Privacy Statement on Distributor Relations and Sale and After Sale Support Processes
LOTTE CHEMICAL TURKEU YÜZEY TASARIMLARI SAN. VE TİC. A.Ş. PRIVACY STATEMENT ON DISTRIBUTOR RELATIONS AND SALE AND AFTER-SALE SUPPORT PROCESSES
1. Data Controller
Your personal data are processed by Lotte Chemical Turkey Yüzey Tasarımları San. ve Tic. A.Ş., a joint stock company registered at Manisa Trade Registry Directorate with the registration number of 14936 and having its registered office situated at Manisa OSB IV. Kısım Keçiliköy OSB Mah. Ahmet Nazif Zorlu No: 22 Yunusemre / Manisa (the “Company”), in its capacity as a data controller, in accordance with the provisions of the Law No. 6698 on the Protection of Personal Data (the “LPPD”) and pursuant to this Privacy Statement on Distributor Relations and Sale and After-Sale Support Processes (the “Privacy Statement”).
Our Company respects your rights regarding your privacy and the protection of your personal data, and aims to establish and maintain a relationship with you that is based on trust. Within this scope, our Company processes your personal data in accordance with all legal regulations on the protection of personal data, particularly the LPPD, and adopts all security measures which are required to ensure the security of your data. This Privacy Statement is intended to provide clarifications on the scope of processing of your personal data which are collected within the scope of the sale of our Company’s products and/or services to our distributors and/or the after-sale support activities including the services rendered to the customers of our distributors and your potential or existing distributor relationship with our Company or the potential or existing distributor relationship of your employer firm with our Company. For further details on the processing of your personal data by our Company, please visit Lotte Chemical Turkey Yüzey Tasarımları San. ve Tic. A.Ş.’s Policy on the Protection and Processing of Personal Data, which is accessible from https://www.belenco.com/en/policy-on-the-protection-and-processing-of-personal-data.aspx .
2. The Methods of Collection of Your Personal Data
Your personal data are collected by our Company wholly or partly by automated means or provided that the process is a part of any data filing system, through non-automated means, from physical and/or electronic environments, via our Company’s websites, mobile applications, printed forms, customer services line, phone, facsimile, cargo/mail, e-mail, online meeting / communication platforms, request / complaint / suggestion platforms, our Company’s headquarters and factory information desks, integrated systems pertaining to authorized public institutions and private organizations and other related 3rd parties and other methods (channels) which may be included in the future.
3. The Categories of Your Processed Personal Data and the Purposes for and the Legal Basis of the Processing of Your Personal Data
A. In Terms of Our Distributors and Their Personnel
Your personal data categories which are processed within the scope of the management of orders, planning and manufacturing activities; the carrying out of operations management; the management of logistics activities; the sample procurement / support management; the management of sale of goods / services; the management of the issuance / amendment /cancellation of invoices, payments and collections and other accounting and financial affairs (e.g., current card opening, return/declaration management); the management of after-sale support activities (e.g., legal warranty, returns, repairs, maintenance, delivery); the selection, inspection and management of domestic distributors; the management of financial status inquiry through authorized institutions concerning the distributor selections; the management of distributor relations; the management of distributor satisfaction; the management of requests / complaints / suggestions of 3rd parties other than the distributor or the distributor’s customers; the management of customer services line; the management of internal / external travel / accommodation; the management of audits and internal audits; the management of communication, audit and reporting within the scope of compliance with the regional/global policies and procedures of our group companies and shareholders; the management of legal and consultancy affairs including the fulfilment of the statutory obligations and the conducting of disputes, to which the Company is a party and/or in which the Company is involved (e.g. lawsuits / execution proceedings / mediation); the management of mandatory communications; the management of storage and archiving activities; the management of information security activities; and the management of quality standards procedures including product / service / process improvement processes, and the purposes for and the legal basis for the processing and transfer of your personal data are thoroughly explained herein below.
