Personal Data Protection Law

1.The purpose of the personal data protection and processing policy;

As, in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”), with this clarification text we have prepared as the data controller, we have provided you with the 10th article titled “disclosure obligation of the data controller” and titled “Rights of the data subject” in the KVKK. Within the framework of Article 11; for what purpose your personal data will be processed, to whom and for what purpose your processed personal data can be transferred, the method and legal reason for the collection of your personal data and your other rights listed in Article 11 of the KVKK.

In the capacity of data controller, we process, record, transfer, share and store your personal data as explained below and within the limits ordered by official legislation.
Our company reserves the right to update this agreement on the protection of personal data at any time within the framework of changes that can be made in the legislation.

2. Collection, processing and processing purposes of personal data;
By our company, which operates in the fields specified in detail in the company's articles of association, due to the said activities; Your verbal, written or electronic personal data is collected and processed due to the regulations of all kinds of official and private institutions and the contracts we have concluded. Your personal data will be used to provide services related to the activities of our company and to increase the quality of these services, to carry out sales, marketing and other activities of our company, to comply with information storage, reporting and informing obligations.  In addition, your personal data may also be used within the scope of studies such as CRM (customer relations management) applications to be made for sales and marketing activities, as well as increasing the quality of service we provide to you.
Your personal data will not be used for purposes other than the above-mentioned purposes without your express consent, and will not be shared or transferred to third parties, except for legal obligations and private/official institutions/ organizations/ businesses.

Our company, your personal data in question only; KVKK art. In other cases stipulated in 5/f.2, we can use this data with our domestic or foreign affiliates, direct or indirect affiliates and joint ventures, or as required by a legal obligation, in order to provide value-added services, opportunities and opportunities to our customers and to increase the service quality. It can be shared with public institutions or organizations that are authorized to request it, and with the institutions, suppliers, authorized dealers/dealers/business partners with whom we have contracted in accordance with our activities, provided that adequate measures are taken.

Although your personal data may vary depending on the services, products or commercial activities provided by our company; It can be collected verbally, in writing or electronically through automatic or non-automatic methods, offices, branches, dealers, call center, website, social media channels, mobile applications and similar tools. As long as you benefit from our company's products and services, your personal data can be processed by being created and updated.

In addition, with the intention of using the services of our company;

a. When you use our call center or website,

b. When you visit our company, website or social media accounts,

c. Your personal data may be processed when you attend trainings, seminars or organizations organized by our company. With your consent or ID Your personal data obtained due to other legal compliance reasons stated in the laws;
(i) our business units can carry out the necessary work to benefit you from the products and services offered by our company;

(ii) Recommending the products and services offered by our company to you by customizing them according to your tastes, usage habits and needs;

(iii) Ensuring the legal and commercial security of our company and those who have a business relationship with it (administrative operations for communication carried out by our company, ensuring the physical security and control of company locations, business partner/customer/supplier (authorized or employees) evaluation processes, legal compliance process, financial affairs etc.;

(iv) Improving the quality of the services provided by our company and improving our quality policy,

(v) to be informed about and benefit from the general and special campaigns, promotions, promotions, discounts and similar advantages offered by our company;
(vi) to be able to process the data obtained together with your personal data, preferences, transactions and browsing time in the relevant channels when you log in with your user name and password in order to receive services from the channels offered by our company, in order to provide you with the information and services you have requested;
(vii) To be able to make notifications (renewal, expiration, etc.) regarding all kinds of loyalty cards issued or to be issued by our company and its related companies/organizations and website memberships of our company and its related companies/organizations, and any communication that may be established with you, To inform about new services and products to be offered, changes, innovations and similar issues in personal data policies and membership conditions;

(viii) To inform you about the information, events and services you will request from our company;

(ix) Determining and implementing our company's commercial and business strategies; (x) ensuring the execution of our company's human resources policies, and;

(xi) Article 5 of the KVKK for the purposes of fulfilling a legal obligation established by the legislation, if it is clearly stated in the legislation or if it is necessary and 6. It may be processed by our company and its related companies/ organizations and other natural and or legal persons mentioned in (c) below within the scope of the personal data processing conditions and purposes specified in the articles.

3. The method and legal reason for collecting personal data;

Your personal data is obtained in all kinds of verbal, written or electronic media in order to provide our products and services as a company within the determined legal framework in line with the purposes specified in the above articles, and in this context, for our company to fully and accurately fulfill its contractual and legal responsibilities. Your personal data collected for this legal reason are processed, recorded, transferred, shared and stored for the purposes specified in article (b) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK.

