ERTUGRUL LEATHER LTD.
UNDER THE LAW ON THE PROTECTION OF PERSONAL DATA NUMBER 6698
ERTUGRUL LEATHER LTD. (“GIO&MI”), as the data controller, provides information on the collection method, processing purposes, transferring of personal data to third parties and the rights of the person concerned, with this clarification text, in accordance with the Law on the Protection of Personal Data No. 6698 (“Law”).
This Clarification Text covers product and service buyers (“Customer”) who visit GIO&MI stores, shop for products from stores, receive GIO&MI Gift Cards, and contact GIO&MI stores or customer services through customer communication channels.
The scope of this Clarification Text is as follows:
1.Legislation on Personal Data
2.Collection Methods of Personal Data
3.Processed Personal Data, Legal Reasons and Purposes of Processing
4.Transfer of Personal Data
5.Rights of the Relevant Person
1. Legislation on Personal Data
GIO&MI, Customers’ personal data; In order to fulfill its obligations regarding the execution of sales processes of products and services, ensuring customer satisfaction, product warranty, follow-up of requests and complaints:
Turkish Code of Obligations No. 6098,
Law No. 6502 on the Protection of the Consumer,
Turkish Commercial Code No. 6102,
Law No. 6563 on the Regulation of Electronic Commerce,
Labor Law No. 4857,
It processes customer personal data in order to fulfill its obligations under the Turkish Penal Code No. 5237 and other applicable legislation.
2. Collection Methods of Personal Data
GIO&MI collects the personal data of the Customers in order to issue invoices, to perform return/exchange transactions upon request, or to recall the product in rare cases such as manufacturing faults, during physical shopping from stores. Customer personal data is collected by the Store Manager at the invoice stage and at the cash register, following the product sale.
In addition to the above-mentioned methods, GIO&MI collects the personal data of product and service buyers, store camera recordings, Customer Service calls and e-mails sent by product or service buyers, notifications from administrative or judicial authorities and other auditory, electronic and physical information in this Clarification Text. It is collected in accordance with the legal reasons regulated in.
3.Processed Personal Data, Legal Reasons and Purposes of Processing
Personal data is any kind of data that makes a person specific or identifiable, and in accordance with the Constitution of the Republic of Turkey, everyone has the right to demand the protection of their personal data. GIO&MI collects and processes the personal data of the Customers sensitively and takes the necessary measures to prevent possible security breaches.
The legal grounds and data processing purposes taken as basis by GIO&MI in the processing of personal data of customers are as follows:
From customer personal data; Identity (name, surname, signature), communication (phone number, e-mail address, address information), customer transaction (invoice, order/demand information), finance (credit card information) data is mandatory for the establishment and performance of the contract. is taken. These data categories are:
Execution of product sales processes and after-sales support services (product warranty, exchange/return, recall), management of customer relations,
Execution of the activity in accordance with the legislation, execution of financial and accounting transactions and wage policy,
It is processed for the purpose of carrying out communication activities regarding returns, exchanges and product information processes and following up requests and complaints.
From customer personal data; Identity (date of birth), contact (phone number for campaign messages) and marketing (shopping history, product loyalty information obtained through survey/campaign study) data are collected and processed within the scope of express consent. These data categories are:
Carrying out sales and after-sales support services for products, and campaigns (season discount and birthday discount processes) and activities aimed at customer satisfaction,
Execution of communication activities (SMS notification regarding campaigns)
Marketing analysis studies are processed for the purpose of conducting wage policy and company and product loyalty processes.
From customer personal data; physical space security (in-store camera recordings) and audio/visual recordings (interviews with customer service, in-store camera recordings) are taken because data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject. These data categories are:
It is processed for the purpose of ensuring the security of data controller operations and ensuring the security of physical space and movable.
GIO&MI processes the personal data of its Customers listed in the table above, again limited to the above purposes. Since GIO&MI adopts data minimization as its data processing policy, it takes care not to collect or process any data whose processing is not required by law or legitimate interest.
Transfer of Personal Data
4.1. On-premises Transfer
GIO&MI applies an authorization matrix while sharing the data of the Customers within the company. Therefore, in the sales and support processes of a product, different units access and process only a limited number of data required by the activity. Confidentiality policies and procedures are carried out to ensure that the data is not shared by these persons outside the company.
4.2. Domestic Transfer
GIO&MI may share the data of the Customers with the following real and legal persons, provided that all necessary security measures are taken in accordance with Article 8 of the Law for the purposes specified in this Clarification Text:
Real and legal persons contracted due to their activities,
Affiliates, business partners and suppliers,
Legal advisors, financial advisors and tax advisors,
With advertising and marketing agencies (by anonymisation),
Institutions and organizations authorized to request the personal data of those concerned, especially regulatory and supervisory institutions, courts and enforcement offices, and persons authorized by these institutions and organizations.
4.3. Transfer Abroad
GIO&MI does not transfer the Customer’s personal data it receives and processes within the scope of this Clarification Text abroad.
5. Rights of the Relevant Person
The Customer, whose personal data is processed by GIO&MI, can exercise the following rights listed in Article 11 of the Personal Data Protection Law:
1.Learning whether personal data is processed or not,
2.If personal data has been processed, requesting information about it,
3.Learning the purpose of processing personal data and whether they are used in accordance with its purpose,
4.Knowing the third parties to whom personal data is transferred at home or abroad,
5.Requesting correction of personal data in case of incomplete or incorrect processing,
6.Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVK Law,
7.Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,
8.Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
9.To request the compensation of the damage in case of loss due to unlawful processing of personal data.
In accordance with the Communiqué on Application Procedures and Principles, the person concerned may submit their requests to the Data Controller in writing or by using the registered e-mail address, secure electronic signature, mobile signature or the e-mail address registered in the GIO&MI system.
For this, Name-Surname, Signature, T.C. With the application form submitted by GIO&MI on the website (https://giomi.com.tr/), which contains the Identification Number, residence or workplace address, e-mail address, telephone or fax number, if any, and explanations regarding the right to be exercised, and 6122 Sokak No. :15 An application can be made to Bornova / İZMİR.
In addition, it is possible to obtain information via the email@example.com e-mail address.
The application made by GIO&MI within the legal period of 30 days following the notification of the application of the relevant person will be evaluated and answered free of charge. In cases where it is obligatory to respond only in recording media such as CD, flash memory, in order to fulfill the requests of the person concerned, GIO&MI has the right to charge the relevant person for the cost of recording media such as CD, flash memory.
GIO&MI has the right to make changes in this Clarification Text due to changes in the law and new procedural methods or regulations that may be determined by the Personal Data Protection Board.
GIO&MI has taken the necessary administrative and technical measures while receiving and processing the data of the product and service buyer as described in this Clarification Text within the scope of the Personal Data Protection Law, and the relevant data security measures are included in the Data Controllers Information Registry. GIO&MI takes the utmost care in terms of the security of the personal data provided to it and undertakes to notify the Customer immediately in case of any violation.
Personal data processed by GIO&MI can be processed by taking all necessary information security measures, provided that they are not used outside the purposes and scope specified in this Clarification Text, will be kept during the legal retention period or for the period required by the processing purpose, and will continue to be used by GIO&MI after being anonymized at the end of the period required by the processing purpose. will be destroyed or destroyed in accordance with the relevant procedure in accordance with the Law and relevant legislation.
In accordance with the Law, GIO&MI collects the personal data of the person concerned in accordance with the law and the rule of good faith, accurately and up-to-date when necessary, for specific, clear and legitimate purposes, in connection with the purpose for which they are processed, limited and measured, for the period stipulated in the relevant legislation or for the period required for the purpose for which they are processed. and takes the necessary measures for this purpose.