The Privacy Policy


We, TPC Danışmanlık Koçluk Liderlik ve Eğitim Limited Şirketi (“TPC”), are committed to protecting and respecting your privacy. We are responsible for protecting your personal information as a “data controller” under the Personal Data Protection Law numbered 6698 (“Law”).


This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.


1.     What information do we collect?


The personal information we collect are as follows:


  • name-surname (identity data),
  • Contact number (contact data)
  • e-mail address (contact data),
  • the company you work for and subject and message (other data).


2.     How do we collect information?


We obtain personal information from you when you enquire about our activities, register with us, send or receive an email, ask a question or otherwise provide us with personal information. We may also receive information about you from third parties, for example from our service providers or from a friend who wants to tell you about our websites or the activities we carry out.


We also gather general information about the use of our website, such as which pages users visit most often and which services, events or facilities are of most interest. We may also track which pages users visit when they click on links in emails. We may use this information to personalise the way our websites are presented when users visit them, to make improvements to our websites and to ensure we provide the best service for users.


Wherever possible we use aggregated or anonymous information which does not identify individual visitors to our websites.


3.     Why do we collect this information?


We collect this information for the purposes described in section 4. The lawful basis for which we process your information is:


  • Your explicit consent (Art. 5/1 of the Law);
  • Compulsory processing of data for our legitimate interests without prejudice to your fundamental rights and freedoms (Art. 5/2f of the Law).


4.     How do we use this information?


We will use your personal information:


  • to provide you with the services, products or information you have requested;
  • to create an account for you if you register with us;
  • to contact you about services we offer and resources we provide; and
  • for administration purposes.


As part of this, we may analyse the personal information we collect to create a profile of your interests and preferences so that we can contact you in the most appropriate way and with the most relevant information.


If you enter your contact details in one of our online registration forms, we may use this information to contact you even if you do not “send” or “submit” the form. We will only do this to see if we can help with any problems you might be experiencing with the form or with our websites.


We will only use your personal information for electronic marketing purposes if we have your consent. If you agree to us providing you with marketing information, you can always opt out at a later date. If you do not wish to receive such messages please let us know by contacting us using our Contact Form.


5.     Cookies


Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy (section 10).


6.     Your choices


You have a choice about whether you want to receive information about our services. We will not use your personal information for marketing purposes or share your information with any third party if you have indicated that you do not wish to be contacted in this manner. You can change your marketing preferences at any time by contacting us using our Contact Form. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.  Please check these policies before you submit any personal data to these websites.


7.     Will we disclose the information we collect to outside parties?


We may pass your information to our data processors, agents and associated organisations for the purpose of providing services to you and for the other purposes listed at section 4 above. Where we use data processors we will make sure there are appropriate controls in place.


We may also need to disclose your information if required by law (for example to government bodies and law enforcement agencies) or if we have your permission to do so.


We will not sell any information about you or your web browsing activity.


We may transfer your information to any of the countries where we hold an office. We do this by complying Article 9 of the Law.


8.     How long do we keep your information for?


We keep your information for no longer than is necessary, as required by data protection law. We will retain your information for any period required by law, for example for compliance with local tax requirements. Where we are not under a legal obligation to retain your information, we will determine what is necessary by reference to the lawful basis for processing set out above and our legitimate interests.


If you have any questions about how long we keep your information, please write to us using our Contact Form.


9.     How do we protect personal information?


We take appropriate technical and organisational measures to ensure that the information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. We protect your information in accordance with our Data Protection Policy.


10.  Information About Our Use of Cookies


Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.


A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree.


Cookies contain information that is transferred to your computer’s hard drive.


You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.


Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies may include analytical/performance cookies or targeting cookies.


We use the following cookies:


  • Google Analytics (analytical / performance cookie) – used to estimate our audience size and usage pattern.
  • Google Adwords (analytical / performance cookie) – used to track sales and data capture arising from use of Google Adwords advertising
  • Facebook (analytical / performance and targeting cookie)- used to track sales and data capture arising from use of Facebook advertising, and show target ads on Facebook to site visitors.


Strictly necessary cookies


These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.


Analytical/performance cookies


They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.


Functionality cookies


These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).


Targeting cookies


These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.


