PROTECTION AND PROCESSING OF PERSONAL DATA POLICY

AYKON TÜKETİM MALLARI PAZARLAMA DAĞITIM MADEN SANAYİ VE TİCARET A.Ş.

Your confidentiality is respected and data security is considered important by AYKON Tüketim Malları Pazarlama Dağıtım Maden Sanayi ve Ticaret A.Ş. (Company).  In this context, this text has been prepared to inform and enlighten you pursuant to the Law No. 6698 on the Protection of Personal Data (“Law”, “KVKK”) and other relevant legislation and this text constitutes our Company’s Policy on the Protection, Processing and Archiving of Personal Data.

1. Notification

The Law No. 6698 on the Protection of Personal Data was adopted to protect fundamental right and freedom of the persons, particularly right of privacy, and to govern the liabilities of real and legal persons processing the personal data and the rules and procedures to be followed by them in the processing of personal data. In this text, the visitors are informed and clarified by the Company and “The Permission on Collection, Processing, Protection, Archiving and Sharing of Personal Data” is submitted for visitors’ information and examination.

AYKON Tüketim Malları Pazarlama Dağıtım Maden Sanayi ve Ticaret A.Ş. do hereby agree, declare and undertake that it shall not sell, rent or make your personal data available to the third parties for any purposes other than the data collection purposes specified in the current legal legislation.

2. Processing of Your Personal Data

The processing of your personal data refers to all kinds of transaction performed on the data such as obtaining, storing, preserving, changing, re-organizing, disclosing, transferring, taking over, making available to be obtained, classifying or preventing their usage in a fully or partially automated manner or non-automated provided that it is part of any data recording system.

3. Data Controller and Representative

As per the Law, your personal data may be processed within the scope described in this text by the Company as data controller.  The Company is responsible for establishing and managing the data recording system by determining the purposes and means of processing of personal data registered in the database. It is hereby declared that the Data Controllers shall be entitled to the capacity of registered data controller by performing the data controller record when the Registry is opened.

4. Our Reasons for Processing Your Data

Your personal data are processed by our consultants, call centers or web pages that process data in order to fulfill the obligations arising from the respective legal legislation related to your personal data, to meet the demands within the scope of the performance of the sales, distribution and marketing contract, to draw up sales contract and fulfill the contractual liabilities, to realize contact request, to perform audit, accounting and financial obligations and to reach an agreement carry out personal data processing activity in a purpose-related, limited and measurable manner in line with the correct and, if required, updated, specific, clear and legitimate purposes based on the law and good faith and including, without limitation the foregoing, this personal data are processed for similar purposes as per the article 5 and 6 of the Law. The personal data is kept for the periods stipulated in the law or specified in the VERBIS system (Data Controllers Registry Information System) regarding the personal data processing purpose.

Account reconciliation and information messages will be send to the telephone and contact address notified to us within the framework of fulfilling its obligations towards its customers, business partners, all business partners with whom our Company engage in a business relationship, dealer (registered in the Tobacco and Alcohol Department/TAPDK) and its customers via SMS and E-mail and our customers will be able to perform their transaction securely through the link on the company website, where they can enter with their own user name and password, display their current accounts at our company and make BA-BS account reconciliation.

The personal data processed by the Company under this paragraph covers at least the following data.

Identity information

Contact Information

Customer Transaction Information (tax chart, TAPDK certificate, etc.)

The personal and corporate data also may be requested from the data owners to fulfill the provisions of law so as to maintain its commercial presence and service obligations arising from any contract. The data owners are deemed to accept and declare that they are informed on the processing of their personal data and that they consent to the use of their personal data as set forth hereto by sharing this data with the company.

As per the Article 10 of the KVK Law, our company clarifies personal data owners and provides required information and responds to the applications within the legal period in case the personal data owners request information and make application for enjoy their legal rights.

Our Company complies with the provided regulation with regards to the processing of sensitive personal data in line with the Article 6 of the KVK Law.

Your Personal Data may be processed by the Company as a Data Officer without seeking any explicit consent, if:

It is provided explicitly in the law;

To be in a position where no consent is explained due to actual impossibility or it is obligatory for the person who is not entitled to legal validity to protect his/her or someone else's life or body integrity.

