Turkey: The Exchange Of Information As Addressed In Competition Board Decisions

The exchange of information between competitors is not regulated under Turkish law. This subject was recently handled within the Guidelines Project on the Application of Articles 4 and 5 of the Act No. 4054 on the Protection of Competition in Horizontal Cooperation Agreements ("Guidelines")1. However, the Guidelines have not been published yet.

In the absence of a legal framework, Competition Board ("Board") decisions should be taken into account concerning information exchange, since the Board has given multiple decisions regarding information exchange and has thus opined on the principles of information exchange for more than ten years.

Parties to the Information Exchange

It can be observed that the parties to information exchange differ according to the horizontal or vertical relationship between the parties.

Horizontal Relationships. Although the Board does not expressly state that information exchange among competitors should be taken into account, this notion can be easily observed in its decisions; for since its establishment, the Board has taken special care to examine cases where there is an exchange of information between competitors. For instance, the Board, in its decision dated 08.08.2002 and numbered 02-47/586-M regarding the Association of Fertilizer Producers2, decided that the exchange of statistical information between competitors should cease since such an exchange might negatively influence the competition. In its decision dated 19.12.2005 and numbered 05-85/1182-3363, the Board pointed to information exchange between competitors by using the phrase "between undertakings in the same market". In one of its more recent decisions dated 18.04.2011 and numbered 11-24/464-1394, the Board did not take into consideration correspondence between the parties, as it was exchanged between Borusan and its retailer (Kosifler) – not competitors.

Board decisions on information exchange among competitors are also examined by the Council of State within the scope of annulment suits issued against Board decisions. The 13th Chamber of the Council of State, in its decision dated 08.05.2012 and numbered E. 2008/9080, K. 2012/9655, considered (after analyzing the effects of such information exchange in the market) information exchanged between competitors as against competition since it might negatively influence the competition.

Vertical Relations. Where there is a vertical relationship between the parties, they are in principle not competitors since they are not active in the same market. Nevertheless, even in such a situation, the Board analyses information exchanged between the parties considering that such an exchange may distort competition in the market where the receiving party is active. The Board, in its decision dated 03.05.2012 and numbered 12-24/675-1956, analyzed whether information exchanged between the supplier and its retailer would lead to coordination between retailers and decided that the information exchanged did not create a distortion of competition since the information exchanged between the parties (the supplier and the retailer) would not lead to any coordination between retailers. This decision is important with regards to information exchanged between suppliers and retailers.

Form of the Information Exchanged

The information exchange between parties may be direct, indirect and regular.

Direct Information Exchange. Direct information exchange is the easiest form of information exchange that may be detected by the Board. Therefore, there are a limited number of Board decisions on direct information exchange between competitors. For example, the Board, in its decision dated 16.06.2009 and numbered 09-28/600-1417, considered the direct exchange of detailed domestic and foreign quantities of sale, monthly import quantities and similar information between Erdemir and Borçelik as anticompetitive.

Indirect Information Exchange. Indirect information exchange is the most common way to exchange information. Indirect information may be exchanged either through statistical or general information or through associations of undertakings.

  • The Board prohibits every kind of statistical or general information exchange between competitors that may inform them of each other's future behavior. The Board first approached this subject in its decision dated 08.08.2002 and numbered 02-47/586-M8, where it considered anticompetitive any kind of statistical or general information exchange which would prevent undertakings from determining their future behavior "on the basis of factors other than individual preferences". There are multiple decisions of the Board on this subject.9
  • The Board also examines information exchanged through associations of undertakings and prohibits information exchanges that may influence undertakings' future decisions. Within this scope, the Board, in its decision dated 08.02.2002 and numbered 02-07/57-2610, decided that information was exchanged between parties through meetings held in the association of undertakings and through monthly statistical bulletins. The Board also emphasized in its decision dated 25.11.2009 and numbered 09-57/1393-36211 that the association of undertakings facilitated the infringement of competition by sharing its work on the calculation of the total production amount of the association members with undertakings.