11.  Your rights


Provided that the circumstances stipulated under Article 28 of the Law titled “Exceptions” are reserved, we would like to remind you that you have the right to apply to TPC within the framework of Article 11 of the Law to, (a) learn whether or not your personal data have been processed, (b) request further information, if your personal data have been processed, (c) learn the purpose of processing your personal data and whether they are used in line with such purpose or not, (d) learn the third party recipients to whom your personal data have been transferred within the country or abroad, (e) request rectification of your personal data if processed incompletely or inaccurately, (f) request erasure or destruction of your personal data as per the conditions set forth in Article 7 of the Law, (g) request the notification of the third parties, to whom your personal data have been transferred to, with respect to the transactions made as per sub-clauses (e) and (f) above, (h) object to any negative consequence resulting from the analysis of your personal data exclusively by automated systems, (i) claim rectification, in writing, of the damages that you have suffered due to unlawful processing of your personal data, if any.


12.  Acceptable use


This acceptable use policy sets out the terms between you and us under which you may access the Site. This acceptable use policy applies to all users of, and visitors to, the Site.


Your use of our site means that you accept, and agree to abide by, all the policies in this acceptable use policy, which supplement our Terms.


13.  Prohibited uses


You may use our site only for lawful purposes.  You may not use our site:


  • In any way that breaches any applicable local, national or international law or regulation.
  • In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.
  • For the purpose of harming or attempting to harm minors in any way.
  • To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards at 6.3 below.
  • To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
  • To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.


You also agree:


  • Not to reproduce, duplicate, copy or re-sell any part of our site in contravention of the provisions of our terms of website use.


  • Not to access without authority, interfere with, damage or disrupt:
    • any part of our site;
    • any equipment or network on which our site is stored;
    • any software used in the provision of our site; or
    • any equipment or network or software owned or used by any third party.


14.  Interactive services


We may from time to time provide interactive services on our site, including, without limitation:


  • a facility to comment on our blog posts; and
  • interactive webinars.


Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).


We will do our best to assess any possible risks for users (and in particular, for children) from third parties when they use any interactive service provided on our site, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in the light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our site, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.


The use of any of our interactive services by a minor is subject to the consent of their parent or guardian. We advise parents who permit their children to use an interactive service that it is important that they communicate with their children about their safety online, as moderation is not foolproof. Minors who are using any interactive service should be made aware of the potential risks to them.


Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.


15.  Content standards


These content standards apply to any and all material which you contribute to our site ( contributions ), and to any interactive services associated with it.


You must comply with the spirit of the following standards as well as the letter. The standards apply to each part of any contribution as well as to its whole.


Contributions must:

  • Be accurate (where they state facts).
  • Be genuinely held (where they state opinions).
  • Comply with applicable law in the Netherlands and in any country from which they are posted.


Contributions must not:

Contain any material which is defamatory of any person.

  • Contain any material which is obscene, offensive, hateful or inflammatory.
  • Promote sexually explicit material.
  • Promote violence.
  • Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.
  • Infringe any copyright, database right or trade mark of any other person.
  • Be likely to deceive any person.
  • Be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence.
  • Promote any illegal activity.
  • Be threatening, abuse or invade another’s privacy, or cause annoyance, inconvenience or needless anxiety.
  • Be likely to harass, upset, embarrass, alarm or annoy any other person.
  • Be used to impersonate any person, or to misrepresent your identity or affiliation with any person.
  • Give the impression that they emanate from us, if this is not the case.
  • Advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse.


16.  Suspension and termination


We will determine, in our discretion, whether there has been a breach of this acceptable use policy through your use of our site.  When a breach of this policy has occurred, we may take such action as we deem appropriate.


  • Failure to comply with this acceptable use policy constitutes a material breach of the terms of use upon which you are permitted to use our site, and may result in our taking all or any of the following actions:
  • Immediate, temporary or permanent withdrawal of your right to use our site.
  • Immediate, temporary or permanent removal of any posting or material uploaded by you to our site.
  • Issue of a warning to you.
  • Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
  • Further legal action against you.
  • Disclosure of such information to law enforcement authorities as we reasonably feel is necessary.
  • We exclude liability for actions taken in response to breaches of this acceptable use policy.  The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.


17.  Changes to the acceptable use policy


We may revise this acceptable use policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this acceptable use policy may also be superseded by provisions or notices published elsewhere on our site.


In accordance with the Law, the requests you will send to TPC must be in writing. To ensure this, with documents proving your identification, you may send your request containing your explanations about the right you want to use in writing to the e-mail address of ozlem.rodoslu@tpcleadership.com and/or personally submit a petition to TPC’s headquarters at Büyükdere Caddesi, Kanyon Ofis Binası No: 185, 1010Y, Levent, Şişli, İstanbul; or submit your application through notary public or by a registered letter with return receipt. The requests stated in your application shall, depending on the content thereof, be concluded as soon as possible and within 30 (thirty) days at the latest.

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