Policy On The Protection And Processing Of Personal Data

Policy On The Protection And Processing Of Personal Data

KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI CLARIFICATION TEXT ON THE PROCESSING OF PERSONAL DATA

Data Controller: KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI

As KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI, we have prepared this Clarification Text on the Processing of Personal Data with the purpose of illuminating data subjects in relation to processing, storage and transfer of your personal data as part of our activities arising from the Personal Data Protection Law no. 6698 (the “KVKK”) and applicable legislation and regulations. In addition, the Cookie Policy includes detailed information about the cookies and SDKs used in case you visit our website, mobile site and/or mobile application, and the personal data processed through these platforms are also explained in this Clarification Text. The Clarification Text shall be effective as of the date it is published by KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI. KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI may make changes in the Clarification Text at any time, adhering to the legal regulations. https://www.turktower.com.tr The changes to be made shall have immediate effect upon publication of the Clarification Text on the website

  1. I. METHOD AND LEGAL REASON OF COLLECTING PERSONAL DATA

    • For purposes of using in or carrying out our services that will be offered to you and identifying the owner and addressee of all kinds of business and transactions, your personal data may be collected, processed and transferred through fully automatic, partially automatic or non-automatic systems, including face-to-face channels, call center, website, mobile applications, messages, e-mails, voice response systems and all kinds of written, verbal and electronic media, by KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI based on your consent for the processing of your personal data or the legal reasons specified in Articles 5 and 6 of the Law or other legislation and listed below:
    • If it is stipulated in any national or international legislation to which KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI is subject to;
    • If processing of data is mandatory should you become unable to express your consent in case of physical impossibility or data processing is mandatory in order to protect the life or physical integrity of the data subject or another person whose consent is not legally valid,
    • Provided that it is directly related to the establishment or performance of a contract, it is necessary to process the personal data of the parties to the contract to be able to provide the requested products and services or to fulfill the requirements of the contracts concluded;
    • Data processing is mandatory in order for KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI to fulfill its legal obligations;
    • Your personal data has been made public by you;
    • Data processing is mandatory for the establishment, exercise or protection of a right;

    Data processing is obligatory for the legitimate interests of KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI provided that such processing of data does not harm your fundamental rights and freedoms.

  2. II. PURPOSES OF PROCESSING PERSONAL DATA

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

    • Offering, charging and invoicing products and services; performing and following up the transactions you request regarding the products and services ordered, purchased and/or used;
    • Introducing and marketing products and services and contacting you regarding these activities; informing you about campaigns, discounts, benefits, conditions, pricing; providing opportunities such as membership, activities, and economic advantages, and performing the necessary procedures for their use;
    • Confirming your identity information and documents when necessary; taking necessary actions to prevent misuse, loss and fraud;
    • Resolving disputes, especially billing disputes;
    • Conducting activities such as diversification, measurement, auditing and analysis of products and services, training of employees, and financial reporting; evaluating your interest in products and services and researching customer satisfaction; providing call center services; handling the questions, complaints and notifications from you; keeping your information that should be kept in accordance with the relevant legislation; copying and backing up information to prevent loss of information; and ensuring the consistency of your information;
    • Fulfilling legal obligations required or mandated by regulatory and supervisory institutions and legal regulations, and conducting legal proceedings and legal procedures.

  3. III. PERSONAL DATA TO BE STORED AND PROCESSED

    Personal data means information that identifies you or makes you identifiable. Your personal data that can be processed by KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI are as follows:

    • Identity Information: This data category refers to types of data such as TR Identity Number, name, last name, place and date of birth, gender, copy of identity document, and photograph.
    • Contact Information: This data category refers to types of data such as address, telephone/fax number, and e-mail address.
    • Membership Information: This data category refers to types of data such as membership number, membership agreement number, your information regarding the sale and use of products and services, as well as your information regarding invoices, debts and payments.
    • Information in Sales Channels: This data category refers to types of data such as the information and documents you transmit in sales processes, data obtained when communicating via electronic or physical means, your voice call recordings stored in accordance with call center standards, and information on your requests and transactions in sales channels.
    • Payment and Bank Information: This data category refers to your bank information, including your credit card, bank account and debit card.
    • Sensitive Personal Information: This data category refers to types of data of people that should be prioritized socially (such as people with disabilities, veterans, etc.).