It is required to process the personal data belonging to the contracting parties provided that it is directly related to the execution of the contract.

It is mandatory for fulfilling the legal obligation as data controller;

It has been made public by the relevant person.

It is required to process data for the establishment, exercise and protection of a right

It is mandatory to process data for legitimate interests of data controller provided that it does not harm the fundamental rights and freedoms of the relevant person

The personal data may be used based on any aforementioned purposes for the following conditions.

Your personal data can be processed for the following purposes;

To contact with you and others as a part of the job.

To send important details and other administrative information on the changes in our service terms and in our electronic services.

To ensure the improvement of quality, training and security (for instance, through phone calls made to our contact numbers, recorded or tracked)
To resolve the complaints and put data access or correction requests into process.

To prevent, detect and investigate crimes including forgery and money laundering and to analyze and manage other commercial risks.

To comply with applicable law and regulatory obligations (including those outside your country of domicile) including the prevention of money laundry and anti-terrorism law; to respect the legal process and to respond the requests received from official and public authorities (including those outside your country of domicile).

To manage our infrastructure and commercial activities and to abide by internal policy and procedures including those related to the auditing, finance and accounting; billing and collections; information processing systems; data and website hosting; business continuity and records, document and print management.

To determine legal rights and defend them; to protect our activities or that of our business partners; our rights, confidentiality, security or goods and/or your or other’s assets and to apply usable remedies or limit our damage.

To carry out marketing research and analysis including satisfaction surveys.

To enable you to participate into contests, prize draws and similar promotions and administer these activities.

To facilitate social media sharing function.

To personalize your experience regarding electronic services by providing you with tailored information and advertisements.

5. To Whom and For What Purposes the Personal Data Processed May Be Transferred

Your personal data shared with our Company may be transferred to our business partners, suppliers, shareholders, group companies, legally authorized public institutions and organizations within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law to ensure the legal and commercial security of our Company, our Group Companies, business partners, shareholders and persons and institutions with whom our company engages in business and commercial relationship, to make necessary works by business units so that you can benefit from product and services provided by our Company and its partners, to offer products and services to you by privatizing them according to your appreciation, usage habits and needs, to determine, improve and apply commercial and business strategies, to assure the execution of human resources policies with sales, marketing, distribution, collection, accounting and audit.

6. Method for Collecting Personal Data and Its Legal Ground

Your personal data is collected by our Company to conduct our commercial activities and provide you with higher quality and safe service based on the different legal reasons through various channels (website, call center, accounting unit, sales managers/consultant). The personal data gathered based on the abovementioned legal reasons are processed and transferred according to the purposes stated in article (b) and (c) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVK Law.

7. The Rights of Personal Data Owner Specified in the Article 11 of the KVK Law

In case you deliver your requests regarding your rights to our Company through the following methods set forth in this Policy and Clarification Text as personal data owners, our Company will conclude the said requests free of charge within at least thirty days based on the nature of the request. However, if a certain fee is provided by the Personal Data Protection Board, the fee determined by our Company will be charged. In this regard, the personal data owners are entitled to following issues:

To find out whether your personal data is processed,

To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,

To learn the third parties to whom your personal data will be transfered at home and abroad,

In case your personal data is incomplete or incorrectly processed, to request their correction and to demand notification of the transaction realized in this context to the third parties to whom your personal data is transferred,

Though it has been processed in accordance with the provisions of the KVK and other respective legislation, to request the deletion or destruction of your personal data in case the reasons requiring the processing have disappeared, and in this respect, to request the notification of the transaction to the third parties to whom your personal data is transferred,

To object any result occurring against you, provided that the processed data is analyzed solely through the automatic systems,

To claim for the compensation for damage where your personal data is harmed due to the illegal processing.

8. Application of Personal Data Owner and KVK Application Form

As per the paragraph 1 of the Article 13 of the KVK Law and the Communiqué on the Procedures and Principles of Application to the Data Controller stipulated in the Official Gazette dated 10.03.2018 and numbered 30356;

Application Procedure

The relevant person submits his/her request to the data controller within the scope of the rights specified in the Article 11 of the Law in writing or via registered electronic mail (KEP), secure electronic signature, mobile signature or by using e-mail address previously notified to the data controller and registered in the data controller's system or through a software or application developed for the purpose of application.