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Personal Data Category
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The Purposes for and Legal Basis of Processing of Personal Data
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| Identity Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Information Security Processes;
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Conducting of Finance and Accounting Affairs;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Carrying out of After-Sale Support Services for Goods / Services;
· Conducting of Goods / Services Sale Processes;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Customer Relations Management Processes;
· Conducting of Activities Intended for Customer Satisfaction;
· Conducting of Risk Management Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Follow-up of Requests / Complaints;
· Ensuring the Security of Movable Properties and Resources;
· Ensuring the Security of the Data Controller’s Operations;
· Providing Information to Authorized Individuals, Institutions and Organizations.
In addition, your personal data within this category are processed within the scope of the management of financial status inquiry through authorized institutions concerning the distributor selections, on the basis of the personal data processing condition (legal ground) of the existence of explicit consent, as stipulated in article 5(1) of the LPPD (if so, given for the aforesaid process), and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Finance and Accounting Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Risk Management Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes.
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| Communication Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Conducting of Finance and Accounting Affairs;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Logistics Activities;
· Carrying out of After-Sale Support for Goods / Services;
· Conducting of Goods / Services Sale Processes;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Customer Relations Management Processes;
· Conducting of Activities Intended for Customer Satisfaction;
· Conducting of Risk Management Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
In addition, your personal data within this category are processed within the scope of the management of financial status inquiry through authorized institutions concerning the distributor selections, on the basis of the personal data processing condition (legal ground) of the existence of explicit consent, as stipulated in article 5(1) of the LPPD (if so, given for the aforesaid process), and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Finance and Accounting Affairs;
· Conducting of Risk Management Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes.
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| Professional Work Experience Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Carrying out of After-Sale Support Services for Goods / Services;
· Conducting of Goods / Services Sale Processes;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Customer Relations Management Processes;
· Conducting of Activities Intended for Customer Satisfaction;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Finance Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Finance and Accounting Affairs;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Storage and Archiving Activities;
· Providing Information to Authorized Individuals, Institutions and Organizations.
In addition, your personal data within this category are processed within the scope of the management of financial status inquiry through authorized institutions concerning the distributor selections, on the basis of the personal data processing condition (legal ground) of the existence of explicit consent, as stipulated in article 5(1) of the LPPD (if so, given for the aforesaid process), and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Finance and Accounting Affairs;
· Conducting of Risk Management Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes.
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Audio-Visual Data
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Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Carrying out of After-Sale Support Services for Goods / Services;
· Conducting of Customer Relations Management Processes;
· Conducting of Activities Intended for Customer Satisfaction;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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Transaction Security Data
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Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Information Security Processes;
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Customer Relations Management Processes;
· Conducting of Activities Intended for Customer Satisfaction;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Request / Complaint / Suggestion Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Carrying out of After-Sale Support Services for Goods / Services;
· Conducting of Customer Relations Management Processes;
· Conducting of Activities Intended for Customer Satisfaction;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Legal Transaction Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Storage and Archiving Activities;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Risk Management Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (€) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2€) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Storage and Archiving Activities;
· Providing Information to Authorized Individuals, Institutions and Organizations.
In addition, your personal data within this category are processed within the scope of the management of financial status inquiry through authorized institutions concerning the distributor selections, on the basis of the personal data processing condition (legal ground) of the existence of explicit consent, as stipulated in article 5(1) of the LPPD (if so, given for the aforesaid process), and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Finance and Accounting Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Risk Management Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes.
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A. In Terms of the Customers of Our Distributors
Your personal data categories which are processed within the scope of the carrying out of operations management; the management of logistics activities; the sample procurement / support management; the management of support activities after sale by distributors (e.g. legal warranty, returns, repairs, maintenance, delivery); the carrying out of experience management of the distributors’ customers; the management of distributors’ customer satisfaction; the management of requests / complaints / suggestions of 3rd parties; the management of customer services line; the management of internal / external travel / accommodation; the management of audits and internal audits; the management of communication, audit and reporting within the scope of compliance with the regional/global policies and procedures of our group companies and shareholders; the management of legal and consultancy affairs including the fulfilment of the statutory obligations and the conducting of disputes, to which the Company is a party and/or in which the Company is involved (e.g. lawsuits / execution proceedings / mediation); the management of mandatory communications; the management of storage and archiving activities; the management of information security activities; and the management of quality standards procedures including product / service / process improvement processes, and the purposes for and the legal basis for the processing and transfer of your personal data are thoroughly explained herein below.
