Personal Data Protection and Privacy Policy As 1889's ("Toptanesarpvesal.com"), we would like to inform you that we attach importance to the protection of your Personal Data and that we have taken measures and steps in accordance with the legal regulations in this area. Our company takes the necessary measures to protect the personal data of our valuable members and customers, franchisees, dealers, business partners, shareholders, employees and other real persons who contact us by applying for a job or visiting our website or in any other way. In order to inform you about our Company rules and policies regarding the processing of personal data and the use of cookies and similar technologies within the framework of the Law on the Protection of Personal Data No. Privacy Policy") we have prepared. To ensure that you will be subject to the privacy policy of our company 1889's and www.toptanesarpvesal.com on the privacy, protection, processing, use, modification, communications and other issues of member and customer information on the website and mobile application, and that you accept the terms each time you use our website. We would like to remind you that you should review this text. As a data controller, it is possible for our Company to provide personal data policies and/or notifications different from this text, depending on the type and nature of the relationship between our Company and the data owner. In this case, the special policies and notifications provided to the data subject may contain different or additional matters than the explanations in this Privacy Policy, and the special policies and notifications provided to him by the data owner should be taken into consideration first. LEGAL BASIS AND GENERAL PRINCIPLES Protection of personal data is regulated in Law No. 6698, Law No. 5651 on Regulation of Broadcasts Made on the Internet and Combating Crimes Committed Through These Broadcasts, Law No. 6563 on Regulation of Electronic Commerce and related secondary legislation. In addition, in the Turkish Penal Code No. 5237, a number of penal sanctions have been envisaged for the protection of personal data. In this context, when the Law on the Protection of Personal Data is examined, it is seen that the definition of "personal data" refers to all kinds of information regarding real persons with an identified or identifiable identity. That is, anonymous information, anonymized information and other data that cannot be associated with a specific person are not considered personal data within the scope of this Privacy Policy. Data processing is the acquisition, recording, storage, preservation, modification, rearrangement, disclosure, transfer, takeover, making available, classification of personal data, wholly or partially, by automatic or non-automatic means, provided that it is a part of any data recording system. means any action that can be taken on personal data, such as preventing its use or use.Our company, in order to take necessary measures to protect confidentiality and in accordance with all legal principles regarding the processing of personal data; processes personal data within the framework of the purposes specified in this Privacy Policy, in accordance with the principles listed below:
  1. Being in compliance with the law and honesty rules,
  2. Being accurate and up-to-date when necessary,
  • Processing for specific, explicit and legitimate purposes,
  1. Being connected, limited and restrained for the purpose for which they are processed,
  2. Preservation for as long as required by the relevant legislation or for the purpose for which they are processed
DATA PROCESSED BY 1889's Our company can process general and special personal data with the explicit consent of the data owner or without explicit consent in cases stipulated in Articles 5 and 6 of the KVK Law. General and special data processed by our company are exemplified below, which data will be processed for each data subject; The type of relationship between the data owner and our Company (member-customer, employee, business partner, service provider, etc.) may vary depending on various factors such as its nature and the communication channels used. Our company, in accordance with the relevant legislation and the principles in this Privacy Policy, the type of relationship between the data owner and our Company (for example, the relationship between our Company and a member-customer, employee, business partner, service supplier, dealer, etc.) Types of data can be processed:
  1. Data for recognizing the data owner such as name, surname, profession, title, information about the institution/organization worked, educational background, employment history, gender, marital status, citizenship status, tax liability status and, if any, information about the parent, guardian and attorney,
  2. Data such as date of birth, place of birth, identity number, blood group, religion and photograph included in identification documents such as identity, passport, driver's license,
  • Contact information such as address, telephone, e-mail and fax number of your home, workplace or temporary residence,
  1. In case the data owner (customer-member) connects to our Company's internet address via social media accounts, the information that the data owner approves to be shared through those channels,
  2. Communication records such as telephone calls, e-mail correspondences and other audio and visual data regarding the products purchased by the data owner,
  3. Internet protocol (IP) address, device ID, unique identifier information, device type, advertising ID, unique device icon, statistics on website views, inbound and outbound traffic information, redirect URL, internet log information, location information, visited sites and information on transactions and actions carried out through our websites, platforms, internet network, advertising and e-mail contents.
Purposes of Using Personal Data 1889's may process personal data for the purposes stated below, in cases and to the extent permitted by the legislation, and may be retained for as long as these purposes require.
