Personal Data Processing Policy

Dear Customers, Potential Customers, and Website Visitors, (“Company”) takes great care in protecting your personal data. In this context, we would like to inform you about your personal data and the processing procedures as the “data controller” in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”).

What Personal Data Do We Process?

In the Establishment of the Electronic Commerce Agreement:

• Your identity information (name, surname, date of birth, ID number)
• Your contact information (address, email address, telephone number)
• If you request an invoice, your ID number and tax identification number (if shared with us)
• Processing for payment with a credit card to be sent to the payment institution
• Information regarding the bank account and the bank you use if bank transfer is selected as the payment method
• Records of the services provided by our company (request and complaint management)
• Records generated from the forms received regarding your complaints
• Customer information related to our electronic commerce system, such as storage and use of information for distinguishing records from other customers without determining the processing purposes and means.

If You Grant Electronic Commercial Communication Permission:

• Your identity information (name, surname)
• Your contact information (address, email address, telephone number)
• Date of birth, address, customer information, invoice content, payment methods (cash, credit card, etc.), old and new mobile/home/work phone/fax numbers, email addresses, identification information (cookies, web browser indicators, IP, beacon, wired/wireless network connection information, etc.)

Purposes of Processing Your Personal Data

Your personal data may be processed in accordance with the legislation on the protection of personal data for the following purposes:

General Purposes:

• To resolve your problems and complaints when you contact us and to communicate with you if necessary, by processing your identity and contact information.
• To fulfill our obligations arising from the legislation and to fulfill our other legal obligations, especially information security, with authorized and competent public institutions and organizations, by processing your identity, contact, invoice, and purchase information.
• To exercise all kinds of rights, including filing lawsuits, responding to claims, and raising objections against official institutions such as courts, enforcement offices, and arbitration boards in case of disputes arising from the contract, by processing your identity, contact, invoice, and purchase information.
• To distinguish the records created for you in our system from the records of other customers, and to enable you to benefit from operational processes by processing your identity and contact information.
• To issue an invoice upon your request by processing your identity and invoice information.
• If you choose to make a payment by credit card, to collect the payment (credit card information is transferred to the payment institution without being stored).
• To fulfill our obligations arising from the legislation regarding data retention by processing your identity, purchase, and invoice information.

If You Grant Electronic Commercial Communication Permission:

We process your identity, contact, and marketing-related information to carry out general or personalized advertisements, notifications, and all kinds of commercial communication activities directed to you.

Method of Collection and Legal Basis for Processing Your Personal Data

Your personal data is processed by Vilutra Technology Incorporated within the framework of your consent given for electronic commercial communication and through delivery, transaction, automatic methods, or electronic systems, especially for requests and complaints.

As Vilutra Technology Incorporated, we collect your personal data based on the legal grounds of “necessity for the performance of a contract and the establishment of a contract,” “fulfillment of a legal obligation,” and “legitimate interests of the data controller”for processing that is necessary for the establishment and performance of the contract, fulfillment of legal obligations, and the legitimate interests of Vilutra Technology Incorporated. We also collect your personal data based on your explicit consent and the legal grounds of “fulfillment of a legal obligation” for our obligations regarding data retention and “necessity for the performance of a contract” and “necessity for the exercise of a right” for tracking your requests and complaints.

All data provided by our customers who have entered into a contract or have a business relationship with us are processed by Vilutra Technology Incorporated based on the consent of our customers and the provisions of the legislation.

Transfer of Your Personal Data

As Vilutra Technology Incorporated, we may transfer your personal data:

• Within Turkey and abroad to our domestic and international business partners and service providers (such as call centers, companies providing personal data collection services through devices, marketing consultancy firms, database providers, electronic communication service providers, consultancy firms, etc.) for purposes such as obtaining information technology, marketing activities, or specialized consulting services, or in cases where our business partners’ servers are located abroad.
• To our dealers and business partners for the purpose of resolving your requests.
• To our business partners to whom you have granted permission and with whom you would like to receive services.
• To authorized and competent public institutions and authorities, as well as judicial authorities, to fulfill our obligations to provide information, documents, and other relevant obligations, and to exercise our legal rights such as the right to file and respond to lawsuits, as requested by these institutions, organizations, and authorities.
• If you choose to make a payment by credit card, your credit card information will be shared with relevant third parties, such as banks and electronic payment service providers, without being stored by Vilutra Technology Incorporated.

Your Rights

In accordance with Article 11 of the Law, you have the right to:

• Learn whether your personal data is being processed,
• Request information if your personal data has been processed,
• Learn the purpose of the processing of personal data and whether they are used in accordance with their purpose,
• Know the third parties to whom your personal data is transferred, whether domestically or abroad,
• Request the correction of your incomplete or inaccurate personal data,
• Request the deletion or destruction of your personal data within the framework of the conditions stipulated in the KVKK legislation,
• Request that the third parties to whom your personal data has been transferred be notified,
• Object to the occurrence of a result against you by the analysis of your processed data exclusively through automated systems,
• Request the compensation of damages in case you incur damages due to the unlawful processing of your personal data.

Contact

You can submit your applications to Vilutra Technology Incorporated as the Data Controller by sending an email to the designated email address for the application procedure (MAIL ADDRESS WILL BE WRITTEN). You can also reach us through the registered email address in the system. Alternatively, you can send your written requests to the address specified below (Please note that in cases where the relevant request must be made in a specific procedure as required by laws, it is important to comply with that procedure).

Company Name: Vilutra Technology Incorporated

Address:

Tax Office and Tax ID:

Telephone:

Trade Registry Number:

MERSIS Number: