Cookie Policy

This Cookie Policy has been prepared by SteelOrbis Elektronik Pazaryeri A.Ş. ("Company") to explain to visitors of our website at www.steelorbis.com and users of our products and services which cookies are used on the website and how users can manage their preferences in this regard. This policy has been prepared in compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the ePrivacy Directive 2002/58/EC, and applicable national implementing legislation.

For more detailed information regarding the processing of your personal data by the Company, we recommend that you review our Data Privacy Notice.

1. WHAT IS A COOKIE?

Cookies are small text files placed on your device by web page servers. They contain information that can be read later by the web servers belonging to the domain that sent them to you. Cookies do not directly contain personal data such as name, gender, or address; however, cookie identifiers, when combined with other information, may lead to the identification of individuals.

As stated in GDPR Recital 30, natural persons may be associated with online identifiers provided by their devices, such as cookie identifiers and internet protocol addresses. When combined with unique identifiers and other information received by servers, these may be used to create profiles of natural persons and identify them.

2. DOES THE COMPANY USE COOKIES?

Yes. The Company uses cookies and similar technologies to ensure that everyone using the website has the best possible experience.

3. PURPOSES OF COOKIE USAGE

The main purposes of using cookies on our website are listed below:

• To improve the services we offer by enhancing the functionality and performance of our website and applications.
• To remember your preferences and personalize your user experience during your visit (language preference, font size, etc.).
• To improve our website, offer new features and conduct performance analysis.
• To determine usage statistics such as where you connected from, what content you viewed, and the duration of your visit.
• To ensure the legal and commercial security of the website for you and our Company.

4. TYPES OF COOKIES

In accordance with the GDPR and the ePrivacy Directive, the cookies used on our website are classified into the following categories:

Strictly Necessary Cookies	These cookies are essential for our website to function properly. Pursuant to Article 5(3) of the ePrivacy Directive, strictly necessary cookies are exempt from the consent requirement. They are used for purposes such as identity verification, session management, and security and are not used for any marketing purposes.
Functional Cookies	These cookies enable our website to remember the preferences of users (language, region, font size, etc.). Not allowing these cookies may prevent personalized features from functioning. Consent is obtained under Article 6(1)(a) GDPR.
Performance and Analytics Cookies	These cookies help improve our website by collecting anonymous statistical information about how visitors use the site. First-party analytics cookies that are limited to performance measurement purposes, do not enable cross-site tracking, and only produce anonymous statistics may qualify as strictly necessary under the ePrivacy Directive in certain jurisdictions. Consent is obtained in accordance with Article 5(3) ePrivacy Directive and Article 6(1)(a) GDPR.
Targeting and Advertising Cookies	These cookies are used to promote products and services, to show you relevant and personalized advertisements, and to measure the effectiveness of advertising campaigns. Your explicit consent is obtained for these cookies pursuant to Article 6(1)(a) GDPR and Article 5(3) of the ePrivacy Directive.

5. NON-COOKIE TRACKING TECHNOLOGIES: TRAFFIC SOURCE DETECTION

When an application form is submitted, only the traffic source information (e.g., organic, referral, paid) is added to the application record. This information is used solely to measure the effectiveness of our campaigns and marketing activities on the basis of Article 6(1)(f) GDPR — legitimate interest. The legitimate interest pursued is the measurement of marketing performance and campaign optimization, which we consider does not override the fundamental rights and freedoms of the data subjects concerned.

In this process:

• No persistent identifiers (such as cookie ID, device ID, or user ID) are generated;
• IP addresses are not stored or are anonymized;
• Traffic source information may be processed together with the personal data provided in the application form, but only for the purposes of evaluating the application and measuring marketing performance.
• No cross-site tracking is conducted.

Right to object: Pursuant to Article 21 GDPR, you have the right to object to the processing of your personal data based on legitimate interest at any time. To exercise this right, please contact us. Upon receipt of your objection, we shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

Legitimate Interest Assessment (LIA): We have conducted a balancing test in accordance with Article 6(1)(f) GDPR to ensure that our legitimate interest in measuring marketing performance does not override your fundamental rights and freedoms. A copy of the LIA is available upon request.