Regular Information Exchange. It can be observed, in light of Board decisions, that the Board considers regular information exchange as anticompetitive. The Board, in its decision dated 20.09.2012 and numbered 12-44/1350-45512, considered skeptical, from the point of view of competition law, the exchange of information consisting of "monthly sales data" (considering that information was exchanged at regular short intervals). There are a lot of decisions where the Board attentively considers monthly information exchanges13. Furthermore, the Board also examines whether information exchanges between parties continued for a prolonged period. The Board, in its decision dated 04.07.2007 and numbered 07-56/672-20914, considered information exchanged "over a prolonged period" as anticompetitive. Nevertheless, the duration of the information exchange is not stated in the decision, therefore, the Board's interpretation on the duration of "prolonged period" is not clarified.

Importance of the Information Exchanged

As has been frequently stated in Board decisions15, information exchange does not constitute per se a competition violation since information exchange does not always influence competition in a negative way; it may even have positive effects on competition. Indeed, it is accepted that information exchange has positive effects on competition if it permits the parties to better organize their future investments.

However, information exchange may be anticompetitive from the point of view of the market structure and the nature of the information exchanged.

Influence of the Market Structure. It may be observed from Board decisions that market structure can have a significant influence on information exchange. The Board takes a flexible approach to information exchange where the market is transparent, since in such a case exchanged information may also be obtained from the market. For instance, the Board, in its decision dated 15.04.2004 and numbered 04-26/287-65, specified that there was low probability that the information exchanged between the parties caused coordination since the products are uniform and there are a lot of actors in the market.16

Contrary to the aforementioned, the Board has an inflexible approach to information exchange where the market is not transparent, which means that the information exchanged between parties may not be obtained from the market. For instance, the Board, in its decision dated 16.06.2009 and numbered 09-28/600-141, considered the information exchange between parties anticompetitive since there were a limited number of actors in the market, the concentration level was high in the market and there were entry barriers to the market.17

However, it should be stated that there is no uniformity in Board decisions regarding market structure:

  • The decisions of the Board concerning market structure are inconsistent. The Board, in its decision dated 28.12.2006 and numbered 06-95/1202-365, decided that information exchange between parties did not constitute a violation of competition by reason of the nature of the aviation fuel market18. On the other hand, the Board, in its decision dated 04.07.2007 and numbered 07-56/672-209, stated that "it may be concluded to be a violation of competition if the coordination and communication between the parties is proved without analyzing the structure of the market"19.
  • The Board has also given contradictory decisions concerning the same market (the same sector). For instance, the Board, in its decision dated 09.09.2009 and numbered 09-41/998-255, decided that the exchange of updated information between the parties did not result in coordination, considering the easy entry to the automotive market20. On the other hand, the Board, in another of its decisions related to the same sector, emphasized that the exchange of prospective information between the parties restricted competition, without taking into account the nature of the market21.

Nature of the Information Exchanged. According to Board decisions, information exchanges conducted by undertakings to help them make decisions "on the basis of factors other than individual preferences22or which prevent undertakings "from taking individual economic decisions"23(strategic information exchange) are prohibited. Additionally, in some of its decisions the Board did not consider the exchange of strategic information between the parties a violation of competition24.

When determining the existence of a strategic information exchange, the Board considers both the content of the information and the time period to which the information is related.

