable.
7. International Data Transfers
Some of our cookie providers (Google LLC, Meta Platforms Inc., LinkedIn Corporation) operate servers outside Türkiye, the EEA and the UK, including in the United States. As a result, personal data collected via cookies may be transferred internationally.
Where transfers leave Türkiye, they are made in accordance with KVKK Art. 9 (as amended on 12 March 2024), based on (i) an adequacy decision issued by the Personal Data Protection Authority, (ii) appropriate safeguards (such as standard contractual clauses, binding corporate rules or undertakings approved by the Authority), or (iii) the limited derogations set out in Art. 9(6).
Where transfers leave the EEA or the UK, we rely on adequacy decisions, the European Commission's / UK ICO's Standard Contractual Clauses (with supplementary measures where necessary), or applicable derogations under GDPR Art. 49 / UK GDPR Art. 49.
8. Third-Party Providers' Independent Responsibility
Third-party cookie providers act as independent or joint controllers in relation to data they collect through our Website. Their processing is governed by their own privacy policies:
9. Retention
Retention periods for individual cookies are set out in the table in Section 3. Personal data collected through cookies is retained for the duration necessary for the relevant processing purpose, and in accordance with our internal Personal Data Retention and Destruction Policy.
10. Managing Your Cookie Preferences
When you first visit the Website, you will see our Cookie Consent Banner, where you can accept or reject non-essential cookies and configure granular preferences. You can revisit your choices at any time via the "Cookie Settings" link in the footer. Our Banner is operated through Benji's Digital's own consent management platform; consent records are kept for 12 months for evidentiary purposes.
You can additionally control cookies through your browser's settings (Chrome, Firefox, Safari, Edge, Brave, Opera and others). Please refer to your browser's help documentation for instructions.
11. Children
Our Website is intended for business and professional audiences and is not directed at children under the age of 18. We do not knowingly collect personal data from individuals under 18. If you believe a child has provided us with personal data, please contact us at [email protected] and we will delete it promptly.
12. Your Rights
Depending on the law applicable to you, you may have the following rights in relation to your personal data processed through cookies:
- Right to be informed and right of access
- Right to rectification of inaccurate or incomplete data
- Right to erasure ("right to be forgotten") in defined circumstances
- Right to restrict or object to processing, including objection to direct marketing and profiling
- Right to data portability (where applicable under GDPR/UK GDPR)
- Right to withdraw consent at any time
- Right not to be subject to a decision based solely on automated processing
- Right to lodge a complaint with the Turkish Data Protection Authority (KVKK Art. 14) or, where applicable, with an EEA / UK supervisory authority
13. How to Exercise Your Rights
You can exercise your rights by contacting us via:
- E-mail: [email protected] (sent from an e-mail address registered with us)
- Postal mail: at our registered office address shown above, in writing and signed
Your request must include your name, identifying details (e.g. national ID / passport number where required by Turkish law), contact details, and a clear description of your request, in accordance with the Turkish Communiqué on Application Procedures to Data Controllers. We will respond within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Turkish Personal Data Protection Authority within the time limits set out in KVKK Art. 14, or with your local supervisory authority where applicable.
14. Updates to This Policy
We may update this Cookie Policy from time to time to reflect legal developments, regulatory guidance, changes in cookie technologies or in our services. Material changes will be communicated through the Cookie Consent Banner, where renewed consent will be requested where required.
15. Contact
Benjis E-Ticaret Danışmanlık Ltd. Şti.
Address: Evliya Çelebi Mah. Sadi Konuralp Cad. No: 5/2, 34430 Beyoğlu / İstanbul, Türkiye
E-mail: [email protected]
Web: www.benjisdigital.com