4. Processing of data of special nature;

According to the KVKK, data related to race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data is personal data of special nature. Our company also takes adequate precautions in the processing of personal data of special nature, determined by the Personal Data Protection Board. In order to provide better service, our company will process the private data of individuals only with the consent of the relevant person and only to serve the purpose of collection.

5. To whom and for what purpose can the processed personal data be transferred;

Your personal data collected ByCimbali Company in order to serve the purposes specified in (b). in addition, our shareholders, business partners, suppliers, legally authorized public institutions and private individuals are required to comply with Article 8and 9 of the KVKK.  It may be transferred within the framework of the personal data processing conditions and purposes specified in the articles.

6. Transfer of personal data abroad;

Our company has the authority to transfer personal data abroad within the conditions determined by the Personal Data Protection Board in the KVK Law, in accordance with the other conditions in the law and after obtaining the explicit consent of the person for this purpose.

7. The rights of the personal data owner listed in Article 11 of the KVKK;

Within the scope of KVKK, we accept that the person concerned has the right to be informed and to obtain his consent before the processing, recording, transfer, sharing and storage of his personal data, and that he has the right to determine the fate of the data after the data is processed, recorded, transferred, shared and stored. In this context, if you submit your requests regarding your rights as personal data owners to our company through the methods set out below in this "clarification text on the processing of personal data", our company will conclude the request free of charge within thirty (30) days at the latest, depending on the nature of the request.

In accordance with the communiqué on the procedures and principles of application to the data controller published by the personal data protection board, regarding your requests regarding your rights as personal data owners;

1. If your application will be answered in writing, no fee will be charged.

2. If the response to the application is given in a recording medium such as cd or flash memory, the fee that may be requested by our company as the data controller cannot exceed the cost of the recording medium.

In this context, personal data owners;

a. learning whether personal data is processed,

b. requesting information on personal data if it has been processed,

c. learning the purpose of processing personal data and whether they are used in accordance with its purpose,

d. Knowing the third parties to whom personal data is transferred at home or abroad,

to. Requesting correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,

f. To request the deletion, destruction or anonymization of personal data within the framework of the conditions stipulated in Article 7 of the KVKK and to notify the third parties to whom the personal data has been transferred,

g. Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

h. In the event that personal data is damaged due to unlawful processing, it has the right to demand the compensation of the damage
However; individuals do not have a right to anonymized data within the company. Our company may share personal data with relevant institutions and organizations for the purpose of exercising the legal powers of a judicial duty or state authority in accordance with the business and contractual relationship.

8. The periods during which your personal data will be processed;

In accordance with the KVKK law, your personal data, which has been processed for the purposes specified in this “clarification text regarding the processing of personal data”, ceases to be processed in accordance with Article 7/f.1. of the KVKK and/or when the time-out periods that we are required to process your data in accordance with the legislation expire, Your personal data will be deleted, destroyed or anonymized by us and will continue to be used.

9. Situations where our company may process your personal data without your express consent as required by law:

Pursuant to Article 5 of the KVKK, our company may process your personal data, which it has received in accordance with the law, without your explicit consent, in the following cases;

Circumstances expressly stipulated in the laws;

  1. If you are unable to disclose your consent as a data owner due to actual impossibility, or if your consent is not legally valid, it is mandatory to process your personal data to protect the life or body integrity of yourself or someone else,
  2.  Our company and related companies/organizations specified in Article (c) other natural and/or legal entities directly related with the formation or performance of a contract you enter into with, provided that the parties to the contract is required for the processing of personal data,
  3.  It is compulsory for our company to fulfill a legal obligation,
  4. Your personal data has been made public by you,
  5. Data processing is mandatory for the establishment, exercise or protection of a right,
  6.  Data processing is mandatory for the legitimate interests of our company, provided that it does not harm your fundamental rights and freedoms.

10. To make a request in accordance with the personal data protection law;

In accordance with paragraph 1 of Article 13 of the KVKK, you can forward your request to our company to exercise your above-mentioned rights, using the method(s) determined/to be determined by the Personal Data Protection Board. Alternatively, if you wish, you can submit your application in writing to our company in accordance with the KVKK.
Law no. 6698 art. You can always contact us by sending an e-mail to [email protected]  to exercise your rights set forth in Article 11. Only [email protected] e-mail address should be used for matters related to your personal data, requests and notifications from channels other than this address will not be evaluated.

Rights regarding personal data can only be exercised about personal data. Requests for the data of people other than the person who filled out the form and whose official documents are attached to it will not be considered. Forms without official documents identifying your identity will not be considered. Even when data deletion requests are fulfilled, we inform you that we are obliged to share the data with the official authorities if requested by the official authorities.

I have read, understood, accepted, I have my express consent.

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