Disclosure Statement on the Protection of Personal Data
As Fursa Grup Satın Alma Danışmanlık Hizmetleri Tic. A.Ş. ("FURSA"), we attach great importance and sensitivity to the privacy and security of your personal data. In this regard, ensuring that all personal data of individuals related to FURSA, including our customers who benefit from our services and products and our business connections, is processed and stored in accordance with the Turkish Law on the Protection of Personal Data No. 6698 ("KVKK") is among our priorities.
In awareness of our capacity as "Data Controller" under the KVKK, we wish to inform you as follows regarding the purposes for which your personal data is processed, the methods and reasons for collection of your data, your rights concerning the processing of your personal data, and the application procedure and principles for exercising these rights.
What Personal Data Do We Collect?
Where necessary, FURSA collects personal data from our visitors (real persons who visit or have visited our Company's electronic platforms - FURSA website, mobile site, etc. - and/or our Company's physical management locations) and our business contacts (shareholders, authorised persons and employees of organisations with whom we have any business relationship such as suppliers, subcontractors) in accordance with the KVKK. We may list the personal data we collect as follows:
- Identity Data: Data relating to the identity of the person such as name, surname, national ID number, nationality, vehicle plate information, identity copy collected from our customers, visitors, shareholders, authorised persons and employees of our business contacts and other third parties.
- Contact Data: Data enabling communication with the person such as phone number, address, email address collected from our customers, visitors, shareholders, authorised persons and employees of our business contacts and other third parties.
- Financial Data: Data such as fee information, expense amount, payment information, bank account number collected from our customers and business contacts according to the legal relationship established between our Company and the data subject.
- Personnel Data: Any personal data that forms the basis of employment rights of real persons working with our Company, which may also include professional experience, collected from authorised persons and employees of organisations with whom we have subcontractor or similar business relationships.
- Physical Location Security Data: Personal data such as security and camera recordings taken upon entry to and during stay in physical premises, from our customers, visitors, shareholders, authorised persons and employees of our business contacts and stores that are our tenants, and other third parties.
- Visual / Audio Data: Personal data such as photographs, voice and video recordings collected from authorised persons and employees of our customers and business contacts, excluding those falling within physical location security information.
- Special Categories of Personal Data: Data such as health data and criminal conviction information specified in Article 6 of the KVKK that we may collect from our customers, visitors, shareholders, authorised persons and employees of our business contacts.
- Other Data: Risk management information, data relating to family members and relatives, customer transaction data, marketing data, and data collected through cookies and other means by automatic methods, from our customers, visitors, shareholders, authorised persons and employees of our business contacts and other third parties.
By What Methods and Legal Bases Do We Collect and Process Your Personal Data?
We collect your personal data through:
- Our internet and mobile sites, and our social media accounts operated on behalf of FURSA on various social media platforms;
- Email, phone, short messages ("SMS") or multimedia messages ("MMS") used within the scope of sales and marketing activities, printed and electronic forms and other communication methods;
- Contracts signed with you or the company you represent, commercial offers presented, printed and electronic forms, documents, correspondence, and applications made to us within the scope of our business activities;
- Business cards and other documents provided by you within the scope of our business meetings and events;
- Third parties such as FURSA's group companies, affiliates and subsidiaries, companies with which we have an organic connection (related companies), business contacts, or companies supplying services/products to us;
by various methods, whether wholly or partly automated or not forming part of any data recording system, in oral, written or electronic form.
We process your personal data collected through the above methods on the basis of one or more of the following legal grounds:
- Your explicit consent;
- Provisions of laws and regulations in force in the Republic of Turkey requiring processing;
- Necessity for the protection of your or another person's life or bodily integrity when you are unable to express consent due to physical impossibility;
- Necessity for the performance of a contract we have concluded with you or your company;
- Necessity for processing your personal data for the fulfilment of our legal obligations;
- Your personal data having been made public by you;
- Necessity for the exercise or protection of our legal or contractual rights as a company;
- Necessity for processing your personal data for our legitimate interest, provided that it does not harm your fundamental rights and freedoms.
We retain all personal data we process in accordance with the periods mandated by the KVKK and other legislation, and in any event for as long as the legitimate purposes above persist, by taking all necessary administrative and technical measures.
For What Purposes Do We Process Your Personal Data?
