ELUCIDATION WORDING ON THE PROCESSING AND PROTECTION OF THE PERSONAL DATA
This public disclosure text is drawn up by STG Grup Danışmanlık ve Ticaret A.Ş. (“Our Corporation”) for the purpose of explicating and providing information for the customers/users of the Corporation and the entire individuals related to our Corporation including the ones benefiting from our products and services regarding the processing of the Personal Data, acting with the capacity of data supervisor in accordance with the Law on Protection of Personal Data No. 6698. You may access detailed information regarding the processing of your Personal Data disclosed by you to our Corporation on our website www.twinsaction.com and the Policy on the Processing and Protection of Personal Data that you find in our Corporation’s Showroom.
1. PURPOSE OF PROCESSING OF PERSONAL DATA
In the context of your legal relationship established with our Corporation; the Personal Data you disclosed shall be processed by our Corporation in accordance with the law and the Law on Protection of Personal Data and the processing purposes stated hereinafter. Accordingly, to be limited with the following purposes; our Corporation processes the Personal Data for the purpose of the performance of the endeavors by the business units of our Corporation that are required for the Personal Data Holders to benefit from the products and services offered by our Corporation; realization of operations with the Business Associates and/or suppliers of our Corporation; accessing to the records of the Personal Data Holders within our Corporation for the further shopping transactions, issuing invoice by automated means with this data by not giving rise to confusion due to reasons name/surname resemblance; ensuring that the customers benefit from the general or customized campaigns and offers related to the merchantable products and services by means of records generated within our Corporation; communicating the campaigns related to the products and services offered to the customers through mail, e-mail, SMS and phone calls; recommending and communicating our products and services to the Personal Data Holders upon customization thereof based on the appreciation, habit and pattern of use and requirements; performance of the required endeavors aiming for the catalogs and campaigns to the customers to be offered and communicated to the customers in consideration of the customers’ continuation and sustainability of using the products and services of our Corporation; amending and altering the products and services offered to be compliant with the requirements and uses of the customers both within the purchasing and the post-sales processes and for the new purchases of the products and services offered; responding to the complaints or requests for inspection related to the products and services purchased and notifying customers in this respect; execution and performance of one-to-one or integrated marketing operations, sales and post-sales operations and purchasing operations; fulfillment of the obligations within the scope of the occupational health and safety and taking the required precautions and measures for the purpose of execution and performance of the human resources policies of our Corporation; performance and steering the financial affair processes and activities for the purpose of ensuring the physical security and auditing of the locations of our Corporations along with the administrative and legal processes towards the communication executed by our Corporation; execution and management of the intracompany system and application management operations by our Corporation, communication, market survey and social responsibility activities and finance operations as well as the product/project/manufacturing/investment quality processes in line with the purpose of determination and implementation of the commercial and business strategies of our Corporation, planning and/or execution of the customer relationship management processes to include the planning and/or execution process of the customer satisfaction activities; contacting with the customers through mail, e-mail and phone calls accordingly; contacting with the Personal Data Holders communicating their requests and complaints to our Corporation and ensuring the following up and management of the requests and complaints; establishment and tracking of the visitor records within the scope of the terms and conditions of the Personal Data processing set forth in Article 5 and 6 of the Law on Protection of Personal Data.
2. RECIPIENTS AND GROUND OF PERSONAL DATA DISCLOSURE
Within the scope of the terms and conditions of the Personal Data set forth in Article 8 and 9 of the Law on Protection of Personal Data, our Corporation can transfer the Personal Data to the Corporation Business Associates, Corporation Stakeholders, Corporation Officials and/or the third parties/organizations to be designated thereof to serve the purposes of ensuring the establishment objectives of the business partnership established for the purposes such as execution and performance of miscellaneous projects and receiving services while sustaining the commercial operations of our Corporation; realization of the operations and activities performed within the scope of the regulation, effectiveness management and corporate communication processes; designing the strategies with respect to the commercial operations and ensuring the optimal management and supervision thereof; alteration and modification of the products based on the requirements and use of customers upon their requests communicated during the sales and post-sales process; notifying the customers regarding the campaigns by means of mail, e-mail and/or phone calls and printing and deliverance of the catalogs. Furthermore, as required by the relevant public institutions and organizations within the scope of their legal authorities and by the relevant private legal entities within the scope of their legal authorities in accordance with the provisions of the legislation, our Corporation is entitled to transfer and disclose the Public Institutions and Organizations that are legally authorized and Private Legal Entities and/or third parties/organizations designated by those that are legally authorized.
