CORPORATE GENERAL CLARIFICATION TEXT ON PROCESSING OF PERSONAL DATA

As Peraluna Örme San. Ve Tic. A.Ş. (“Peraluna”) we have prepared this clarification text in order to inform you, our Visitors, Online Visitors, Customers, Potential Customers, Supplier Employees and Supplier Executives regarding the processing, storage and transfer of your personal data within the framework of the Personal Data Protection Law No 6698 (“KVKK”) and its activities arising from relevant legislation and legal regulations.

1. What Are the Personal Data Categories We Process and For What Purposes Do We Process Them?                                      

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Your personal information can be processed by Peraluna Örme San. Ve Tic. A.Ş. according to article 4.2 of KVKK in accordance with the principles of

(i) Being in conformity with the law and good faith,

(ii) Being accurate and when necessary, up to date,

(iii) Being processed for specified, explicit, and legitimate purposes,

(iv) Being relevant, limited and proportionate to the purposes for which data are processed,

(v) Being stored only for the time designated by relevant legislation or necessitated by the purpose for which data are collected

within the scope of our ongoing business relations with our business partners, it can be processed for the following purposes (it is possible for one person to fall into multiple categories).

1. Our Visitors

Physical security information (e.g. security camera records) of our visitors will be processed for the following purposes;

1. to ensure physical security.

2. Our Online Visitors

Transaction security information (e.g. your IP address information), marketing information (e.g. shopping history information, cookie records) and identification information, contact information (e.g. your e-mail address) (if you provide us with them*) of our online visitors using our website will be processed for the following purposes;

1. conducting activities in accordance with the legislation,
2. execution of information security processes,
3. tracking of requests / complaints,
4. conducting communication activities,
5. providing information to authorized persons, institutions and organizations,
6. access to our website via the Internet.

3. Our Customers

Identity information, contact information, customer transaction information (e.g. order information), physical security information, legal transaction information, marketing information (e.g. order history information) of the executives and/or employees of our legal person customers and/or natural person customers will be processed for the following purposes;

           

1. conducting activities in accordance with the legislation,
2. conducting financial and accounting operations,
3. execution / audit of business activities,
4. conducting logistic activities,
5. carrying out after sales support services of goods/services,
6. carrying out sales processes of goods/services,
7. conducting marketing analysis operations,
8. execution of contract processes,
1. giving necessary information to authorized persons, institutions, and organizations,
10. ensuring physical security,
11. follow-up and conducting of legal affairs,
50. carrying out storage and archiving operations,
1000.  conducting risk management operations,
14. executing advertisement/campaign/promotional processes, sending commercial electronic messages,
15. carrying out loyalty management programmes for company/products/services
16. conducting communication activities.

4. Our Potential Customers

Identification information, contact information, customer transaction information, transaction, physical security information, marketing information of the executives and/or employees of our legal person customers and/or natural person customers will be processed for the following purposes;

1. carrying out sales processes of goods/services
2. execution of contract processes,
3. ensuring physical security,
4. executing advertisement/campaign/promotional processes, sending commercial electronic messages,

5. conducting marketing analysis operations.

5. Our Supplier Employees

Identification information, contact information, physical security information,  of our supplier employees will be processed for the following purposes;

1. conducting communication activities,
2. execution / audit of business activities,
3. ensuring physical security,
4. conducting supply chain management processes,
5. conducting logistics activities,
6. conducting activities in accordance with the legislation,
7. conducting occupational health / safety activities.

6. Our Supplier Executives                        

Identity information, contact information, physical security information, customer transaction information, marketing information, legal transaction information of our natural person business partner or legal person business partner executives will be processed for the following purposes;

1. execution / audit of business activities,
2. execution of goods / service procurement processes,
3. conducting financial and accounting affairs,
4. execution of contract processes,
5. execution of investment processes,
6. ensuring physical security,
7. follow-up and conducting of legal affairs.