We process the personal data we collect according to its nature for the following purposes:
- Carrying out by our business units the planning, evaluation and work necessary to enable our customers to benefit from the products and services we offer as FURSA;
- Conducting advertising and marketing activities for our products and services, providing information on promotions, campaigns, offers, newsletters, events and the like, conducting corporate communication activities, and customising products and services according to the preferences, usage habits and needs of data subjects;
- Conducting Marketing and Customer Relationship Management activities;
- Organising corporate communication and related events, campaigns and invitations and providing information thereon, conducting market research;
- Improving the digital platforms we offer to our customers and deriving statistics on users' number, type, visit frequency, behaviour, geographical location and the like to provide an efficient and personalised experience to platform users, offering personalised content, campaigns and advertising according to platform users' interests and needs, and using cookies for this purpose;
- Tracking, evaluating requests, suggestions and complaints from data subjects, customer satisfaction management, and planning, statistics and satisfaction evaluation studies thereunder;
- Managing relationships with business contacts, suppliers, subcontractors and similar firms, conducting business and commercial relations; implementing human resources policies;
- Exercise of legal rights, use of transaction history information as evidence in case of dispute after termination of the legal relationship;
- Determination and implementation of commercial, legal and business strategies;
- Implementation of financial policies; e-invoice management;
- Planning, auditing and implementation of information security processes, management of information technology infrastructure;
- Conducting planning, reporting, visitor/customer statistics and similar analyses within the scope of our Company's activities; and/or
- Compliance with relevant domestic legislation, provision of information requested by public institutions and organisations, fulfilment of reporting obligations.
Do We Transfer Your Personal Data to Third Parties and/or Abroad?
We may transfer the personal data we collect to our group companies, affiliates and subsidiaries, companies with which we have an organic connection (our related companies), business partners serving our Company domestically and/or abroad, business contacts, suppliers, insurance companies, banks and financial institutions, consultancy firms from which we receive support in areas such as legal, tax, etc., Company officials, our shareholders, legally authorised public institutions and private persons, and service providers from whom we receive support in storage, archiving, and information technology support (server, hosting, software, cloud computing, etc.) processing personal data on behalf of our Company domestically and/or abroad, where the above legal grounds exist and in accordance with the stated purposes to continue our Company's activities and business processes, subject to compliance with the provisions laid down under the KVKK. As FURSA, we undertake that your personal data will be stored securely and will not be processed unlawfully.
Data Subject Rights and Application Procedure
Your Rights Regarding Your Personal Data
We wish to inform you that you have the following rights regarding the data being processed within our Company:
- To learn whether your personal data is being processed;
- To request information if your personal data has been processed;
- To learn the purpose of processing of your personal data and whether it is used in accordance with that purpose;
- To learn who the third parties are to whom your data has been transferred domestically or abroad and what data has been transferred;
- To request rectification if your processed personal data is incomplete or inaccurate;
- To request that third parties to whom your personal data has been transferred be notified of any rectification, deletion or destruction of your personal data;
- To request deletion or destruction of your processed personal data where the grounds requiring processing have ceased to exist or your personal data has become outdated;
- To object to the emergence of a result against you arising from the analysis of your processed personal data exclusively by automatic systems;
- To claim compensation for damage arising from unlawful processing of your personal data.
Application
You may submit your requests regarding the above rights to our Company in writing by completing the application form below, or via your registered email address, secure electronic signature, mobile signature, or the email address you have previously notified to us and which is registered in our system. Please click here for the application form.
As FURSA, we will conclude your requests free of charge as soon as possible and in any event within thirty days depending on the nature of the request. Depending on the nature of your request and the method of application, we may request additional verification (sending a message to your registered phone, calling, etc.) to determine whether the application belongs to you and thus protect your rights. If any cost arises from fulfilling your requests, we may only charge you the fees set out in the tariff determined by the Personal Data Protection Board.
We may accept or reject requests directed to FURSA by stating the reasons, and communicate this response to the applicant in writing or electronically. If the request is accepted, we are obliged to fulfil the request immediately as FURSA.
Complaint
If your requests directed to FURSA are rejected by the Company, you are not satisfied with the response given by the Company, or no response is given, you may lodge a complaint with the Personal Data Protection Board within 30 days from the date the response is communicated to you, or within 30 days from the end of the 30-day period if no response is given.
Data Controller Identity and Contact Information
This disclosure statement has been prepared by Fursa Grup Satın Alma Danışmanlık Hizmetleri Tic. A.Ş., established in Turkey and whose details are set out below, as "Data Controller" and addressed to the relevant data subjects.
Trade Name: Fursa Grup Satın Alma Danışmanlık Hizmetleri Tic. A.Ş.
Address: ……………………………
Mersis No: …………………………
Phone: …………………..
Fax: …………………….
KEP (Registered E-Mail) address: ………………….