In the event that the processing activity realized for the above-cited purposes fails to fulfill any of the exemptions and exceptions anticipated within the scope of Law, your expressed consent shall be sought by our Corporation related to the relevant process.
3. METHODS OF PERSONAL DATA COLLECTION AND LEGAL GROUNDS
For the purpose of auditing and supervision of the compliance of the Law on Protection of Personal Data with the Article 1 regulating the purpose of the Law and Article 2 regulating the scope of the Law, the realization of the objectives set forth in the Articles 5 and 6 of the Law on Protection of Personal Data and the Policy and accurately and complete fulfillment of the obligations arising from the law within the frame of the legal grounds based on legislation, agreement, claim and request, the Personal Data are collected through various means such as on sorts of verbal, printed and electronic media through technical and other methods and/or social media accounts that you authorize to be accessed by our Corporation and processed by our Corporation or data processors appointed by our Corporation.
4. RIGHTS OF THE PERSONAL DATA HOLDERS PURSUANT TO THE LAW ON PROTECTION OF PERSONAL DATA
Our Corporation, in accordance with Article 10 of the Law on Protection of Personal Data, informs you, regarding your rights as the Personal Data Holders, provides guidance on how the said rights are exercised, and realizes the internal mechanism, administrative and technical regulations required for all those. Our Corporation, in accordance with Article 11 of the Law, informs the individuals with their Personal Data collected, regarding finding out whether the Personal Data is processed, requesting information in this regard in the event that their Personal Data was processed, eliciting the purpose of Personal Data processing and whether it is used as intended, knowing the third party recipients of the Personal Data both inland and outland, requesting for the correction in case of inaccurate or flawed processing of the Personal Data, requesting for the deletion or destruction of the Personal Data within the scope of the requirements set forth in Article 7 of the as Law on Protection of Personal Data, requesting for the notification of the processes performed in accordance with paragraph (d) and (e) of Article 11 of the Law on Protection of Personal Data to the third parties that are the recipient of the Personal Data, raising objection to an outcome to be revealed against that particular person by means of analyzing the data processed through exclusive automated systems, claiming for damages to be compensated in the case of sustaining damages due to processing of the Personal Data in breach of the Law.
The Personal Data Holders are entitled to communicate their requests related to their above-cited rights by completing the Application Form enclosed on APPENDIX and delivering it to our Corporation free of charge along with the information and the documents for identity purposes by means of the methods hereinafter or other methods stated by the Board of Personal Data Protection:
– Deliverance of the copy of the form upon completion bearing wet signature through notary public or registered letter with return receipt to Barbaros Mah. Ahlat sokak Varyap Meridian E Blok No:30 Ataşehir/İSTANBUL.
– Deliverance of the form bearing a secure electronic signature within the scope of Electronic Signature Law No. 5070 to firstname.lastname@example.org by means of registered e-mail.
– Through any other method anticipated/to be anticipated by the Board of Personal Data Protection.
In order for the third parties to request for application on behalf of the Personal Data Holders, a Special Power of Attorney is required to be issued by the Personal Data Holder through the notary public empowering the entity to file the application.
Our Corporation shall finalize the request as earliest as possible based on the nature of the request and no later than 30 (thirty) days without applying any charges. However, in case the process requires an additional cost, our Corporation is entitled to request for a fee to be calculated based on the tariff set forth by the Board of Personal Data Protection.
APPENDIX: APPLICATION FORM
FORM OF EXPRESS CONSENT ON PERSONAL DATA PROCESSING
I have read the elucidation wording on the Processing and Protection of the Personal Data provided to me. I have further been informed of the Law on Personal Data Protection, comprehended by legal rights and I hereby agree and acknowledge that the following consent of mine obtained in this regard is valid and based on my free will.
I hereby grant my approval with my express and written consent for my personal data that I have disclosed to benefit from the products and services of your Corporation and be informed on such and my personal data to be acquired by your Corporation from the relevant real and legal entities to be processed to allow me to benefit from the products, applications, advantages or campaigns that are convenient for me in line with my requirements and for the purposes of general information and ensuring all sorts of communications to be established with me and to be disclosed to the Business Associates of your Corporation, Stakeholders of your Corporation, Officials of your Corporation, legally authorized Public Institutions and Organizations, legally authorized Private Legal Entities and/or third parties/organizations to be designated by such in the event that my Personal Data is required and the deliverance of information, promotional and marketing communications and messages with data, audio and image content to be directly transmitted or through SMS, MMS, telephone, fax, dialer devices, electronic mail and similar communication channels by your Corporation with the awareness that I am entitled to reject such at any time.
Personal Data Holder
Name & Surname: