Legal

Privacy Policy

This Privacy Policy explains how ICBC Turkey collects, uses, discloses, and safeguards information in connection with our website and the risk-management and treasury advisory services we provide. Please read this policy carefully. This is a general template and should be reviewed and adapted to reflect your actual data practices and applicable law before publication.

Last updated: [Insert Date]

1. Introduction

ICBC Turkey ("ICBC Turkey", "we", "us", or "our") respects the privacy of visitors to our website and of the individuals and organizations who engage with our services. This Privacy Policy describes the categories of information we may collect, how that information is used and shared, and the choices available to you regarding our handling of your information.

By accessing our website or engaging our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described here, we recommend that you do not use our website or services.

2. Information We Collect

We may collect the following categories of information, depending on how you interact with us:

  • Contact information — such as name, business email address, telephone number, company name, and job title, typically submitted through a contact or inquiry form.
  • Business and engagement information — details you provide in connection with a request for a technical brief, consultation, or proposal, including information about your organization's risk-management or treasury needs.
  • Technical and usage information — such as IP address, browser type, device information, referring pages, and general usage patterns collected automatically through standard web server logs and similar technologies when you visit our website.
  • Correspondence — records of communications between you and ICBC Turkey, including emails and any documents exchanged during the course of an inquiry or engagement.

We do not knowingly collect sensitive personal information, such as health data, biometric data, or government identification numbers, through our website.

3. How We Use Information

We use the information we collect for purposes that may include:

  • Responding to inquiries and providing requested materials, such as technical briefs or service information;
  • Evaluating and, where applicable, delivering the services you have requested;
  • Maintaining and improving the functionality, security, and performance of our website;
  • Communicating with you about our services, including administrative notices and updates you have requested;
  • Complying with applicable legal, regulatory, or contractual obligations;
  • Detecting, investigating, and preventing fraudulent activity, security incidents, or misuse of our website.

4. Legal Basis for Processing

Where applicable law requires a legal basis for processing personal information, we generally rely on one or more of the following: your consent, the necessity of processing to perform a contract or take steps toward entering into one at your request, our legitimate business interests in operating and improving our services, and compliance with legal obligations. Where processing is based on consent, you may withdraw that consent at any time by contacting us using the details on our Contact page.

5. Sharing of Information

ICBC Turkey does not sell personal information. We may share information in the following limited circumstances:

  • Service providers — third parties who perform functions on our behalf, such as website hosting, analytics, or communication tools, subject to confidentiality obligations.
  • Professional advisors — including legal, financial, or compliance advisors, where necessary for the operation of our business.
  • Legal and regulatory disclosures — where required to comply with applicable law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of ICBC Turkey, our clients, or others.
  • Business transfers — in connection with a merger, acquisition, reorganization, or sale of assets, subject to appropriate confidentiality safeguards.

6. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law, or is necessary to establish, exercise, or defend legal claims. When information is no longer needed, we take reasonable steps to delete, anonymize, or securely dispose of it.

7. Data Security

We implement reasonable administrative, technical, and organizational measures designed to protect information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security of information transmitted to or stored by us.

8. Cookies and Similar Technologies

Our website may use cookies and similar tracking technologies to support core functionality, remember preferences, and understand how visitors interact with our site. You can typically control or disable cookies through your browser settings; please note that disabling certain cookies may affect the functionality of our website.

9. Your Rights

Depending on your jurisdiction, you may have certain rights with respect to your personal information, which may include the right to:

  • Request access to the personal information we hold about you;
  • Request correction of inaccurate or incomplete information;
  • Request deletion of your personal information, subject to certain exceptions;
  • Object to or restrict certain processing activities;
  • Request a copy of your information in a portable format, where applicable;
  • Withdraw consent where processing is based on consent.

To exercise any of these rights, please contact us through the details provided on our Contact page. We may need to verify your identity before responding to certain requests.

10. International Data Transfers

ICBC Turkey operates in Turkey, and information we collect may be processed and stored within Turkey or, where applicable service providers require it, in other jurisdictions. Where personal information is transferred internationally, we aim to ensure appropriate safeguards are in place consistent with applicable data protection law.

11. Children's Privacy

Our website and services are intended for business use by adults and are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a minor, please contact us so we can take appropriate action.

12. Third-Party Links

Our website may contain links to third-party websites or resources. This Privacy Policy does not apply to those third-party sites, and we are not responsible for their content or privacy practices. We encourage you to review the privacy policies of any third-party sites you visit.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date at the top of this page. We encourage you to review this Privacy Policy periodically.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please reach out via the contact details provided on our Contact page.