İLVİ AYAKKABI DERİ VE TEKSTİL ÜRÜNLERİ SANAYİ VE TİCARET ANONİM ŞİRKETİ

CLARIFICATION TEXT ON COLLECTING, PROCESSING AND PROTECTING PERSONAL DATA

1- GENERAL STATEMENTS VE DEFINITIONS

This clarification text has been issued in order to ensure İlvi Ayakkabı Deri ve Tekstil ürünleri Sanayi ve Ticaret A.Ş fulfill its “obligation to clarify” within the framework of article 10 of the Law on Protection Of Personal Data numbered 6698 (Law) as “Data Controller”.

The definitions of terms mentioned below in this clarification text refer to the definitions stated in the law numbered 6698 and the regulations and declarations related to this law.

Personal Data: It refers to all kind of information related to the identified or identifiable natural person,
Processing of Personal Data: It is the series of operations that are carried out on personal data such as collection, recording, storage, retention, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification or preventing the use thereof, fully or partially through automatic means or through non-automatic means only for the process which is a part of any data registry system set out in the Law,,
Data Subject: It refers to the natural person whose personal data will be processed,,
Explicit consent: Consent that relates to a specified issue, declared by free will and based on information,
Anonymisation: Rendering personal data impossible to link with an identified or identifiable natural person, even through matching them with other data,
Data Controller: Data controller is the natural or legal person who determines the purposes for which and means by which personal data is processed and is responsible for establishing and managing the data registry system,
Data Processor: Any natural or legal person who processes the personal data on behalf of the data controller by the power vested in by the data controller,
Data Registry System: It is a registration system where personal data shall be recorded while getting configured according to determined criteria,
Contact Person: It is the natural person notified by the data controller which is natural and legal person established in Turkey and by representative who represents the data controller which is natural and legal person not established in Turkey during the registration with the Registry for communicating with the Authority relating to obligations within the scope of the Law and secondary legislation to be prepared in accordance with this Law,
Personal data storage and extermination policy: It is a policy that data controllers use it as a basis in order to determine the maximum period of time required for the purpose for which personal data are processed, erased, destructed and anonymised.

2- INFORMATION RELATED TO DATA CONTROLLER

Legal persons are themselves the data controllers for the legal persons. The data controller obligations of legal persons established in Turkey under the Law are fulfilled by capacity of competent to represent and bind the legal person or the person(s) specified in the relevant legislation pursuant to provisions of the relevant legislation. Competent representative may assign one or more persons for its obligations to be fulfilled for the implementation of the Law. This assignment does not remove the responsibilities of legal person pursuant to the provisions of the Law.

İLVİ carries on its activities as a capital company with legal personality established in Turkey. The informations about İLVİ as the data controller are as determined below.

Data Controller’s;

Title	:	İLVİ Ayakkabı Deri ve Tekstil Ürünleri Sanayi ve Ticaret A.Ş.
Mersis (Central Registration System) Number	:	0474066342400001
Address	:	Halaskargazi Mah. Valikonağı Cad. No: Pınarbaşı Apt. 55/A 34371 Nişantaşı / Şişli / İstanbul
Telephone Number	:	+90 212 234 41 47-46-49
Fax Number	:	+90 212 234 41 48
Email Address	:	[email protected]
Registered Email Address (KEP)	:	[email protected]

3- OBLIGATIONS OF DATA CONTROLLER

İLVİ is obliged to inform the data subjects about the following within the scope of obligation to clarify;

The identity of the controller and of his representative, if any
The purpose of data processing,
The recipients to whom the data can be transferred, and the purpose of the transfer
The methods and legal reasons of collection of personal data,
The rights of the data subject whose personal data is porcessed,

The data controller is obliged to take all necessary technical and organizational measures to provide an appropriate level of security for the purposes of;

Preventing unlawful processing of personal data,
Preventing unlawful access to personal data,
Ensuring the retention of personal data.

İLVİ does not disclose the personal data which İLVi obtained them by carrying out the necessary audits in order to ensure the implementation of the provisions of the Law numbered 6698 in its own institution or organization to anyone contrary to the provisions of this Law, neither use such data for purposes other than that for which the personal data have been processed.

4- PERSONAL DATA TO BE PROCESSED

Personal data to be processed by İLVİ are stated below and in cases which they are made essential by the laws and/or required, any other type of information can be added and/or changes can be made.

Personal Data to be processed are;

Personal information such as name, surname, Republic of Turkey identity number, date of birth, gender, etc.,
Contact information such as address, telephone number, fax number, email address, etc.,
Tax office and tax number information,
Information such as salary, social security, bank account number and family members of employees,
Information related to subjects such as job and education,

5- METHODS OF COLLECTING PERSONAL DATA

Personal data can be obtained/collected by data subject himself/herself directly as well as indirect ways, including but not limited to, online electronic commerce platforms, franchises, collaborated business partners, institutions and organizations in accordance with the purpose of collecting the personal data to be collected..

6- PURPOSE OF PROCESSING PERSONAL DATA

İLVİ processes the personal data following purposes stated below. These purposes are;

To fulfill the liabilities regarding public claims determined within the framework of tax codes, the Turkish Commercial Code numbered 6102 and other legal regulations,
To take measures regarding the protection of consumers’ rights within the framework of the Consumer Protection Law numbered 6502,
To receive orders made by the data subjects regarding the products they want to purchase from İLVİ, to sell the products, to deliver the products to the data subjects, to ensure that the payments are made, to provide after sales service regarding the product purchased by the data subjects, to assure and assess customer satisfaction, to receive and manage requests and complaints regarding the products or services purchased by the data subjects, if there any,
Setting up the distant sales agreements for the purchases made through the electronic commerce platforms, verifying the identity of data subject,
Improving quality of services,
Making campaigns of products and servies, promoting and advertising them, informing customers about such activities,
Providing security in stores, improving productivity
Give consumers having an İLVİ Card a chance of earning exclusive points (İLVİMoney) or discounts for their purchases within the framework of İLVİ Loyalty Program.