  • Content of the Exchanged Information. Even though the Board does not define strategic information, it gives some indication as to what can be deemed strategic information. The following information is accepted as strategic information:
    • Information related to prices, capacity utilizations, production quantities and customer based sales quantities25;
    • Information related to detailed sales prices and quantities of brands as per provinces, regions and sub-segments as well as information related to market shares26;
    • Information related to monthly production numbers, payments made for raw materials and sub-industries as well as information related to paid taxes and wages on the basis of each sub-model27;
    • Stock data and sales data28;
    • Information related to any kind of parameter related to price conditions and supply control29;
    • Consolidated or statistical information are not considered strategic information when the following conditions are fulfilled30:
      • Tables showing data related to quantities (capacity, production, sales, exports, imports) and capacity utilization should be prepared in a manner that prevents their disclosure on the basis of an undertaking or group of undertakings which form an economic unit, and only total countrywide information should be shared;
      • In addition to the distributed statistics, no comments, analyses or advice which may affect the competitive behavior of an undertaking should be disclosed;
      • Estimations related to future prices, productions and capacity utilization should not be shared;
      • It should be ensured that officials responsible in associations of undertakings for the collection and tabling of data conceal sensitive information from members of the association and third parties; and
      • Tables showing monthly data should not be published before at least two months following the month to which they are related.
  • Time Period to which Information Exchange is related. The Board, in order to determine whether an information exchange is anticompetitive, also examines the time period to which this information is related. Nevertheless, Board decisions on that subject are not yet uniform. Although in some of its decisions the Board holds that prospective information exchange is prohibited31, it states in other decisions that retroactive information exchange may also create future coordination between competitor undertakings within a dynamic process32.

Unilateral Information Exchange

The Board, in its recent decisions, to determine whether there is a unilateral exchange of information, examines the behavior of the undertaking receiving the information and decides that competition is violated where the undertaking receiving the information does not to the information. Further, the Board, where the information exchanged is in written form, such as an electronic mail, looks for an immediate answer from the objecting counterpart. The same principle is also applied to verbal information exchanges such as in meetings. In such cases, the Board examines whether the participants have directly objected to the information exchanged (and recorded their opposition in the minutes of the meeting)33.

The Presumption of Information Exchange

As mentioned above, the 13th Chamber of the Council of State, in its recent decision dated 08.05.2012 and numbered E. 2008/9080, K. 2012/965, decided that as long as it is not established that the exchange of information between parties will not influence their future decisions, it will be assumed that said exchange will result in coordination between them. As per this decision, it may be stated that the Council of State has established a rule of presumption, which foresees that information exchanges will influence parties' future behavior34. Nevertheless, as also mentioned above, in cases where the market is transparent, and that information may be easily obtained, and where the information exchanged is related to general and statistical information, the decision of the Council of State should be made with caution. Likewise, there should be a flexible approach on the exchange of information in export transactions, which do not affect any market in Turkey35.

Conclusion

The principle criterion considered by the Board is whether an information exchange will limit undertakings' capability "to take individual economic decisions". However, the Board has not established uniform and objective conditions which facilitate the determination as to whether this criterion is met. The Board, in some of its decisions:

  • Has prohibited the retroactive exchange of information;
  • Has not taken into account the market structure; and
  • Has brought a rule of presumption on information exchange (Council of State).

Within the scope of the aforementioned Board decisions, it can be observed that information exchanged is de facto restricted. However, as also mentioned above, information exchanged may sometimes have positive effects on competition. With this in mind, uniform and objective conditions should be established which facilitate a determination as to whether the criterion established by the Board is met. Hence, it is anticipated that the Guidelines, which have not yet been published, will shed some light on these subjects and be a proper guide for undertakings.

Footnotes

1 The Guidelines was submitted to public opinion at the end of 2012. For further information, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=sLwJqE8Qet01Sk2Es7ie3Q==-H7deC+LxBI8= (accessed on: 21.03.2013).

2 For information about the decision, see PISMAF, Samil, İktisadî ve Hukukî Açıdan Teşebbüsler Arası Bilgi Paylaşımı, Rekabet Kurumu Uzmanlık Tezleri Serisi, No. 280, Ankara 2012, p. 79.

3 To reach the decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.3013).

4 To reach the decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

5 To reach de decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=c30JfvlYGh59eUsyDmy7wg==-H7deC+LxBI8=&nm=251 (accessed on: 21.03.2013).

6 To reach the decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

7 To reach the decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

8 For detailed information on the decision, see endnote 2.

9 For instance, see the Board decision dated 04.07.2012 and numbered 12-36/1040-328, http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

10 To reach the decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

11 To reach the decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

12 To reach the decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

13 For instance, see Board decision dated 04.07.2012 and numbered 12-36/10040-328. For information about the decision, see endnote 10.

