Data Protection Policy

The responsible party within the meaning of data protection laws, in particular the EU General Data Protection Regulation (DSGVO), is:

Spy Pharma

🌐 www.spypharma.com

✉️ info@spypharma.com

📞 +90 (850) 840 79 00

📍 Istanbul/Turkey

Your data subject rights

You can exercise the following rights at any time under the contact details provided by our data protection officer:

Information about your data stored by us and its processing (Art. 15 DSGVO)

Correction of incorrect personal data (Art. 16 DSGVO)

Deletion of your data stored by us (Art. 17 DSGVO)

Restriction of data processing, provided that we are not yet allowed to delete your data due to legal obligations (Art. 18 DSGVO)

Objection to the processing of your data by us (Art. 21 DSGVO)

Data portability, provided that you have consented to the data processing or have concluded a contract with us (Art. 20 DSGVO)

If you have given us consent, you may revoke this consent at any time with effect for the future.

You may at any time lodge a complaint with a supervisory authority, e.g., the competent supervisory authority in the federal state of your residence or the authority responsible for us as the controller. A list of supervisory authorities (for the non-public sector) with address can be found at: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

Collection of General Information When You Visit Our Website

Nature and Purpose of Processing

When you access our website, i.e., when you do not register or otherwise submit information, information of a general nature is automatically collected. This information (server log files) includes, for example, the type of web browser, the operating system used, the domain name of your Internet service provider, your IP address and the like. They are processed in particular for the following purposes:

To ensure that the website connection is established without problems

To ensure smooth use of our website

To evaluate system security and stability

For other administrative purposes

We do not use your data to draw conclusions about you personally. Information of this kind is statistically evaluated by us, if necessary, to optimize our website and the technology behind it.

Legal Basis

The processing is carried out in accordance with Art. 6 (1) lit. f DSGVO based on our legitimate interest in improving the stability and functionality of our website.

Recipients

Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website.

Storage Period

The data is deleted as soon as it is no longer required for the purpose for which it was collected. This is generally the case for the data used to provide the website when the respective session has ended.

Provision Mandatory or Required

The provision of the aforementioned personal data is neither legally nor contractually required. However, without the IP address, the service and functionality of our website is not guaranteed. In addition, individual services and services may not be available or may be limited. For this reason, an objection is excluded.

Cookies

Type and Purpose of Processing

Like many other websites, we also use so-called “cookies”. Cookies are small text files that are stored on your terminal device (laptop, tablet, smartphone or similar) when you visit our website. This provides us with certain data such as IP address, browser used and operating system. Cookies cannot be used to launch programs or transfer viruses to a computer. Based on the information contained in cookies, we can facilitate your navigation and enable the correct display of our web pages. In no case will the data we collect be passed on to third parties or linked to personal data without your consent.

Of course, you can also view our website without cookies. Internet browsers are regularly set to accept cookies. In general, you can deactivate the use of cookies at any time via your browser settings. Please use the help functions of your Internet browser to find out how to change these settings. Kindly note that individual functions of our website may not work if you have deactivated the use of cookies.

Storage Period and Cookies Used

Insofar as you allow us to use cookies through your browser settings or consent, the following cookies may be used on our websites:

End of session

In as much as these cookies may (also) affect personal data, we will inform you about this in the following sections. You can delete individual cookies or the entire cookie inventory via your browser settings. In addition, you will receive information and instructions on how to delete these cookies or block their storage in advance. Depending on the provider of your browser, you will find the necessary information under the following links:

Mozilla Firefox

Internet Explorer

Google Chrome

Opera

Safari

Contact Form

Type and Purpose of Processing

The data you enter will be stored for individual communication with you. For this purpose, it is necessary to provide a valid e‑mail address and your name. This serves the assignment of the request and the subsequent response to the same. The provision of further data is optional.

Legal Basis

The processing of the data entered in the contact form is based on a legitimate interest (Art. 6 para. 1 lit. f DSGVO). By providing the contact form, we would like to enable you to contact us in an uncomplicated manner. The information you provide will be stored for the purpose of processing the request and for possible follow-up questions. If you contact us to request a quote, the data entered in the contact form is processed to carry out pre-contractual measures (Art. 6 para. 1 lit. b DSGVO).

Recipients

Recipients of the data are, if applicable, order processors.

Storage Period

Data will be deleted no later than 6 months after the request has been processed. If a contractual relationship arises, we are subject to the statutory retention periods under the German Commercial Code (HGB) and will delete your data after these periods have expired.

Provision Mandatory or Required

The provision of your personal data is voluntary. However, we can only process your request if you provide us with your name, e‑mail address and the reason for the request.

Inquiry by E‑Mail

Type and Purpose of Processing

If you contact us by e‑mail, telephone or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for processing your request. We do not disclose this data without your consent.

Legal Basis

The processing of this data is based on Art. 6 (1) lit. b DSGVO if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on your consent (Art. 6 (1) (a) DSGVO) and/or on our legitimate interests (Art. 6 (1) (f) DSGVO), as we have a legitimate interest in the effective processing of requests addressed to us.

Recipients

Recipients of the data may be order processors.