In the said application,

It is obligatory to include:

The name, surname and signature, if it is written,

TR ID no for the citizens of the Republic of Turkey, and the nationality, passport number and if any the identification number for foreigners,

The residential address or business address based on notification,

The electronic mail address, telephone and fax number, if any, and

The subject of said request.

The relevant information and documents are included in application.

The date on which the document is notified to the data controller or representative specified in the written application is the application date.
Concerning the application made by other methods, the date when the application is delivered to the data controller is the application date.

Respond to Application

The data controller is responsible for taking  all necessary administrative and technical measures to conclude effectively the application to be made by the relevant person in accordance with the law and good faith within the scope pf this Communique.

The data controller accepts the application or rejects it by explaining the ground.

The data controller conveys his/her respond to the relevant person in writing or electronically.

Response letter involves the following:

The information on the data controller or representative,

The name and surname of the applicant, TR ID No for the citizens of the Republic of Turkey, and the nationality, passport number and if any the identification number for foreigners, the residential address or business address based on notification, the electronic mail address, telephone and fax number, if any,

The subject of said request and

The explanation of data controller on the said application.

The data controller concludes the requests contained in the application free of charge as soon as possible and within thirty days at the latest depending on the nature of the request. Notwithstanding, the fee specified in the Article 7 may be charged in case the transaction requires an additional cost. If the application is caused by the error of the data controller, the fee is returned to the relevant person.

In case the request of the relevant person is accepted, the requirement of the request is fulfilled as soon as possible and the relevant person is informed.

Fee

If the application of the person is responded in writing, no fee will be charged up to ten pages. A transaction fee amounting to 1 Turkish Lira can be charged for each page more ten pages.

In case the respond to the application is given in a recording medium such as CD and flash disk, the fee which can be requested by the data controller cannot exceed the cost of the recording medium.

You can download “KVK Application Form” through the link on our Website to use your rights related to the Protection of Your Personal Data and send your request including your explanation on your right that you request to use from the rights mentioned above to İvedikköy Mahallesi 1566. Cadde No:8 Yenimahalle/Ankara by filling the “KVK Application Form” at ankarabilgi@aykonpazarlama.com.tr and by submitting a signed copy of the form through a notary public or other methods stipulated in the KVK Law.

9. Cookie Policy

A cookie is a small text file where the data on your roaming in that website are stored on your PC, phone or other device.

The purpose of the Cookie Policy is to offer an interesting and tailored website/application and ad portfolio by ensuring the proper functioning of a website, improving the user experience, developing and optimizing the site, rendering more  appropriate, interest-based advertising. Furthermore, a cookie is used to remember your preferences (language, country, etc.) during your visit to our site and in future visits.

Pursuant to this Policy, the “Cookies” used by this website as the main information storage method and the "Local Storage” area of ​​the browser are used for the same purpose. All information contained in this section is also applied to the abovementioned  “Local Storage”. We do not store the sensitive personal data such as your address, password, credit or similar in the Cookies we use.

Escape Clause for Not Using Cookie in Website If you don’t want to use any Cookie in this website taking into consideration the aforesaid limitations, you must first disable the use of Cookie in your browser and then delete the Cookies recorded in your browser in relation to this website. You can use this option at any time to avoid use of Cookies.

Disabling the use of Cookie: You can restrict, block or delete the Cookies used on this website by altering the settings of your browser at any time by following the abovementioned steps. Although the settings vary in each browser, the Cookies are usually located in the “Contact”, “Information Form” menu. For further information on setting Cookies in your browser, see the “Help” menu of the browser.

The Company reserves the right to make changes and updates in its Company KVK Policy, which may be stated in the KVK Law.

AYKON Tüketim Malları Pazarlama Dağıtım Maden Sanayi ve Ticaret A.Ş.
İvedikköy mahallesi 1566. Cadde No:8 Yenimahalle/Ankara
E-mail of Data Controller : ankarabilgi@aykonpazarlama.com.tr
Tel : (0312) 334 06 40- (0312) 397 39 99"