2. What Are the Collection Methods of Your Personal Data?

Your personal data specified in categories above are gathered in automated or non-automated ways through physical means such as order forms, contracts, visitor forms, or information systems and electronic devices (e.g. telecommunications infrastructure, computers and phones), third parties (e.g. KKB and Findeks), our website and other documents declared by the person concerned.    

3. What Is the Legal Reason For Collecting Your Personal Data?

Your personal data is processed by Peraluna Örme San. Ve Tic. A.Ş. in order to achieve the objectives described above, on the basis of the following legal reasons as stated in Article 5 of KVKK;

(i) Explicitly stipulated in laws,

(ii) Provided that it is directly related to the establishment or execution of a contract, the processing of personal data of the contract parties is necessary,

(iii) Data processing is mandatory for the data controller to fulfil their legal obligation,

(iv) Data processing is mandatory for the establishment, use or protection of a right,

(v) Data processing is mandatory for the legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.

(vi) Our Customers’ and Potential Customers’ identity and communication information may be processed for the purposes of advertising, campaigns, promotion and sending commercial electronic messages based on their explicit consent.

4. Do We Transfer Your Personal Data to a Third Party?         www.akkasgroup.com

1. Personal data of our visitors can be shared with law enforcement and judicial authorities for the purpose of resolving legal disputes and if required by the relevant legislation.

2. Personal data of our online visitors can be shared with judicial authorities and authorized public institutions and organizations for the purpose of resolving legal disputes and if required by the relevant legislation.

3. Personal data of our customers can be transferred to authorized public institutions and organizations for the purposes of conducting activities in accordance with the legislation, follow-up and execution of legal affairs, providing information to authorized persons, institutions and organizations, within the scope of the legal regulations; to our group companies, information companies, suppliers, cargo companies, insurance companies, banks and our financial advisor to the extent necessary for the proper performance of the service in order to execute/ audit business activities, carry out risk management processes and perform our services properly. In addition, the personal data in question may be transferred to the law office and judicial authorities from which we receive service in order to be used as evidence in legal disputes that may arise in the future.

4. Personal data of our potential customers may be transferred to the law office and judicial authorities from which we receive service in order to be used as evidence in legal disputes that may arise in the future.

5. Personal data of our supplier employee can be transferred to authorized public institutions and organizations for the purposes of conducting activities in accordance with the legislation, follow-up and execution of legal affairs, providing information to authorized persons, institutions and organizations, execution / audit of business activities within the scope of the legal regulations; to our group companies, information companies, suppliers, cargo companies, banks and our financial advisor to the extent necessary for the proper performance of the service. In addition, the personal data in question may be transferred to the law office and judicial authorities from which we receive service in order to be used as evidence in legal disputes that may arise in the future.

6. Personal data of our supplier executive can be transferred to authorized public institutions and organizations for the purposes of conducting activities in accordance with the legislation, follow-up and execution of legal affairs, providing information to authorized persons, institutions and organizations, execution / audit of business activities within the scope of the legal regulations; to our group companies, information companies, suppliers, cargo companies, banks and our financial advisor to the extent necessary for the proper performance of the service in order to perform our services properly. In addition, the personal data in question may be transferred to the law office and judicial authorities from which we receive service in order to be used as evidence in legal disputes that may arise in the future.

5. Do We Transfer Your Personal Data Abroad?               www.akkasgroup.com

As Peraluna Örme San. Ve Tic. A.Ş. we do not transfer your personal data abroad.

6. How Can You Exercise Your Rights Regarding Your Personal Data?

Your requests regarding the above-mentioned rights and your requests within the scope of Article 11 of the Law on Protection of Personal Data No 6698, which regulates the rights of the data subject, can be conveyed to Peraluna Örme San. Ve Tic. A.Ş. through the "Application Form to Data Controller" prepared for your convenience in accordance with the "Notification Regarding the Application Procedures and Principles of Application to Data Controller" at the address “https://www.peraluna.com/”

Data Controller: Peraluna Örme San. Ve Tic. A.Ş.

Address: Atatürk Cad. 137.Sok. No: 1 Kat 2 Ayazağa, Sarıyer İstanbul

Mail: [email protected]