Storage Period

The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g., after we have completed processing your request). Mandatory statutory provisions—in particular statutory retention periods—remain unaffected. If a contractual relationship is established, we are subject to the statutory retention periods under the German Commercial Code (HGB) and delete your data after these periods have expired.

Provision Mandatory or Required

The provision of your personal data is voluntary.

Use of Google Analytics

Nature and Purpose of Processing

This website uses Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA (hereinafter: “Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. However, due to the activation of IP anonymization on these web pages, your IP address will be truncated beforehand by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. The purposes of data processing are to evaluate the use of the website and to compile reports on website activities. Based on the use of the website and the Internet, other related services are then to be provided.

Legal Basis

The processing of the data is based on the user’s consent (Art. 6 para. 1 lit. a DSGVO).

Recipients

The recipient of the data is Google as an order processor. For this purpose, we have concluded the corresponding order processing agreement with Google.

Storage Period

The data is deleted as soon as it is no longer required for our recording purposes.

Third-country Transfer

Google processes your data in the USA and has submitted to the EU_US Privacy Shield https://www.privacyshield.gov/EU-US-Framework.

Provision Mandatory or Required

The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this may result in functional restrictions on the website.

Revocation of Consent

You can prevent the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case you may not be able to use all functions of this website to their full extent. You can also prevent the collection of data generated by the cookie and related to your use of the website (including your IP address) to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link:

Browser Add-On to disable Google Analytics

In addition or as an alternative to the browser add-on, you can prevent tracking by Google Analytics on our pages by clicking this link. This will install an opt-out cookie on your device. This will prevent the collection by Google Analytics for this website and for this browser in the future, as long as the cookie remains installed in your browser.

Profiling

The Google Analytics tracking tool can be used to evaluate the behaviour of visitors to the website and analyse their interests. For this purpose, we create a pseudonymous user profile.

Use of Google Maps

Nature and Purpose of Processing

On this website, we use the services of Google Maps. Google Maps is operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”). This enables us to display interactive maps directly on the website and allows you to use the map function conveniently. You can find more information about data processing by Google in the Google privacy policy. There you can also change your personal data protection settings in the Data Protection Center. Detailed instructions on managing your data in connection with Google products can be found here.

Legal Basis

The legal basis for the integration of Google Maps and the associated data transfer to Google is your consent (Art. 6 para. 1 lit. A DSGVO).

Recipients

We do not collect any personal data, through the integration of Google Maps.

Storage Period

We do not collect any personal data, through the integration of Google Web Fonts. For more information on Google Web Fonts, see https://developers.google.com/fonts/faq and Google’s privacy policy: https://www.google.com/policies/privacy/.

Third-country Transfer

Google processes your data in the USA and has submitted to the EU_US Privacy Shield https://www.privacyshield.gov/EU-US-Framework.

Provision Mandatory or Required

The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this may result in functional restrictions on the website.

Revocation of Consent

If you do not want Google to collect, process or use data about you via our website, you can deactivate JavaScript in your browser settings. In this case, however, you will not be able to use our website or only to a limited extent.

Embedded YouTube Videos

Nature and Purpose of Processing

On some of our websites, we embed YouTube videos. The operator of the corresponding plugins is YouTube, LLC, 901 Cherry Ave, San Bruno, CA 94066, USA (hereinafter “YouTube”). When you visit a page with the YouTube plugin, a connection to YouTube servers is established. In the process, YouTube is informed which pages you are visiting. If you are logged into your YouTube account, YouTube can assign your surfing behaviour to you personally. You can prevent this by logging out of your YouTube account beforehand. If a YouTube video is started, the provider uses cookies that collect information about user behaviour. For more information about the purpose and scope of data collection and processing by YouTube, please refer to the provider’s privacy policy, where you will also find more information about your rights in this regard and settings options to protect your privacy: https://policies.google.com/privacy.

Google processes your data in the USA and has submitted to the EU-US Privacy Shield https://www.privacyshield.gov/EU-US-Framework.

Legal Basis

The legal basis for the integration of YouTube and the associated data transfer to Google is your consent (Art. 6 para. 1 lit. a DSGVO).

Recipients

Calling up YouTube automatically triggers a connection to Google.

Storage Period and Revocation of Consent

Anyone who has deactivated the storage of cookies for the Google ad program will not have to deal with any such cookies when watching YouTube videos. However, YouTube also stores non-personal usage information in other cookies. If you would like to prevent this, you must block the storage of cookies in the browser. For more information on data protection at “YouTube”, see the provider’s privacy policy at: https://www.google.de/intl/de/policies/privacy/.

Third-country Transfer

Google processes your data in the USA and has submitted to the EU_US Privacy Shield https://www.privacyshield.gov/EU-US-Framework.

Provision Mandatory or Required

The provision of your personal data is voluntary, based solely on your consent. If you prevent access, this may result in functional restrictions on the website.

SSL Encryption

To protect the security of your data during transmission, we use state-of-the-art encryption methods (e.g., SSL) via HTTPS.

Commissioned Processors

The following organizations, companies or persons have been commissioned by the operator of this website to process data: Commissioned processors.

Changes to Our Data Protection Policy

We reserve the right to adapt this data protection policy so that it always complies with the current legal requirements or in order to implement changes to our services in the data protection policy, e.g., when introducing new services. The new privacy policy will then apply to your next visit.