14 To reach the decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

15 For instance, see the Board decision dated 19.12.2005 and numbered 05-85/1182-336, http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

16 For information about the decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

17 For information about the decision, see endnote 7.

18 To reach the decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

19 For information about the decision, see endnote 15.

20 To reach the decision, see the following link: http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

21 To reach the decision, see PISMAF, p. 83, fn. 246.

22 Letter of the Competition Authority to the Turkish Cement Manufacturer's' Association dated 15.05.1998. For information about the letter, see endnote 9.

23 Board decision dated 09.09.2009 and numbered 09–41/998–255. For information about the decision, see endnote 18.

24 For detailed information, see Board decision dated 24.06.2009 and numbered 09-30/637-150. The existence of exchange of strategic information is stated in the dissenting opinion, http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (access on: 21.03.2013).

25 Board decision dated 04.07.2007 and numbered 07-56/672-209. For information about the decision, see endnote 15.

26 Board decision dated 15.04.2004 and numbered 04-26/287-65. For information about the decision, see endnote 17.

27 Board decision dated 20.09.2012 and numbered 12-44/1350-455. For information about the decision, see endnote 13.

28 Board decision dated 18.04.2011 and numbered 11-24/464-139. For information about the decision, see endnote 4.

29 Board decision dated 20.12.2006 and numbered 06-92/1172-350, http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

30 Board decision dated 08.08.2002 and numbered 02-47/586-M. For information about the decision, see endnote 2.

31 For instance, Board decision dated 08.08.2002 and numbered 02-47/586-M and Board decision numbered 09-41/998-M. For information about the decision, see PISMAF, p. 79 and 83. Additionally, see decision of the 13th Chamber of the Council of State dated 08.05.2012 and numbered E. 2008/9080, K. 2012/965. For information about the decision, see endnote 5.

32 For instance, see Board decision dated 20.09.2007 and numbered 07-76/907-345, http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

33 For instance, see Board decision dated 11.04.2007 and numbered 07-31/325-120, http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013) or Board decision dated 18.04.2011 and numbered 11-24/464-139, http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxBI8=&nm=90 (accessed on: 21.03.2013).

34 For information about the decision, see endnote 5.

35 See Board decision dated 06.10.2005 and numbered 05-65/928-250, http://www.rekabet.gov.tr/default.aspx?nsw=tfjcBAxVih5pUKigR05EaA==-H7deC+LxB18=&nm=90 (accessed on: 27.03.2013).

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Authors
 
Some comments from our readers…
“The articles are extremely timely and highly applicable”
“I often find critical information not available elsewhere”
“As in-house counsel, Mondaq’s service is of great value”

Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
Mondaq on Twitter
 
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
 
Email Address
Company Name
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Registration
Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:
  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.
  • Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.
    If you do not want us to provide your name and email address you may opt out by clicking here
    If you do not wish to receive any future announcements of products and services offered by Mondaq you may opt out by clicking here

    Terms & Conditions and Privacy Statement

    Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

    Use of www.mondaq.com

    You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.

    Disclaimer

    Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

    The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.

    Registration

    Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

    • To allow you to personalize the Mondaq websites you are visiting.
    • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
    • To produce demographic feedback for our information providers who provide information free for your use.

    Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

    Information Collection and Use

    We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

    We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

    Mondaq News Alerts

    In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.

    Cookies

    A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

    Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

    Log Files

    We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

    Links

    This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

    Surveys & Contests

    From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.

    Mail-A-Friend

    If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.

    Emails

    From time to time Mondaq may send you emails promoting Mondaq services including new services. You may opt out of receiving such emails by clicking below.

    *** If you do not wish to receive any future announcements of services offered by Mondaq you may opt out by clicking here .

    Security

    This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

    Correcting/Updating Personal Information

    If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

    Notification of Changes

    If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

    How to contact Mondaq

    You can contact us with comments or queries at enquiries@mondaq.com.

    If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.

    By clicking Register you state you have read and agree to our Terms and Conditions