PRIVACY AND COOKIE POLICY

This English version is provided for information. In case of any discrepancy, the Turkish version prevails.

1. What this policy covers

1.1. This policy explains the general principles that govern how Trigonium İlaç Anonim Şirketi (ODORGO), which operates the odorgo.com.tr website (the “Site”), handles personal data, and the cookies used on the Site. In this document, “we” means Trigonium İlaç Anonim Şirketi and “you” means the person using the Site. “KVKK” means Personal Data Protection Law No. 6698 (6698 sayılı Kişisel Verilerin Korunması Kanunu) and the “Board” means the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu).

1.2. Which of your personal data are processed in the membership, order, payment, delivery, return, customer service, product review and commercial electronic message processes, for which purposes and on which legal grounds, to whom they are transferred, how long they are kept and your rights are explained in the Customer Personal Data Privacy Notice published on the Site. That information is not repeated here.

1.3. Articles 4 to 9 of this policy are the privacy notice under Article 10 of the KVKK for personal data processed through cookies and similar technologies on the Site.

1.4. Reading this policy or using the Site does not mean that you give explicit consent to the processing of your personal data. Your consent for cookies is obtained separately through the cookie preferences panel described in Article 8.

2. Data controller

  • Trade name: Trigonium İlaç Anonim Şirketi (ODORGO)
  • Address: Esentepe Mah. Büyükdere Cad. Loft Residance No: 201 İç Kapı No: 40 Şişli/İstanbul
  • E-mail: [email protected]
  • Phone: +90 532 721 77 54

Our other company details are in Article 2 of the Customer Personal Data Privacy Notice.

3. General principles

3.1. We process your personal data in accordance with the principles in Article 4 of the KVKK:

  • (a) lawfully and fairly,
  • (b) accurately and, where necessary, kept up to date,
  • (c) for specified, explicit and legitimate purposes,
  • (ç) in a manner that is relevant, limited and proportionate to the purposes for which they are processed,
  • (d) retained for the period laid down in the legislation or required for the purpose for which they are processed.

3.2. We do not sell or rent your personal data. Data transfers made for the provision of services and for the other purposes explained in this policy or in the Customer Personal Data Privacy Notice are set out in the relevant document.

3.3. We take the necessary technical and organisational measures under Article 12 of the KVKK to prevent unlawful processing of and unlawful access to your personal data and to protect your data. These measures include:

  • (a) limiting access to data to persons authorised by the nature of their work,
  • (b) encrypting the connection between the Site and your browser,
  • (c) not storing card details ourselves; card payments are taken on the payment institution’s payment page,
  • (ç) requiring the parties from whom we receive services to comply with confidentiality and data security obligations.

3.4. If your personal data are obtained by others through unlawful means, we will notify the Board without delay and at the latest within 72 hours of becoming aware of it, in accordance with Article 12 of the KVKK and the Board’s decisions; and we will notify the affected persons as soon as reasonably possible after they have been identified.

3.5. We do not ask you for health data or other special categories of personal data. Details are in Article 3.2 of the Customer Personal Data Privacy Notice.

4. What cookies are

4.1. Cookies are small text files saved to your browser or device when you visit a website. In this policy, “cookie” also covers similar technologies used for the same purposes, such as pixels, tags and the browser’s local storage.

4.2. By duration, cookies are of two types: session cookies are deleted when you close your browser; persistent cookies remain on your device for a set period.

4.3. By who places them, cookies are also of two types: first-party cookies are written to the Site’s own domain; third-party cookies are written to the domains of the providers of the tools we use on the Site.

5. Cookies and tools used on the Site

5.1. The tables below list the cookies and tools used on the Site by category. The durations show the longest time a cookie can remain in your browser. You may delete cookies earlier. The duration of a cookie does not show how long the provider keeps the data sent to it through that cookie; that period is subject to the provider’s own policy.

5.2. Strictly necessary cookies. These are required for the Site to work and to be secure; your consent is not sought. If you block them in your browser, some parts of the Site may not work.

Tool and providerCookie / storagePurposeDuration
ikas (our e-commerce infrastructure provider)ikas_session_id (local storage)Keeping your session and basket, making the order steps workRemains in your browser until you delete it
ikas (our e-commerce infrastructure provider)ikas_visitor_id, ikas_journey_id (local storage)Enabling the e-commerce infrastructure to recognise your visit and the steps of your visitRemains in your browser until you delete it
Cloudflare (infrastructure security)__cf_bmDistinguishing malicious automated traffic (bots)30 minutes
Cloudflare (infrastructure security)_cfuvidSite security and traffic managementSession
CookieYes (cookie preferences panel)cookieyes-consentRemembering your cookie preference1 year

At the payment step, the payment institution may also use its own security cookies. Information about these cookies is in the payment institution’s own privacy notice.

5.3. Analytics cookies. These are used to measure how many people visit the Site, which pages are viewed, where visitors come from and how the Site performs. They are written only if you give consent.

Tool and providerCookie / storageDuration
Google Analytics 4, Google group of companies_ga, _ga_PK804LX8SK400 days
Yandex Metrica, Yandex group of companies (Russian Federation)_ym_uid, _ym_d1 year
Yandex Metrica_ym_isad1 day
Yandex Metrica_ym_visorc30 minutes
Yandex MetricaLocal storage entries beginning with _ymRemain in your browser until you delete them
Yandex Metrica (on Yandex domains)yandexuid, yuidss, i, bh400 days
Yandex Metrica (on Yandex domains)ymex1 year

5.4. Marketing cookies. These are used to measure the effect of our advertising (for example, whether a purchase was made on the Site after an advertisement was seen), to show you advertisements relevant to your interests and to show advertisements on other platforms to people who have visited the Site. They are written only if you give consent.

Tool and providerCookie / storageDuration
Google Ads conversion and remarketing tag, Google group of companies_gcl_au90 days
Google Ads_gcl_ls (local storage)Remains in your browser until you delete it
Google Ads (on Google domains)IDE400 days
Google Ads (on Google domains)test_cookie15 minutes
Meta Pixel (Facebook and Instagram advertising), Meta group of companies_fbp90 days
TikTok Pixel, TikTok group of companies_ttp, _tt_enable_cookie, ttcsid390 days
X (Twitter) Pixel, X Corp. (United States of America)_twpid, _twsid390 days
X (Twitter) Pixel (on X domains)guest_id, guest_id_ads, guest_id_marketing, personalization_id, muc_ads400 days
Reddit Pixel, Reddit, Inc. (United States of America)_rdt_uuid90 days
OpenAI advertising pixel (ChatGPT ads), OpenAI group of companies__obref1 year

5.5. Tag management. Google Tag Manager is used on the Site. This tool does not measure anything itself; it manages the loading of the tools above on the Site. Your cookie preferences are applied through the cookie preferences panel and the tag settings.

5.6. WhatsApp link. When you click the WhatsApp link on the Site, you are redirected to the WhatsApp application or website. Any further steps are subject to WhatsApp’s own terms. How your data are processed when you write to us on WhatsApp is explained in the Customer Personal Data Privacy Notice.

6. Data processed through cookies and legal grounds

6.1. The following data are processed through cookies: cookie and device identifiers, browser and device information, IP (Internet Protocol) address and the approximate location derived from it, the pages you visit, your clicks, the source or advertisement through which you arrived at the Site, actions on the Site such as adding to basket and purchases, and the amounts of those actions. Each tool processes only the part of these data needed for its own purpose.

6.2. These data are collected automatically through cookies placed in your browser and tags added to the Site.

6.3. Legal grounds:

  • (a) Strictly necessary cookies used to make the basket, the session and the order steps work: being directly related to the establishment or performance of a contract with you (KVKK Article 5/2-c).
  • (b) Strictly necessary cookies used for Site security and for remembering your cookie preference: our legitimate interest, provided that it does not harm your fundamental rights and freedoms (KVKK Article 5/2-f).
  • (c) Analytics and marketing cookies: your explicit consent (KVKK Article 5/1).

6.4. The data collected through analytics and marketing cookies are transferred to the providers of the tools listed in Articles 5.3 and 5.4. Some of these providers may also process the data under their own privacy policies to provide and improve their own services.

7. Transfers abroad

7.1. The servers of some of the providers listed in Articles 5.2 to 5.4 and Article 8.6 are located abroad. Data collected through these tools may be transferred to the United States of America, European Union countries, the United Kingdom (for CookieYes), the Russian Federation (for Yandex) and other countries where these providers operate.

7.2. If you do not consent to analytics and marketing cookies, these cookies are not written and no data are transferred through these cookies.

8. Managing your cookie preferences

8.1. The cookie preferences panel opens on your first visit to the Site. The panel offers “Accept All”, “Reject All” and “Manage Preferences” options with equal ease. Analytics and marketing cookies are not written until you make a choice.

8.2. With “Manage Preferences” you can give or refuse consent separately for the analytics and marketing categories.

8.3. Rejecting cookies does not prevent you from using the Site, becoming a member or placing an order.

8.4. You can change your preferences and withdraw your consent at any time using the cookie icon in the corner of the page. When you withdraw your consent, further use of cookies based on your explicit consent in the relevant category is stopped. Withdrawal does not retroactively affect the lawfulness of earlier processing. Data for which the reason for processing no longer exists are deleted, destroyed or anonymised in accordance with the legislation; you may also exercise your rights in Article 9 at any time.

8.5. Your preference is remembered for 1 year. At the end of that period, or if there is a material change in the purposes of the cookies, their providers or the scope of your consent, you will be asked for your preference again.

8.6. So that we can prove your preference, a consent record is kept by CookieYes Limited (United Kingdom), the provider of the cookie preferences panel, on Amazon Web Services cloud infrastructure. This record contains a randomly generated consent number, your masked IP address, country information, the preference you gave and the date and time. This record is kept, for the purpose of proving your preference and protecting our rights in a possible dispute, on the legal ground that processing is necessary for the establishment, exercise or protection of a right (KVKK Article 5/2-e), for as long as necessary for that purpose.

8.7. You can also delete or block cookies in your browser settings. If you block strictly necessary cookies, some parts of the Site may not work.

9. Your rights and applications

9.1. Your rights under Article 11 of the KVKK and the ways to apply to exercise them are set out in Articles 10 and 11 of the Customer Personal Data Privacy Notice. You may apply through the same channels for your data processed through cookies.

9.2. You may withdraw your consent to cookies as described in Article 8.4 without needing to make an application.

10. Links to other websites

The Site may contain links to other websites. The privacy practices of those websites are not under our control; their own policies apply.

11. Changes

We may update this policy due to changes in legislation, changes in the tools we use on the Site or changes in our data processing activities. The current text is published on this page together with the last updated date. If there is a material change affecting the scope of your consent, we will ask for your preference again in the cookie preferences panel.

Last updated: 27.09.2026