Turkey: An Overview Of Margin Squeeze In Turkish Competition Law

I. Overview

Article 6 of Law No. 4054 on the Protection of Competition (the "Law No. 4054") entitled "Abuse of Dominant Position" provides a general prohibition of abuse and a non-exhaustive list of examples. Although the list does not specifically categorize margin squeeze (or price squeeze) as a form of abuse, margin (price) squeeze was listed as a form of exclusionary abuse under the Guidelines on the Assessment of Exclusionary Abusive Conduct by Dominant Undertakings published in January 2014 (the "Guidelines"). The Guidelines are based on the same principles as the Guidance on the European Commission's Enforcement Priorities in Applying Article 82 of the European Commission Treaty to Abusive Exclusionary Conduct by Dominant Undertakings ("EU Guidance"). According to paragraph 61 of the Guidelines, margin squeeze occurs "when an undertaking active in a vertically related market that is dominant in the upstream market sets the margin between the prices of the upstream and downstream inputs at a level which does not allow even an equally efficient competitor in the downstream market to profitably trade on a lasting basis." This definition and similar definitions had already been provided in the Turkish Competition Board's ("Board") decisions1 before the enactment of the Guidelines.

The Board has stipulated in various decisions2 and in the Guidelines that in order for margin squeeze to occur (i) the undertaking shall be vertically integrated in a way to engage in activities in upstream and downstream markets within the same production chain and constitute a single economic entity in the relevant upstream and downstream markets; (ii) the undertaking shall be in a dominant position in the upstream market; (iii) the input shall be an indispensable input to be active in the downstream market; (iv) the margin between the wholesale and retail prices shall be squeezed in a way to make it impossible for as-efficient-competitors to compete in the downstream market3; (v) the investigated conduct must lead to actual or potential foreclosure and restrict competition in the downstream market; and (vi) the dominant undertaking shall not have any objective justifications. The absence of one or more of above conditions makes it difficult to establish an infringement through margin squeeze.

This approach in the Turkish legislation is in line with the margin squeeze definition adopted in the European Union.4 EU Guidance explains margin squeeze as follows: "a dominant undertaking may charge a price for the product on the upstream market which, compared to the price it charges on the downstream market, does not allow even an equally efficient competitor to trade profitably in the downstream market on a lasting basis (a so-called 'margin squeeze')."5

We discuss below the Turkish margin squeeze cases in the telecommunications sector first, as this sector has garnered most of the margin squeeze cases, and move on to the Board's decisions in other sectors.

II. Margin Squeeze in the Telecommunications Sector

a. Legislation

In the Turkish jurisprudence, margin squeeze in the telecommunications sector merits attention due to both the growing number of cases and the Board's shared competence in telecommunications. To elaborate, Law No. 4054 prohibits all practices that prevent, restrict or distort competition in markets for goods and services. The telecommunications sector is no exception to the application of Law No. 4054, evidenced by the plethora of cases in this sector. The Board analyses margin squeeze cases ex-post, i.e. after the implementation of the price tariffs at the wholesale and retail levels. Up until 2014, the Board was arguably alone in dealing with margin squeeze in the telecommunications sector, frequently receiving complaints against large players. The only involvement of the Information and Communication Technologies Authority ("CTA") in margin squeeze cases was under Article 7 of the Law No. 5809, which requires the Board to seek the CTA's advice before delivering any decision pertaining to telecommunications sector.

On the other hand, the Electronic Communications Law numbered 5809 ("Law No. 5809") empowers the CTA to take the necessary actions to ensure an effective competition in the telecommunications sector. Within the scope of Article 7 of the Law No. 5809, without prejudice to the application of Law No. 4054, the CTA is "entitled to perform examination and investigation of any action conducted against competition in electronic communications sector, on its own initiative or upon complaint; to take measures it deems necessary for the establishment of competition and to request information and documents within the scope of its tasks." The CTA's authority to regulate margin squeeze originates from Article 13.2(c) and Article 13.3 of the Law No. 5809. Article 13.2(c) enables the CTA to prevent operators with "significant market power" from implementing anti-competitive tariffs including price squeeze. Article 13.3 stipulates that "[p]rocedures and principles pertaining to the implementation of this Article" are to be designated by the CTA.

Under Law No. 5809, the Information and Communication Technologies Board ("CTB") has published the "Principles and Procedures on Identification, Elimination and Prevention of Margin Squeeze" ("Principles and Procedures") which entered into force on July 1st, 2014. Within this scope, the CTA is authorized to conduct margin squeeze analysis ex-ante or ex-post in the telecommunications sector, whereas the Board is authorized to intervene ex-post in all relevant markets. In terms of margin squeeze, the CTA may impose obligations only to undertakings having "significant market power". The CTA examines the margin between the prices offered at the wholesale level and retail level; however, it does not determine a specific margin.

After the entry into force of Principles and Procedures, the CTA has published only one decision regarding margin squeeze6, where the CTB ordered Turk Telekom to comply with Article 12(2) of the Principles and Procedures which concerns the procedure to be followed when the CTB finds margin squeeze with regard to tariffs already in force (i.e. ex-post analysis). On the other hand, the Board did not intervene regarding the tariff subject to the CTB's decision. Overall, due to lack of precedents, the consequences of this shared competence are not yet evident.

b. The Board's Case Law

The first case that merits attention is the Turk Telekom Internet Infrastructure decision7 of the Board, where the Board initiated an investigation against Türk Telekomünikasyon A.Ş. ("Turk Telekom") based on an alleged abuse of Turk Telekom in the internet access services market and imposed an administrative monetary fine of approximately TL 1.2 trillion (approx. EUR 705,972 at the time) against Turk Telekom for abusing its dominant position by determining network access tariffs so high that its competitors could not compete in the relevant upstream market, and at the same time determining internet access tariffs very low in the downstream market. Even though the allegations and the decision were not based on margin squeeze, and the Board fined Turk Telekom based on the theory of predatory pricing, as Kaya explains, the case could have been handled under the theory of margin squeeze also, which would probably have yielded similar results as to the existence of an infringement.8

In the Turk Telekom Student-Teacher Campaign decision9 where the Board decided upon a margin squeeze claim for the first time, it rejected the complaints based on the ground that Turk Telekom's campaign in the case had already been approved by the CTA, indicating that the campaign fell outside the scope of Law No. 4054.10 The wholesale prices of the dominant supplier had also been approved by the CTA. Interestingly, the Turkish Competition Authority's experts assigned to the case argued that the CTA had only approved the campaign based on its own legislation and this should not prevent the Board from taking the necessary measures if the campaign violated Law No. 4054. The Board appeared to maintain this approach of rejecting complaints regarding tariffs that had previously been approved by the CTA, until the Council of State started rendering decisions indicating the opposite.11 In its famous Telkoder decision12, for example, the Council of State underlined that even though the tariffs subject to the complaint had been approved by the CTA, this should not translate into inaction on the Board's part, which is the body "generally authorized" to detect and punish infringements in the telecommunications sector. The Council of State further emphasized the need for the Board to intervene when there is anti-competitive conduct by indicating that "if these undertakings are held exempt from the application of Law No. 4054, this might lead to competition law infringements going unpunished in the sector [i.e. the telecommunications sector]."

In decisions where the Board actually analyzed whether there was margin squeeze, it has used different methods for the margin squeeze analysis. In its Turkcell Corporate Tariffs pre-investigation decision13, the Board compared the call termination fees and retail fees of the investigated undertaking, Turkcell İletişim Hizmetleri A.Ş. ("Turkcell") in order to decide whether Turkcell, operating in the upstream market, applies a price in the upstream market that is higher than its own retail price in the downstream market. The Board further discussed whether an efficient operator may be able to operate with a normal profit in the downstream market. As such, the Board aimed to determine whether there was a positive margin between the average retail price of the investigated undertaking and the sum of an efficient operator's call origination and call termination costs. The Board eventually found that the margin between Turkcell's retail prices in downstream market and the cost of the operators is sufficient for the downstream competitors to duly operate and compete.

The 2008 margin squeeze case against Turk Telekom14, where the Board imposed a total administrative monetary fine of TL 12.4 million (approx. EUR 5.9 million at the time) to Turk Telekom and TTNet A.Ş. ("TTNet"), Turk Telekom's subsidiary, provides detailed insight into abuses through margin squeeze. The investigation was launched upon complaints from various internet service providers that Turk Telekom abused its dominant position in the wholesale broadband internet access services market through a TTNet campaign in the retail broadband internet access services market. Aside from the conditions of margin squeeze, the decision underlines three aspects of margin squeeze before moving on to the analysis of Turk Telekom's conducts: (i) in terms of the calculation of the margin, the margin between the dominant undertaking's retail price and wholesale price must first be calculated to see whether this margin is negative, and if not, whether this margin can compensate the incremental costs of an equally efficient competitor for the sales of the relevant product/service must be established, (ii) margin squeeze is different from predatory pricing and the retail prices do not need to be predatory for the finding of margin squeeze, (iii) the duration of the conduct matters, and if the discounts are applied in a short term, this can be considered an objective justification. The Board found that between November 2006-February 2008, Turk Telekom and TTNet set the monthly access fees to end users at the retail level below fees that Turk Telekom applies to other internet service providers for internet infrastructure. The decision highlights that even an as-efficient-competitor would have to be operating at loss to be able to stay in the market. When discussing the conditions of margin squeeze, the Board also referred to two decisions of from EU case law, i.e. Telefonica15 and Deutsche Telecom.16 This is a classic example of the Board turning to European cases when there are not many precedents in the Turkish jurisprudence regarding a certain type of infringement.

