Cookie Policy

1. What is a cookie?

Cookies are small text files stored on a browser or device when a website is visited. Pixels, tags, local storage and similar technologies may also serve cookie-like functions depending on how they are used.

2. Cookie categories used

3. Purposes of cookie use

Cookies and similar technologies may be used for the following purposes:

• operating the website securely and properly,
• managing user sessions and security processes,
• remembering user preferences,
• measuring errors, performance and traffic,
• improving services and user experience,
• measuring advertising and marketing activities when the user has given permission.

4. Cookies used

This section lists only cookies actually used on the website:

The cookie preference record (lenacars_cookie_consent) is stored in browser local storage; it is not an HTTP cookie.

Unused Google, Meta, Microsoft or other services are not listed merely on a hypothetical basis. The inventory is updated according to technologies actually in use.

The KVKK Board considers it good practice to clearly state a cookie’s name, purpose, duration and first- or third-party nature in cookie notices.

5. Legal bases

Personal data processing activities carried out through essential cookies may rely on the legal bases in Article 5 of the KVKK, depending on the nature of the processing.

For non-essential functional, analytics and marketing cookies, where no other processing condition under the KVKK applies, explicit consent is obtained.

Explicit consent must be;

• related to a specific cookie category,
• based on information,
• freely given,
• expressed through an active user action

These conditions must be met. Disclosure and explicit consent are not combined in the same statement.

6. Cookie preferences

On the first visit, non-essential cookies are kept off by default.

The cookie notice clearly offers the user the following options:

• Accept all
• Reject all
• Manage preferences

Functional, analytics and marketing cookies must be manageable as separate categories. Accept and reject options must not be presented with different colours, visibility or size in a way that steers the user toward a particular choice. In KVKK Board decisions, obtaining bulk consent for non-essential cookies and failing to offer category-based preferences has been considered problematic for valid explicit consent.

Users may later change or withdraw their cookie preferences via the “Cookie Preferences” link on the site.

Cookies may also be deleted or blocked via browser settings; however, browser settings do not replace the website’s obligation not to run non-essential cookies before consent.

7. Third-party cookies and transfers abroad

Cookies may be used through third parties providing analytics, communication, embedded content or advertising services. In that case, the relevant provider, cookie name, purpose, duration and party information are set out in the cookie table above.

Where the third-party provider or infrastructure is located abroad and a personal data transfer therefore occurs, the transfer is carried out in accordance with the conditions in Article 9 of the KVKK.

Simply stating “The third party’s own policy applies.” is not sufficient. Lena Mama’s obligations as data controller continue with respect to cookie use and transfer activities on its own site. The Board has treated transfers abroad via third-party cookies without a lawful basis as a violation.

8. Retention periods

Cookies may be stored for the session or for a defined period.

Each cookie’s actual retention period is stated separately in the cookie table in this policy. When the retention period ends, the cookie is deleted by the browser; users may also remove cookies earlier via browser settings or, where available, the cookie preference panel.

9. Policy updates

This policy may be updated if cookies in use, service providers, legislation or the website’s technical structure change. The current version and last update date are published on this page.

10. Contact

You may send questions about cookies and personal data processing to info@lenacars.com.