CLARIFICATION TEXT ON PERSONAL DATA PROTECTION LAW
Data Controller: “LOLOVY”
Efsane Sport Textile Tourism and Logistic Services Industry and Trade Ltd. Co.
Tax ID. No.: 3250473656
1.1. We, as Efsane Sport Textile Tourism and Logistic Services Industry and Trade Ltd. Co., hereby provide information acting as the Data Controller following the Article 10 titled "Obligation of the Data Controller to Inform" of the Personal Data Protection Law No. 6698, published in the Official Gazette dated 7 April 2016 and numbered 29677, with the aim of primarily protecting privacy of personal life including the fundamental rights and freedoms of individuals and determining the responsibilities of real and legal persons when processing personal data.
1.2. As Efsane Sport Textile Tourism and Logistic Services Industry and Trade Ltd. Co., we have prepared this document with the purpose of ensuring that the personal data of our citizens is processed in compliance with the Turkish Constitution, international treaties to which our country is a party concerning human rights, and the Personal Data Protection Law No. 6698 (KVKK), along with other relevant legislation. The processing of all personal data shared with our company will be carried out lawfully, in connection with our activities and service objectives, and in a proportionate manner, allowing the data subjects to effectively exercise their rights.
2.1. The concepts ‘personal data’, ‘sensitive personal data’, and ‘data processing’ used in the clarification text are based on the definitions provided in the Law on the Protection of Personal Data ("KVKK"). In the KVKK, the following terms are used:
2.1.1. Personal Data Protection Law ("KVKK"): Law No. 6698 on the Protection of Personal Data, published in the Official Gazette on 7 April 2016 and entered into force.
2.1.2. Personal Data: Refers to any kind of information relating to an identified or identifiable real person.
2.1.3. Data Processor: Refers to the real or legal person who processes Personal Data on behalf of the Data Controller based on the authority granted by the Data Controller.
2.1.4. Data Controller: Refers to the real or legal person who determines the purposes and means of processing Personal Data and is responsible for the establishment and management of the data recording system.
2.1.5. Processing of Personal Data: Refers to any operation or set of operations performed on Personal Data, whether wholly or partially automated or non-automated, which includes obtaining, recording, storing, preserving, altering, rearranging, disclosing, transferring, taking over, making retrievable, classifying, or preventing the use of data.
3.1. The personal data belonging to the data subject, as stated in Article 4 of KVKK (Law on the Protection of Personal Data), will be processed by the data controller Company within the scope of the purposes specified below, following the principles of legality and honesty, accuracy, being up-to-date when necessary, specific, clear, and legitimate purposes; being relevant, limited, and proportionate to the purposes for which they are processed; and in compliance with the retention rules prescribed by the relevant legislation or the duration required for the processing purposes.
4. Purpose of Processing Your Personal Data
4.1. Under the provisions of Articles 4, 5, and 6 of the KVKK (Personal Data Protection Law), your personal data will be processed as follows:
4.1.1. In accordance with the principles of legality and honesty,
4.1.2. In a limited and proportionate manner, relevant to the purposes of processing,
4.1.3. Accurately and up-to-date,
4.1.4. For specific, clear, legitimate purposes, and for the duration prescribed by the relevant legislation or necessary for the purposes for which they are processed.
4.2. Your personal data will be processed in the scope of the conditions and purposes specified in the Articles 5 and 6 of Law No. 6698, with the aims of;
5.1. Your personal data may be transferred to our business partners, suppliers, shareholders, subsidiaries, legally authorized public institutions, and private individuals within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of Law No. 6698 for the following purposes:
6.1. Personal data is collected, used, recorded, stored and processed by our company through verbal, written, and/or electronic means, and with the explicit and understandable information provided to the data subjects, along with obtaining their explicit consent when necessary, in accordance with the law and principles of integrity, limited to the legitimate purposes explicitly stated above, and within the framework of the principle of proportionality. Furthermore, your personal data is collected for the purpose of developing the products and services we offer and conducting our commercial activities, based on different channels and various legal grounds, such as contacting us, establishing a contractual relationship, visiting our business premises, or sharing information in promotional events. Personal data collected for these legal reasons can be processed and transferred within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698, as well as for the purposes stated in this Privacy Notice.
6.2. Moreover, we assure that your Personal Data will not be processed by our company for purposes other than those specified in this information document, will not be transferred to third parties located in Turkey or abroad, and will not be retained
7.1. Our company keeps the processed personal data for the periods determined by the legislation, and in cases where the legislation does not specify a separate period, the personal data is stored for the duration required by our company's practices and commercial practices associated with the services provided while processing that data, and after this period, it is kept only for the duration necessary to constitute evidence in possible legal disputes, as demonstrated to be necessary in practice. After the expiration of the specified periods, such personal data is deleted, destroyed, or anonymized.
8. Rights of the Data Subject
8.1. Data subjects, acting as the data controller, have the following rights regarding their personal data:
8.1.1. To learn whether their personal data is being processed,
8.1.2. To request information if their personal data has been processed,
8.1.3. To learn the purpose of the processing of their personal data and whether they are used in line with that purpose;
8.1.4. To be informed about the third parties, both domestic and abroad, to whom their personal data has been transferred,
8.1.5. To request the correction of their personal data if it is processed incompletely or inaccurately,
8.1.6. To request the deletion or destruction of their personal data within the framework of the conditions set forth in Article 7 of Law No. 6698,
8.1.7. To request the notification of the transactions performed under Article 11, sublacuses (d) and (e) of Law No. 6698 to the third parties to whom their personal data has been transferred,
8.1.8. To object to any result against them that arises solely from the analysis of their processed data through automated systems,
8.1.9. To claim compensation in case they incur damages due to the unlawful processing of their personal data.
8.2. To exercise the aforementioned rights, data subjects can submit their written requests, along with the necessary identification information and explanations about the right they wish to exercise, to the address: Efsane Sport Textile Tourism and Logistic Services Industry and Trade Ltd. Co./Barbaros Hayrettin Paşa. 1992 St. V.City No:16/171 Esenyurt/ISTANBUL, using the previously notified and electronically registered email address by the data controller. Applications must be in Turkish.
8.3. In the applications, it is mandatory to include the name, surname, and signature if the application is written, the Turkish Republic ID number for Turkish citizens, nationality for foreigners, passport number/ID number, place of residence or business address for notification, the registered email address if available, phone or fax number, and the subject of the request.
8.4. In the application, as a data subject, it is required that the requested matter be clear and understandable, relevant to the person making the request, or if acting on behalf of someone else, to be specifically authorized for this purpose and provide evidence of this authorization. The application should include identification and address information, and supporting documents verifying the identity should be attached to the application.
8.5. Applications made within this scope will be concluded as soon as possible and no later than 30 days. If the response to the relevant person's application is provided in writing, no fee will be charged for up to ten pages. For each page exceeding ten pages, a processing fee of 1 TL may be charged. If the response is provided on a recording medium such as a CD or flash drive, the fee requested by Efsane Sport Textile Tourism and Logistic Services Industry and Trade Ltd. Co. for the recording medium cannot exceed the cost of the medium.