Later cases showcased various approaches to what constitutes "cost" in the calculation of the margin. In its Turkcell GSM Tariffs decision17, for example, unlike the Turkcell Corporate Tariffs decision, the Board conducted its margin squeeze analysis by calculating the margin between Turkcell's inter-connection costs and its per minute retail prices. However, the Board went back to its approach in the Turkcell Corporate Tariffs decision with its Turkcell GSM Campaigns decision18, using a "total call cost" criteria which was the sum of the call origination cost and the call termination cost.

A recent margin squeeze case in the telecommunications sector was, remarkably, not an investigation or a pre-investigation, but a negative clearance decision19 where the Board granted negative clearance to TTNet's bundling of its Tivibu service (paid TV services) with its internet and telephone services. TTNet provides its internet and telephone services in a vertically integrated structure with Turk Telekom, and their practices had been questioned many times under the theory of margin squeeze, which is why margin squeeze appears to become relevant in the negative clearance notification. The decision becomes very interesting towards the end, where the Board underlines that the most important aspect to be decided upon was whether the campaign could compensate the costs. Since the campaign was not yet in force, the Board saw fit to conduct an ex-ante analysis of margin squeeze. The analysis was therefore based on certain projections in terms of the profitability of the campaign. Seeing that TTNet expected to gain profits from the campaign, the Board concluded that the campaign would compensate the costs. The Board thus granted negative clearance to the campaign, while warning TTNet at the same time that if the projections on profitability were to change, the relevant campaign could fall under Article 6 of Law No. 4054 after its implementation. The decision raises the question whether the Board has gone beyond its powers by conducting an ex-ante margin squeeze analysis. To that end, the Board explained that since the case was a negative clearance application (i.e. the Board did not act ex officio or upon complaint), the conduct had not yet taken place in the market and therefore an ex-post analysis was not applicable. On the other hand, the Board still wanted to analyze whether the campaign would restrict competition under the margin squeeze theory before granting negative clearance, seeing the vertically integrated structure of Turk Telekom and its margin squeeze track record. Therefore, the decision indicates, the Board had to apply an ex-ante margin squeeze test based on projected prices and costs.

III. Margin Squeeze in Other Sectors

Even though margin squeeze cases are generally witnessed in the telecommunications sector, there are also other sectors where undertakings faced margin squeeze allegations investigated by the Board. In the Nuh Çimento Margin Squeeze I20 case, Detaş Beton Sanayi A.Ş. directed allegations to Nuh Çimento Sanayi A.Ş. ("Nuh Çimento") and its subsidiary Nuh Beton A.Ş. ("Nuh Beton"), stating that Nuh Çimento had abused its dominant position in the ready-mixed concrete market through margin squeeze and predatory pricing. The Board indicated that margin squeeze could be considered a sub-branch of refusal to supply and moved on to the analysis of whether the conditions for refusal to supply occurred. The Board then determined that another undertaking was the market leader both in capacity and in production in the relevant market, and therefore Nuh Çimento was not in a dominant position. Based on this, Article 6 of Law No. 4054 could not have been infringed. The Board concluded that an investigation against Nuh Çimento was not necessary and the complaint was rejected.

In its Frito Lay21 decision, the Board analyzed the Kraft Gıda San.Tic.A.Ş.'s ("Kraft Gıda") allegations against Frito Lay Gıda San.Tic.A.Ş. ("Frito Lay") that Frito Lay had not increased its prices despite increase in costs and that this constituted margin squeeze. The Board first set the record straight by underlining that margin squeeze and predatory pricing were different types of abuse, and that for margin squeeze to occur, the undertaking in question must be vertically integrated. Accordingly, the Board assessed whether Frito Lay committed predatory pricing, but eventually dismissed this claim.

In the recent Nuh Çimento Margin Squeeze II decision22, the Board investigated margin squeeze allegations brought against Nuh Çimento and Nuh Beton in the cement market of the Anatolian side of Istanbul (including Kocaeli). Consistent with its previous decisions, the Board evaluated whether Nuh Çimento was in a dominant position in the upstream market. Accordingly, the Board found that Nuh Çimento was not in a dominant position in the said market and without further evaluating other conditions of margin squeeze, the Board decided that Nuh Çimento had not infringed Article 6 of the Law No. 4054.