| Personal Data Category |
The Purposes for and Legal Basis of Processing of Personal Data |
| Identity Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Information Security Processes;
· Conducting of Audit / Ethics Activities;
· Conducting of Activities Intended for Relations Management with and Satisfaction of Distributor’s Customers;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Carrying out of After-Sale Support Services for Goods / Services;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Communication Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Audit / Ethics Activities;
· Conducting of Activities Intended for Relations Management with and Satisfaction of Distributor’s Customers;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Logistics Activities;
· Carrying out of After-Sale Support Services for Goods / Services;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Distributor’s Customers’ Purchase Transaction Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Audit / Ethics Activities;
· Conducting of Activities Intended for Relations Management with and Satisfaction of Distributor’s Customers;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Carrying out of After-Sale Support Services for Goods / Services;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Professional Work Experience Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Audit / Ethics Activities;
· Conducting of Activities Intended for Relations Management with and Satisfaction of Distributor’s Customers;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Logistics Activities;
· Carrying out of After-Sale Support Services for Goods / Services;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Audio-Visual Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Audit / Ethics Activities;
· Conducting of Activities Intended for Relations Management with and Satisfaction of Distributor’s Customers;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Carrying out of After-Sale Support Services for Goods / Services;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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Transaction Security Data
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Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Information Security Processes;
· Conducting of Audit / Ethics Activities;
· Conducting of Activities Intended for Relations Management with and Satisfaction of Distributor’s Customers;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Request / Complaint / Suggestion Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Audit / Ethics Activities;
· Conducting of Activities Intended for Relations Management with and Satisfaction of Distributor’s Customers;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Carrying out of After-Sale Support Services for Goods / Services;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Legal Transaction Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interests are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Storage and Archiving Activities;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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4. The Domestic and Cross-Border Transfer of Your Personal Data to Third Parties
Your personal data which are retained by our Company may be accessed solely by our personnel who have been granted with restricted access authorization for the aforementioned purposes, to the extent as is necessary to fulfill their duties, and will not be transferred to third parties located in Turkey and/or abroad in cases where the conditions for transfer which are regulated in articles 8 and/or 9 of the LPPD are not satisfied. Nevertheless, your personal data which are processed within the scope of each personal data category listed hereinabove may be transferred to the following recipient groups if the aforesaid personal data processing conditions (legal grounds) for the data category concerned are further satisfied in terms of the purposes for transfer, and in accordance with articles 8 and/or 9 of the LPPD:
· to our service providers located in Turkey and/or abroad including our group companies acting as a service provider (e.g. sworn-in certified public accountants, tax and legal consultants, auditing/accounting companies, logistics companies, contracted workshops, information technology and data hosting service providers), as limited with the identity, communication, professional work experience, audio-visual, distributor’s customers’ purchase transaction, request / complaint / suggestion, finance and transaction security, legal transaction and risk management personal data categories and, for the purposes as specified hereinabove for each data category, and particularly, in order to ensure the procurement of products and/services for the execution of our Company’s operations;
· to our distributors located in Turkey and/or abroad, as limited with the identity, communication, professional work experience, audio-visual, distributor’s customers’ purchase transaction, request / complaint / suggestion, transaction security and legal transaction personal data categories, for the purposes as specified hereinabove for each data category, and particularly, in order to provide sale or after-sale support services for our Company’s goods and/or services;
· to our group companies and shareholders located overseas, as limited with the identity, communication, professional work experience, audio-visual, distributor’s customers’ purchase transaction, request /complaint / suggestion, finance, legal transaction, transaction security, and risk management personal data categories, for the purposes as specified hereinabove for each data category, and particularly, in order to enable the planning and/or materialization of the communication, audit and reporting activities for compliance with regional/global policies and procedures;
· to the Risk Center of Banks Association of Turkey, KKB Kredi Kayıt Bürosu A.Ş. (Credit Bureau Joint Stock Company) and other risk management and rating institutions (e.g. Exim Bank) located in Turkey, as limited with identity, communication, risk management and finance personal data categories, for the purposes as specified hereinabove for each data category, and particularly, in order to identify financial capability and credibility and crime prevention and prevention of laundering of proceeds of crime, for the establishment and maintenance of potential and existing distributor relations by our Company;
· to potential buyers, sellers or other transacting parties located in Turkey and/or abroad and their employees, consultants and database service providers involved in the process, who are under a confidentiality obligation, as limited with the identity, communication, professional work experience, audio-visual, legal transaction, risk management, transaction security, distributor’s customers’ purchase transaction, finance and request /complaint / suggestion personal data categories, for the purposes as specified hereinabove for each data category, and particularly, in order to facilitate the carrying out of the legal and financial due diligence of our Company in case of any potential corporate merger, acquisition, joint venture, de-merger and other structural changes; and
· to the authorized public institutions and organizations (e.g. courts, notaries, tax offices) in Turkey and/or abroad, as limited with the identity, communication, professional work experience, audio-visual, distributor’s customers’ purchase transaction, request /complaint / suggestion, finance, transaction security, legal transaction and risk management personal data categories, for the purposes as specified hereinabove for each data category, and particularly, in order to fulfill our Company’s statutory obligations and the follow-up the legal affairs thereof.
