Clarification Text on Processing of Personal Data


The purpose of the present Clarification Text on Processing of Personal Data (“Text”) is to determine the terms and conditions on use of personal data shared with the Company by the Site users/members/visitors (“Data Subject”) during operation of [www.tac.com.tr] internet site (“Site”) operated by Zorluteks Tekstil Ticaret Ve Sanayi A.Ş. (“Company”) with the capacity of Data Controller, or generated during Data Subject’s use of the Company Site, and to inform the Data Subject in accordance with the Law No. 6698 on Protection of Personal Data (“Law”) and to seek consent of the Data Subject when necessary.

Processed Personal Data Personal Data

The Company is able to process and transfer the personal data including, but not limited to those listed hereunder on Data Subject either through automatic methods and/or otherwise during use of Site or registration process pursuant to the data processing conditions and objectives as set out in this Text, and performs Consensual Processing only after obtaining explicit consent from the Data Subject.

  • Identity Information
  • Contact Information
  • User Information
  • User Operation Information
  • Operation Security Information
  • Financial Information
  • Legal Action and Compliance Information
  • Audit and Inspection Information
  • Request/Complaint management Information
  • Event Management Information
  • Marketing Information

The data anonymized irrevocably shall not be considered as personal data and processing actions for such data shall not be subjected to this Text.

Processing Purpose of the Personal Data

The personal data of the Data Subject can be processed by the Company in order to allow execution of the studies required for offering products and services to concerned persons and execution of respective business processes, execution of the studies required for the commercial operations in progress and execution of respective business processes, for planning and execution of commercial and/or business strategies, for ensuring legal, technical and commercial security of the Company or the concerned persons in business relation with the Company, for creation of membership registries over the site and identity authentication during registration process, delivery and improvement of services offered at the Site, fulfilment of objectives set out in the Membership Contract in case of membership to the Site through development of adequate software version and fulfilment of obligations intrinsic to the services delivered at the Site; and shared with legally and duly authorized public authorities and agencies and private law corporate bodies as stipulated by the applicable legislation.

The Company is entitled to process and transfer the personal data in cases set forth hereinabove pursuant to the personal data processing conditions and objectives as specified in the third subparagraph of second paragraph of article 5 of the Law, and performs Consensual Processing only after obtaining explicit consent from the Data Subject.

Consensual Processing

The personal data of the Data Subject can be processed by the Company for the purposes of planning and execution of sales and marketing process for products and/or services of the Company, including special offers specific to the Data Subject, for cross-selling, for target audience identification, for keeping track of the movements of the Data Subject for executing activities to achieve improved user experience and developing functioning of mobile applications with the internet site of the Company and customization on the basis of Data Subject’s preferences, execution of direct and indirect marketing, customized marketing and remarketing operations, execution of customized segmentation, targeting, analysis and in-house reporting operations, planning and execution of market researches, satisfaction surveys and planning and execution of customer relations management processes, and planning and execution of processes for achieving and/or improving loyalty to the products and/or services of the Company in accordance with the explicit consent of the Data Subject in cases where the personal data processing conditions set out in second paragraph of article 5 and sixth paragraph of article 6 of the Law are not fulfilled, and can be shared with Zorlu Holding A.Ş. and group companies, business partners, suppliers and outsourced third parties of the Company.

Personal Data Collection Method and Legal Justification

The Personal Data is collected from the Data Subject automatically in electronic media during his/her visit to the Site, registration process and navigation in the Site. The personal data so collected is processed pursuant to the objectives set out in the present Text and under the scope of the personal data processing conditions set out in second paragraph of article 5 and sixth paragraph of article 6 of the Law.

Personal Data Archiving Duration

The Company shall store and archive the personal data provided by the Data Subject as long as required for the processing objectives set forth hereinabove.

Furthermore, the Company shall be entitled to store the personal data until expiry of the prescription period set in accordance with the applicable legislation and limited to the purpose of presenting necessary defense under the scope of any conflict that might arise between the Data Subject and the Company.

Measures and Commitments on Data Security

The Company hereby undertakes to adopt all necessary technical and administrative measures and undertake necessary audits for assuring the level of security adequate for

  • Preventing illegal processing of the personal data,
  • Preventing illegal access to the personal data and
  • Protection of the personal data.

The Company shall not disclose and use, outside its intended purpose, the personal data collected on the Data Subject in defiance of the present Disclosure Text on Processing of the Personal Data and the Law on Protection of the Personal Data and provisions of applicable legislation.

If any links are provided to the other applications on the Site, the Company shall not be responsible on confidentiality policies and contents of such applications.

Rights of the Data Subject and Exercise Thereof

In accordance with Article 11 of the Law, the Data Subject is entitled to,

  • Learn whether the Personal Data is processed,
  • Demand information accordingly if the Personal Data is processed,
  • Learn the processing purpose of the Personal Data and whether such data is used for intended purpose,
  • Learn about the domestic or foreign third parties to which such data is transferred,
  • Request correction if such Personal Data proves to be deficient or defective and request informing of the third parties such personal data was transferred to concerning the correction made thereon,
  • Request for deletion or destruction of the personal data in case the purposes that require processing thereof are eliminated despite being processed in compliance with the Law and provisions of other applicable laws and request informing of the third parties such personal data was transferred to concerning the correction made thereon,
  • Object to any consequence against the Data Subject arising from analysis of processed data exclusively with the automatic systems, and
  • Claim indemnification of damages arising from illegal processing of the Personal Data.

Any claims regarding such rights shall be reviewed and finalized within 30 (thirty) days if delivered to Levent 199, Büyükdere Caddesi No:199 34394 Şişli/İstanbul address, or to electronic mailing address (KEP) registered as zorlutekstil@hs03.kep.tr, or to kvkzorlutekstil@zorlu.com address in written with secure electronic signature, mobile signature or electronic mailing address notified to the Company in advance and registered on the Company systems, if any, by the Data Subject. The claims to be submitted by the Data Subject must contain the name, surname of the Data Subject, signature if submitted in written, National Identification Number or nationality, passport number or ID number, if any, for foreigners, official notification address or business address, electronic mail address for notifications, if any, telephone and fax numbers and the subject matter of the claim.

If any written reply is requested for claims, then no fee shall be charged for up to ten pages, and the Company reserves the right to claim payment on the basis of the fee schedule stipulated by the legislation for responses on more than ten pages. If the response to the application is requested in any softcopy format on CD, flash disc, etc., then Company is entitled to charge the claimant Data Subject the cost of the recording medium.

Amendments in the Text

The Company is entitled to amend the provisions in the present Text any time. The provisions amended by the Company become valid and effective upon publication thereof.

PROTECTION OF PERSONAL DATA APPLICATION FORM

ZORLU TEXTILE GROUP  PERSONAL DATA PROTECTION AND PROCESSING POLICY