COOKIE POLICY

Effective Date: 14 April 2026
Last Updated: 14 April 2026

This Cookie Policy sets out information regarding the use of cookies and similar technologies on the website www.avhos.com, the mobile application, the user dashboard, subdomains and associated digital platforms (collectively referred to as the “Site” or “Platform”) managed by AVHOS Legal Automation Systems (“AVHOS”).

This Policy applies to all natural persons, including Site visitors, members, subscribers, potential users and anyone carrying out any transaction via the Site. Where the processing of personal data via cookies is concerned, this Policy shall be considered in conjunction with the AVHOS Privacy Policy, the Information Notice on the Processing of Personal Data and, where necessary, consent forms.

ARTICLE 1 – PURPOSE AND SCOPE

The purpose of this Cookie Policy is to provide transparent and clear information regarding the types of cookies and similar technologies used by AVHOS, their purposes, legal grounds, retention periods, methods of managing user preferences, potential use of third-party cookies, possibilities of data transfer abroad, and the rights of data subjects.

This Policy is an integral and supplementary part of the AVHOS User, Membership and Platform Terms of Use. In the event of any conflict between the provisions, this Policy shall be interpreted in conjunction with mandatory legislation, specific information notices and explicit consent texts.

ARTICLE 2 – WHAT ARE COOKIES?

Cookies are small text files that websites you visit or digital platforms you use store on your device via your browser. Cookies enable the Site to function, manage sessions, remember your preferences, ensure security, measure performance and enhance the user experience.

In addition to cookies, AVHOS may use pixels, local storage technologies, session identifiers, SDK-based mobile tracking tools and similar technologies. The term “cookie” in this Policy is used to encompass these technologies to the extent appropriate to their nature.

ARTICLE 3 – PURPOSES OF COOKIE USE

AVHOS may use cookies on the Site for the following purposes:

• To provide the basic functions necessary for the Site to operate,
• To provide secure access to the user account and manage sessions,
• Managing identity verification, security, prevention of misuse and information security processes,
• To remember preferences, language selections and user interface settings,
• To safeguard form processing and technical integrity,
• Measuring site performance and conducting error/traffic analyses,
• Improving service quality and enhancing the user experience,
• Conducting analysis, statistics, advertising, marketing, retargeting and personalisation activities where explicit consent has been given,
• Compliance with legal obligations.

ARTICLE 4 – TYPES OF COOKIES

4.1. Cookies by Duration

Session Cookies: These are cookies used during the browser session and deleted when the browser is closed.

Persistent Cookies: These are cookies stored on the device for a specific period and transmitted to the Site by the browser during subsequent visits.

4.2. Cookies by Source

First-Party Cookies: Cookies placed directly by AVHOS.

Third-Party Cookies: These are cookies placed by third parties such as AVHOS’s business partners, technical service providers, analytics providers, security service providers, or advertising/marketing infrastructure providers.

4.3. Cookies by Purpose

Essential Cookies: These are cookies necessary for the platform to function properly, to ensure security, to maintain sessions, to process forms, to perform authentication, and to enable the technical delivery of the service. Without these cookies, certain sections of the Site may not function.

Functionality Cookies: These are cookies that remember the user’s preferences, language selection, interface settings, or similar personalised preferences. The legal nature of these cookies and whether they are essential is assessed separately based on their specific purpose.

Performance and Analytics Cookies: These are cookies used to understand how the Site is used, to analyse errors and traffic, to measure visitor behaviour, and to determine which pages are used most frequently.

Advertising and Marketing Cookies: These are cookies used for commercial purposes such as displaying content, campaigns or advertisements tailored to the user’s interests, measuring advertising performance, and retargeting.

ARTICLE 5 – COOKIES USED

The list of cookies provided below may vary depending on AVHOS’s current technical infrastructure and the services it uses. AVHOS takes care to keep its cookie lists up to date.

5.1. Essential Cookies

These cookies may be used for the basic functions of the Platform to work. If essential cookies are blocked, disruptions may occur in login, session, security, form or basic usage functions.

Note: Certain functional cookies, such as the language preference cookie, may be classified as either mandatory or non-mandatory depending on the specific technical implementation. AVHOS assesses this distinction based on the specific purpose of use and, where necessary, subjects it to user consent via the cookie preference panel.

Legal Basis: Essential cookies may be used on the legal grounds of enabling the technical provision of the service, managing user accounts, ensuring data security, carrying out operations directly related to the conclusion or performance of a contract, and ensuring system security.

Important Notice: If these cookies are blocked via your browser, logging in, secure access, form processing or certain basic platform features may not work.

5.2. Functionality Cookies

Functionality cookies may be used to remember user preferences and personalise the experience. Whilst some of these may be deemed essential in cases of specific technical necessity, functionality cookies that are not essential may be subject to explicit consent.

Legal Basis: Performance of a contract, legitimate interest or explicit consent, depending on the specific purpose of use. Where explicit consent is required, the relevant cookies are disabled by default.

5.3. Analytics and Performance Cookies

Analytics and performance cookies may be used to measure site usage, detect errors and analyse performance. These cookies are disabled by default where explicit consent is required and are only activated with the user’s active consent.

Important Note: Analytics cookies are not essential cookies. In cases where explicit consent is required, these cookies will not be activated unless the user actively consents.

5.4. Advertising, Marketing and Tracking Cookies

Cookies used to measure the performance of advertising campaigns, analyse traffic sources, carry out retargeting, or optimise marketing activities are only activated with explicit consent.

These cookies are only placed with your explicit consent. If you do not give your consent, advertising, marketing and tracking cookies will not be activated.

ARTICLE 6 – DATA THAT MAY BE PROCESSED VIA COOKIES

The data that may be processed via cookies may vary depending on the nature of the cookie used, but may include the following:

• IP address,
• browser type and version,
• device type and operating system information,
• session information,
• date and time of visit,
• browsing activity and page usage information,
• language and preference settings,
• security verification and transaction logs,
• advertising and campaign interaction data,
• traffic source and referral information.

Where such data constitutes personal data, processing activities are carried out in accordance with the applicable data protection legislation.

ARTICLE 7 – LEGAL BASIS FOR THE USE OF COOKIES

Essential cookies may be used for purposes such as the operation of the Site, user account management, session security, the provision of technical services, the execution of form and login processes, and the assurance of information security and system integrity, based on the legal grounds provided for in the relevant legislation.

As regards functionality, performance, analytics, advertising and marketing cookies, each cookie is assessed individually. Cookies requiring explicit consent are not activated without the user’s approval. The user may withdraw the explicit consent they have given at any time via the cookie preference panel, browser settings or other appropriate tools.

Withdrawing explicit consent does not automatically render actions carried out prior to the withdrawal unlawful; however, the use of cookies based on explicit consent ceases following the withdrawal.

ARTICLE 8 – MANAGING COOKIE PREFERENCES

Upon first accessing the Site, the user may specify, accept, reject or subsequently change their preferences regarding non-essential cookies via the cookie preference panel.

Via the cookie preference panel, the user may:

• accept or reject analytics cookies,
• accept or reject marketing cookies,
• withdraw previously given explicit consent.

The user can also manage cookies via their browser settings. For common browsers, cookie management is generally carried out via the following menus:

• Chrome: Settings > Privacy and Security > Cookies and other site data
• Firefox: Settings > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Manage Cookies
• Edge: Settings > Cookies and site permissions

You can delete cookies by using your browser’s “Clear browsing data” or similar feature. However, if essential cookies are deleted or blocked:

• your session may be closed,
• you may need to log in again,
• some platform features may not work,
• your user experience may be negatively affected.

ARTICLE 9 – THIRD-PARTY COOKIES

Cookies belonging to third-party service providers offering analytics, performance measurement, advertising management, security or integration services on the Site may be used. Technical control over these cookies may also be subject to the relevant third parties’ own systems and policies.

Examples of third-party cookie providers that AVHOS may use include:

• Supabase / Authentication infrastructure: Essential cookies for authentication and session management,
• Cloudflare / CDN / Security Service: Security cookies for load balancing, bot detection, traffic security and DDoS protection,
• Google Analytics: Analytical cookies for usage analysis and performance measurement,
• Hotjar [if active]: Performance/analytical cookies for behavioural analysis and user experience measurement,
• Sourcebuster: Cookies for traffic source measurement, campaign and marketing performance tracking,
• Other services [if applicable]: Live support, A/B testing, marketing automation, error tracking and similar tools.

Where relevant third-party services are enabled, cookies associated with these services are displayed in separate categories where necessary, and explicit consent is obtained from the user where legal requirements do not apply.

To manage third-party cookies:

• the cookie preference panel,
• browser settings,
• the opt-out or preference tools provided by the relevant service provider

.

ARTICLE 10 – COOKIE RETENTION PERIOD

The retention period of cookies may vary depending on the type of cookie, its technical characteristics, the purpose of use, and the infrastructure of the relevant service provider. Session cookies expire when the browser is closed, whilst persistent cookies may be stored on the device for a specific period.

AVHOS takes care to determine the retention period of cookies in a manner that is limited to the purpose of use, necessary and proportionate. Technical necessities, security requirements and obligations arising from legislation are reserved.

ARTICLE 11 – PROTECTION AND SECURITY OF PERSONAL DATA

With regard to personal data processed via cookies, AVHOS exercises reasonable care to prevent unlawful processing and access, to ensure the security of the data, and to take the necessary technical and organisational measures.

However, due to the nature of the internet, an absolute guarantee of security cannot be provided. It may not always be possible to completely eliminate all risks arising from unauthorised access, security risks originating from third-party service providers, infrastructure issues or cyber attacks.

For more detailed information regarding personal data processed in connection with cookies, please refer to the AVHOS Privacy Policy and the Information Notice on the Processing of Personal Data.

ARTICLE 12 – TRANSFER OF DATA ABROAD

Some data collected via cookies may be transferred abroad due to the third-party service providers or technical infrastructure elements used being located abroad.

This transfer is carried out solely in accordance with applicable legislation and subject to the relevant legal conditions being met. Where explicit consent is required, cross-border transfers will not be carried out without the user’s explicit consent. Depending on the specific circumstances, the appropriate transfer mechanism—such as an adequacy decision, appropriate safeguards, a standard contractual clause, or explicit consent—will be applied in accordance with the legislation.

You can find more detailed information on cross-border data transfers in the texts below:

• KVKK Information Notice,
• KVKK Consent Statement,
• Privacy Policy.

ARTICLE 13 – RIGHTS OF THE DATA SUBJECT

With regard to your personal data processed via cookies, you may exercise the following rights by contacting AVHOS under the applicable data protection legislation:

• to find out whether personal data has been processed,
• to request information regarding the processing of personal data if it has been processed,
• to find out the purpose of the processing and whether it is being used in accordance with that purpose,
• to find out to which third parties the data has been transferred within or outside the country,
• to request the rectification of incomplete or inaccurate data,
• to request the erasure or destruction of the data,
• to request that the third parties to whom the data has been transferred be informed of any corrections or erasures made,
• objecting to a decision made solely through automated processing that adversely affects you,
• to claim compensation for damages resulting from unlawful processing.

ARTICLE 14 – CHANGES TO THE POLICY

AVHOS may update this Cookie Policy at any time in accordance with legislative changes, decisions of the Board, technical requirements, updates to the Site’s infrastructure, changes in cookie usage, or company policies.

The updated text shall take effect from the date of publication on the Site, together with the effective date. Significant changes may be additionally notified via email or in-platform notifications where deemed necessary.

The User’s continued use of the Site may be interpreted as an acknowledgement of the current policy text, subject to mandatory statutory provisions; however, an active consent mechanism will be applied separately for new cookies requiring explicit consent.

ARTICLE 15 – CONTACT AND ENQUIRIES

You may use the following contact channels for any questions, requests or applications regarding cookies under the KVKK:

Email: info@avhos.com
Address: Kartaltepe Mah. 1. Malazgirt Cad. No:6/2 Küçükçekmece/İstanbul
Telephone: 0850 885 08 44

Applications under Article 11 of the KVKK will be processed within the timeframes stipulated by law and, as a rule, within a maximum of 30 days.

ARTICLE 16 – ENTRY INTO FORCE

This Cookie Policy shall enter into force on 14 April 2026 and shall take effect from the moment it is published on the Website.