IV. Conclusion

The Board's case law regarding margin squeeze has been developing over the past decade, with the focus on the telecommunications sector. The number of margin squeeze cases outside the telecommunications sector is quite limited, and in many of these cases, the Board dismissed the allegations after having found out that the undertaking subject to the complaint was not in a dominant position. Within this scope, how the shared competence between the Board and the CTA will unravel in practice is yet to be seen. Overall, the increasing number of margin squeeze decisions well demonstrates the Board's awareness towards this type of infringement and warrants particular attention on the part of vertically integrated undertakings.


1. See e.g. Turk Telekom Summer Storm Campaign decision dated 19.11.2008 and numbered 08-65/1055-411; Turkcell GSM Campaigns decision dated 09.05.2013 and numbered 13-27/371-172.

2. Turk Telekom Summer Storm Campaign decision dated 19.11.2008 and numbered 08-65/1055-411; Çimsa decision dated 10.03.2011 and numbered 11-15/261-89; Turkcell GSM Campaigns decision dated 09.05.2013 and numbered 13-27/371-172.

3. "When establishing the costs of the equally efficient competitor, the Board will generally use LRAIC [Long-Run Average Incremental Cost], calculated for the downstream product of an undertaking dominant in the upstream market" (Guidelines, para. 62)

4. See O'Donoghue and Padilla, The Law and Economics of Article 82 EC, p. 303; Allison Jones, Brenda Sufrin, EU Competition Law Text, Cases and Materials, Fifth Edition, p. 426; Peter Roth QC, Vivien Rose, European Community Law of Competition, Sixth Edition, p. 993.

5. "In margin squeeze cases the benchmark which the Commission will generally rely on to determine the costs of an equally efficient competitor are the LRAIC of the downstream division of the integrated dominant undertaking" (EU Guidance, para. 80)

6. CTB's Turk Telekom decision dated 08.12.2014 and numbered 2014/DK-SRD/635.

7. Turk Telekom Internet Infrastructure decision dated 02.10.2002 and numbered 02-60/755-305. This decision was subsequently annulled by the Council of State due to procedural deficiency, upon which the Board reassessed the alleged abuse of dominant position of Turk Telekom with its decision dated 05.01.2006 and numbered 06-02/47-8. The Board's position did not change in the second decision.

8. Şerife Demet Kaya, Fiyat Sıkıştırması Ekonomik ve Hukuki Açıdan Bir Değerlendirme, Rekabet Kurumu Uzmanlık Tezleri Serisi No:87, p.24.

9. Turk Telekom Student-Teacher Campaign decision dated 08.09.2005 and numbered 05-55/833-226

10. Şerife Demet Kaya, Fiyat Sıkıştırması Ekonomik ve Hukuki Açıdan Bir Değerlendirme, Rekabet Kurumu Uzmanlık Tezleri Serisi No:87, p.26.

11. See the Council of State 13th Chamber's Borusan decision dated 20.11.2007 and numbered E.2006/2052-K.2007/7582; Telkoder decision dated 08.05.2012 and numbered E.2008/14245-K.2012/960.

12. The case was the appeal of the Board's decision dated 11.09.2008 and numbered 08-52/792-321.

13. Turkcell Corporate Tariffs decision dated 04.07.2007 and numbered 07-56/634-216

14. Turk Telekom Summer Storm Campaign decision dated 19.11.2008 and numbered 08-65/1055-411

15. Case COMP/38.784 – Wanadoo España vs. Telefónica, 04.07.2007.

16. Deutsche Telekom AG vs. Commission, Case T-271/03, Court of First Instance, 10.04.2008.

17. Turkcell GSM Tariffs decision dated 27.01.2011 and numbered 11-06/90-32.

18. Turkcell GSM Campaigns decision dated 09.05.2013 and numbered 13-27/371-172.

19. TTNet Negative Clearance decision dated 05.02.2015 and numbered 15-06/74-31.

20. Nuh Çimento Margin Squeeze I decision dated 10.07.2010 and numbered 10-63/1317-494.

21. Frito Lay decision dated 07.07.2015 and numbered 15-28/345-115.

22. Nuh Çimento Margin Squeeze II decision dated 18.02.2016 and numbered 16-05/118-53.

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.

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
Font Size:
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
Confirm Password
Mondaq Topics -- Select your Interests
 Law Performance
 Law Practice
 Media & IT
 Real Estate
 Wealth Mgt
Asia Pacific
European Union
Latin America
Middle East
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

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.


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.


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 by clicking here .

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.


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.


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.


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.


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.