6. CONSENT MANAGEMENT AND COOKIE PREFERENCES

In accordance with the GDPR and the ePrivacy Directive, your consent is required for all cookies except strictly necessary cookies. You can set your preferences through the cookie consent panel that appears when you first visit our website. To comply with the regulations governing cookies, we:

• Receive your consent before using any cookies except strictly necessary cookies;
• Provide accurate and specific information about the data each cookie tracks and its purpose in plain language before consent is received;
• Document and store the consent received;
• Allow you to access our service even if you refuse certain cookies;
• Make it as easy for you to withdraw your consent as it was to give it.

You can also manage cookies through your browser settings:

• Firefox: Manage privacy and cookie preferences through browser settings.
• Chrome: Manage cookies through the Privacy and Security section of browser settings.
• Microsoft Edge: Manage privacy and cookie preferences through browser settings.
• Safari: Manage cookies through the Privacy section of browser settings.

For more information about cookies, please visit www.aboutcookies.org

7. INTERNATIONAL DATA TRANSFERS

Where personal data collected through cookies or similar technologies is transferred outside the European Economic Area (EEA), such transfers are conducted in accordance with Chapter V of the GDPR (Articles 44–49).

8. COOKIES USED ON OUR WEBSITE

Detailed information about the cookies used on our website is provided in the table below. We periodically update this list.

Cookie Name	Cookie Type	Purpose	Retention
Doubleclick / IDE	Persistent	Google Ads Retargeting	6 Months
Facebook / fr	Persistent	Meta Ads Ad Optimisation	90 days
Facebook / sb	Persistent	Targeting / Analysis	90 days
Google / 1P_JAR	Persistent	Statistical data and conversion tracking	1 month
Google / NID	Persistent	User preference tracking (language, search options)	6 months
Google / __Secure-3PAPISID	Persistent	User profiling and ad targeting	2 years
_ga / ga*	Persistent	Visitor identification (Analytics)	2 years
_gid	Persistent	24-hour session separation	24 hours
_gcl_au	Persistent	Conversion tracking	3 months
_gads	Persistent	Ad frequency	13 months
_fbp	Persistent	Retargeting (Meta)	90 days
_clck	Persistent	User ID (Clarity)	1 year
_clsk	Persistent	Session link (Clarity)	1 day
li_fat*, li_s*	Persistent	Conversion and campaign analysis (LinkedIn)	90 days
_li_gc	Persistent	Cookie consent record (LinkedIn)	2 years
bcookie / bscookie	Persistent	Browser identification / security (LinkedIn)	2 years

9. YOUR RIGHTS UNDER THE GDPR

Under the GDPR, you have the following rights in relation to the processing of your personal data:

• Right of access — You have the right to obtain confirmation as to whether your personal data is being processed and access to such data;
• Right to rectification— You have the right to have inaccurate personal data corrected;
• Right to erasure— You have the right to request deletion of your personal data under certain conditions;
• Right to restriction— You have the right to request restriction of processing under certain conditions;
• Right to data portability— You have the right to receive your personal data in a structured, commonly used format;
• Right to object — You have the right to object to processing based on legitimate interest, including processing for direct marketing purposes;
• Right to withdraw consent— Where processing is based on consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, please contact us at steelorbis@hs01.kep.tr or info@steelorbis.com. You also have the right to lodge a complaint with supervisory authority.

10. CHANGES TO THE COOKIE POLICY

Our Company may make changes to this Cookie Policy at any time. These changes will take effect immediately upon the revised Cookie Policy being uploaded to the website.

Last update: 01 March 2026
Disclaimer: This policy has been prepared in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR), the ePrivacy Directive 2002/58/EC, and applicable national implementing legislation. It may need to be updated in light of legislative changes, new regulatory guidance, or the forthcoming ePrivacy Regulation.