  4. IV. TRANSFERRING PERSONAL DATA

    Your personal data may be transferred to the following domestic and foreign buyer groups within the scope of the Law and other applicable legislation:

    • The suppliers and business partners that we work with for the supply or delivery of the products and services you want to buy or use;
    • The business partners and suppliers with whom we cooperate and/or from whom we procure services in order to offer and promote products and services;
    • Your proxies, guardians and representative authorized by you;
    • Institutions or organizations authorized to request your personal data, such as regulatory and supervisory institutions, courts and execution offices, and persons designated by them.

  5. V. YOUR RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA

    In accordance with Article 11 of the Law, by applying to KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI using one of the methods specified in the “Contact” section of this Policy, you have the right to:

    • learn whether your personal data is processed,
    • if processed, request information on the processing of your data,
    • learn the purpose of processing of your personal data and whether the data is used according to its purpose,
    • know the third parties to whom your personal data is transferred within the country or abroad,
    • request for correction of your personal data if missing or inaccurate data is processed,
    • request for deletion or destruction of your personal data in accordance with the conditions set forth in Article 7 of the Law,
    • request that the third parties to whom your personal data has been transferred are informed about the procedures done as per your abovementioned rights to the correction, deletion or destruction,
    • demand compensation of damages incurred due to processing of your personal data in violation of the Law.

  6. VI. CONTACT

    You can send your requests regarding the implementation of the Law and your questions about your personal data by sending an e-mail from your registered e-mail (KEP) address to the e-mail address kulas@hs01.kep.tr, or by writing to us and sending your letter through a notary public to the address KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI - Kisikli Mah. Kisikli Cad. No:105 K:1 D:3 Uskudar/ISTANBUL” or send it to the e-mail address toweriletisim@turktower.com.tr, in a form that is prepared in accordance with the Communiqué on Application Procedures and Principles to the Data Controller.

COOKIE POLICY

This Policy has been prepared to provide information on cookies and similar technologies (collectively referred to as “cookies”) that can be used on the website and applications of KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI. If you use the website and applications of KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI; cookies and similar technologies can be used, saved on your device and your personal data can be processed in accordance with the purposes and methods stated below in accordance with the Cookie Policy of KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI.

WHAT IS A COOKIE?

Cookies are files or pieces of information that may be stored on your computer (or other internet-enabled devices such as smartphones and tablets) when you visit a website. A cookie usually contains the name of the website from which it was received, the “lifetime” of the cookie and a unique numerical value, which is usually generated randomly. Cookies record your actions and preferred settings during your browser session or for your next visit to our website. If you visit our websites again, this information will be sent back to the server. In this way, your computer or mobile device is automatically recognized and, for example, your preferred settings are automatically loaded for your convenience. Cookies offer you the advantage of not needing to make settings each time you visit the website or applications of KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI.

WHAT ARE THE PURPOSES OF USE OF COOKIES?

Cookies are used for enabling you to effectively switch between web pages, facilitating the use of websites, following your preferences to improve our offers, our online visibility and advertising according to your needs in terms of content, graphics and technology, enriching and improving the overall user experience, statistically evaluating usage data for our websites, and helping us improve the structure and content of our websites.

In addition, cookies may also be used to better customize our services in line with your interests and needs and/or to speed up your future activities and experiences on our websites.

HOW TO CHANGE COOKIE PREFERENCES

Although many internet browsers accept cookies by default, you can refuse or delete cookies from the settings section of your browser. For detailed information on how to edit your browser settings, please refer to your browser’s help screen.

If you choose to refuse or delete cookies, please keep in mind that this may prevent some features or services of KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI website from working properly, and therefore affect your experience on KULE VERICI TESISLERI ISLETIM VE TEKNOLOJILERI ANONIM SIRKETI website. Since your cookie preferences are managed through the browser you use, you will also need to renew your opt-out preferences when you use a different browser or purchase a new computer.