7- TRANSFER AND PROTECTION OF PERSONAL DATA

İLVİ does not transfer personal data obtained in accordance with the purposes for processing the data to third parties without explicit consent of the data subject.

İLVİ may share/transfer personal data with 3rd parties and organizations such as persons, institutions and/or organizations obligated/authorized by the liabilities of tax and social security codes, other laws and legislation, public legal personalities authorized to obtain/collect personal data, including but not limited to, Revenue Administration, Turkish Employment Agency, Social Security Institution, The Financial Crimes Investigation Board, Interbank Card Center, Credit Registration Bureau, İLVİ's domestic/abroad affiliates, companies carried out as franchise, collaborated business partners, institutions and organizations, branches PTT, companies providing logistics support service, consulting service and independent audit service in order to fulfill the purposes to provide a better service within the framework of article 6 with or without any legal obligations under the condition that the rights of the data subject will be reserved within the scope of the Law numbered 6698.

8- OBTAINING EXPLICIT CONSENT ON PROCESSING OF PERSONAL DATA OF THE DATA SUBJECT

Personal data which will be processed by İLVİ shall be processed with explicit consent of the data subject within the framework of the Law numbered 6698. Explicit consent has been defined as consent that relates to a specified issue, declared by free will and based on information

As per the provisions of the Article 5/2 of the Law numbered 6698, personal data may be processed without seeking the explicit consent of the data subject only in cases where one of the following conditions is met:

It is expressly provided for by the laws.
It is necessary for the protection of life or physical integrity of the person himself/herself or of any other person, who is unable to explain his/her consent due to the physical disability or whose consent is not deemed legally valid.
Processing of personal data of the parties of a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
It is necessary for compliance with a legal obligation to which the data controller is subject.
Personal data have been made public by the data subject himself/herself.
Data processing is necessary for the establishment, exercise or protection of any right.
Processing of data is necessary for the legitimate interests pursued by the data controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.

9- TIME PERIOD FOR STORAGE OF PERSONAL DATA

İLVİ shall erase, destruct or anonymise personal data in cases where the reason of processing disappears, storage period determined by the Law and relevant legislation exceeds.

10- THE RIGHTS OF THE DATA SUBJECT

Each person has the right to request to the data controller about him/her;

to learn whether his/her personal data are processed or not,
to demand for information as to if his/her personal data have been processed,
to learn the purpose of the processing of his/her personal data and whether these personal data are used in compliance with the purpose,,
to know the third parties to whom his personal data are transferred in country or abroad,,
to request the rectification of the incomplete or inaccurate data, if any,
to request the erasure or destruction of his/her personal data under the conditions referred to in Article 7 of the Law,
to request reporting of the operations carried out pursuant to sub-paragraphs (d) and (e) Article 11 of the Law to third parties to whom his/her personal data have been transferred,
to object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems,
to claim compensation for the damage arising from the unlawful processing of his/her personal data.

11- REQUEST TO DATA CONTROLLER

Natural persons (data subjects) whose personal data are processed have right to request to the data controllers within the scope of their rights specified in Article 11 of the Law numbered 6698. Data subjects may benefit from this right provided that they make the requests in Turkish. Data subjects may make their requests to İLVİ by one of the communication channels below. Data subjects may make requests;

in writing,
by registered electronic mail (KEP) address,
by secured electronic signature or mobile signature,
by the e-mail address which has been previously recorded in the data controller’s system,
by means of a software or application designed for purposes of this request.

The request must include the following;

Name, surname and signature, if the request is made in writing,
For Turkish Citizens, TC identity number; for foreigners, nationality, passport number or identity number if available,
Residential / business address subject to the notification,
Electronic mail address, telephone, fax number subject to notification if available,
Subject of demand,,

Documents and information regarding the demand shall be attached to the request. Requests can be made by using “Request Form” Communication channels stated in chapter “2- INFORMATION RELATED TO DATA CONTROLLER” of this clarification text herein can be used for the requests to be made by data subjects.

İLVİ shall conclude demands in the request within the shortest time by taking into account the nature of the demand and at the latest within thirty days and free of charge. However if the action requires an extra cost, fees may be charged in the tariff determined by the Board in the Article 7 of “Comminuque On The Principles And Procedures For The Request to Data Controller”. If the request is made due to fault of the data controller, the fee is refunded to data subject.

12- CHANGES AND UPDATES

This clarification text herein has been issued within the scope of the Law numbered 6698 and the Regulations and Comminuques pursuant the Law herein and İLVİ’s purposes and policies of processing personal data. İlgili Required changes can be made in this clarification text due to changes in related legal legislation and/or the changes that may occur in İLVİ’s purposes or policies of processing personal data.

You can find the request form related to your rights stated above here.

İLVİ Ayakkabı Deri ve Tekstil Ürünleri Sanayi ve Ticaret A.Ş.
Mersis (Central Registration System) Number	:	0474066342400001
Address	:	Halaskargazi Mah. Valikonağı Cad. No: Pınarbaşı Apt. 55/A 34371 Nişantaşı / Şişli / İstanbul
Telephone Number	:	+90 850 305 10 11
Fax Number	:	+90 212 234 41 48
Email Address	:	[email protected]