5. The Period for Processing of Your Personal Data
Your personal data which are acquired during our Company’s operations are retained and disposed pursuant to the general principles and regulations laid down in our Company’s policies and procedures on retention and disposal, which are drafted in accordance with primarily, the Constitution, and the LPDD, the Regulation on the Deletion, Destruction and Anonymization of Personal Data and other applicable legislation.
Within this scope, if all of the aforementioned personal data processing conditions cease to exist, your personal data will be disposed accordingly. Your personal data will then be continued to be processed during the statutory limitation periods pertaining to the specific process. Your personal data which are processed on the basis of the requirement of the attainment of explicit consent for personal data processing will be disposed at the first disposal period following the revocation of your explicit consent. Please see section 6 of this Privacy Statement for your requests concerning the disposal of your personal data.
6. Your Rights under the LPPD
Pursuant to article 11 of the LPPD, you possess the following rights, as a data subject:
- being informed of whether your personal data are processed by our Company or not;
- requesting information thereon if your personal data have been processed;
- being informed of the purpose for the processing of your personal data and whether such data were used in conformity with such purpose or not;
- knowing the third parties in Turkey or abroad to whom/which personal data are transferred;
- requesting the rectification of incomplete or inaccurate personal data which were processed and the notification, of the operation carried out within this scope, to third parties to whom/which personal data were transferred;
- requesting the deletion or destruction of personal data despite the processing in accordance with the law and other applicable legal provisions, once the reasons necessitating the processing cease to exist, and within this scope, if the personal data were processed incompletely and inaccurately, the notification, of the operation carried out within this scope, to third parties to whom/which personal data were transferred;
- objecting to any outcomes to your detriment by means of the analysis of the processed data exclusively through automated means;
- claiming the compensation of your damages, in case you incur any damages due to the unlawful processing of personal data.
You may submit your application regarding your aforementioned rights, in accordance with the provisions of the Communiqué on the Procedures and Principles of Application to the Data Controller (in writing or electronically, via registered electronic mail (KEP) address, signed with secure electronic signature or mobile signature, or via your e-mail address which had previously been notified to our Company and which is recorded in our system - along with the information / documentation* verifying your identity in order to enable our Company to confirm your status as an actual right-holder/beneficiary (e.g. Turkish ID number or passport number for citizens of other countries, residential address / workplace address for notification/service, mobile phone / landline /facsimile number, e-mail address) by filling in the Data Subject Application Form which is accessible from https://www.belenco.com/en/data-subject-application-form.aspx or through the channels which are indicated in the Data Subject Application Form as pertaining to the data controller, in accordance with the procedures and principles which are mentioned hereinabove and which are laid down in the applicable legislation. Your application will be concluded free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of your request; however, in case the transaction requires an additional cost, you may be charged according to the tariff determined by the Personal Data Protection Board.
* Please note that no special categories of personal data (e.g., religion or blood type information) should be included in the said documentation.