  1. Fulfilling legal and administrative obligations and exercising the rights arising from the current legislation,
  2. Informing public officials on matters related to public safety upon request and in accordance with the legislation,
  • Negotiation, establishment and performance of agreements concluded/considered to be concluded (For example, establishment of a distance sales agreement between our Company and member customers and fulfillment of the obligations assumed pursuant to the agreements concluded under the relevant articles of the distance sales agreement and the Consumer Protection Law),
  1. Confirming the identity information of the customers who shopped/received through the website/mobile applications and recording the address and other necessary information required for communication,
  2. Providing a better shopping experience for customers, determining suitable products that customers may be interested in by taking into account their interests, informing customers about suitable products, informing them about campaigns, promotions and advantages, providing effective customer service,
  3. Providing suggestions and solutions to our customers by our contracted institutions and solution partners and informing our customers about the services we have provided,
  • Communicating with our customers about the conditions, current status and updates of the contracts we have concluded under the relevant articles of the Law on Distance Sales Contract and Consumer Protection, and providing necessary information,
  • Arranging all records and documents that will be the basis for the transaction in electronic (internet/mobile etc) or paper media,
  1. Increasing customer satisfaction, getting to know our customers who shop from websites and/or mobile applications and using them in customer environment analysis, using them in various marketing and advertising activities, and in this context, conducting surveys in electronic and/or physical environment through contracted institutions,
  2. Evaluation of customer complaints and suggestions about our products and services,
  3. Ensuring and improving coordination, cooperation and efficiency within or between units within our company,
  • Ensuring the security of the website and other electronic systems and physical environments used by our company,
  • Notifying the changes in the legislation or the rules and policies accepted by our Company or making other notifications concerning the data owner,
  • Investigation, detection, prevention of violations of the contract and the law and reporting them to the relevant administrative or judicial authorities,
  1. Resolving current and future legal disputes,
  • Answering requests and questions,
  • Providing employee needs within the framework of our company's human resources policies and conducting, developing and improving recruitment processes,
  • Evaluating and finalizing the suitability of job applications and communicating with job applicants,
  • Developing and improving our company's human resources, public relations and marketing policies,
  1. The necessity of data processing for the establishment, exercise or protection of a right,
  • Protecting the legitimate interests of our Company, provided that it does not harm the fundamental rights and freedoms of the data owner.
Protection, Security and Control of Your Personal Data Within the scope of the relevant legislation, our company takes the necessary technical and administrative measures to ensure the appropriate level of security as a data controller in order to prevent the legal processing of personal data and illegal access to the data and to ensure the preservation of personal data. It is ensured that it is carried out in accordance with the internal policies and rules prepared for the purpose. Studies are carried out to raise awareness among employees about the personal data protection legislation and the in-house policies and rules prepared in this direction, and necessary statements and commitments are taken from employees and individuals and institutions that process data on behalf of our Company, for the confidentiality and protection of data, and violation of these statements and commitments is subject to certain sanctions. Necessary information security measures are implemented to prevent unauthorized access to personal data, and the adequacy of the measures taken is subject to regular checks to continuously improve the existing data security system. The Sharing and Storage Period of Personal Data with Third Parties at home/abroad Provided that you comply with the general principles listed in Article 4 of the KVK Law and the conditions stipulated in Articles 8 and 9, and take the necessary security measures, the purposes indicated under the "Purposes of Processing Personal Data" of this Privacy Policy and the personal data are provided to third parties in the country and abroad. We may transfer it to individuals and process and store it on domestic and foreign servers or other electronic media. In this context, your personal data may be collected from program partner institutions and organizations that we cooperate with in order to carry out our activities, domestic/foreign persons and institutions whose services we use for data storage and from which we receive physical server and/or cloud services, domestic/foreign companies from which we receive services for sending commercial electronic messages, banks. In order to increase customer experience and provide better service, it can be shared with various domestic/foreign advertising companies, agencies and survey companies or other domestic/foreign business partners within the scope of marketing activities. Except where a longer period is legally required or permitted, our Company retains personal data only for the period necessary to fulfill the purposes set out in this Privacy Policy. Personal data whose storage period has expired are deleted, destroyed or anonymized by our Company within the framework of article 7 of the KVK Law.Data Owner's Rights Under the Law on Protection of Personal Data As a data owner, in accordance with Article 11 of the KVK Law:
  1. Learning whether personal data is processed,
  2. to request information about personal data if it has been processed,
  • Learning the purpose of processing personal data and whether they are used in accordance with its purpose,
  1. knowing the third parties to whom personal data is transferred in the country or abroad,
  2. to request correction of personal data in case of incomplete or incorrect processing,
  3. in case the reasons requiring the processing of personal data disappear, requesting their deletion or destruction,
  • to request notification of correction and deletion processes to third parties to whom personal data has been transferred,
  • to object to the emergence of a negative result by analyzing the processed data exclusively through automated systems,
Personal Data Collection Method and Legal Reason Your personal data may be obtained in written, oral, audio or video recording or other physical or electronic forms for the purposes specified in this Privacy Policy, within the framework of the conditions set forth in Articles 5 and 6 of the KVK Law. It can be collected through stores and other physical environments that data owners can contact, website, mobile applications, social media and other public channels, or through training, conferences and similar events organized or by means of investigation. Although we usually obtain personal data from data owners, business partners with whom we work within the framework of the conditions specified in Articles 5 and 6 of the KVK Law, and persons, institutions and organizations that are referenced in job applications or included in the applicant's work and education history, recruitment platforms, It is also possible to obtain it through the persons and institutions represented by the data owner/representing the data owner. USE OF COOKIES AND SIMILAR TECHNOLOGIES While accessing our company's website, electronic platforms, applications or e-mail messages or advertisements sent by our company, small data files can be placed on users' computers, mobile phones, tablets or other devices used to record and collect certain data. These data files placed on computers and other devices may be cookies, pixel tags, flash cookies and web beacons, as well as other technologies for data storage purposes. The term "cookie" is used to express cookies and similar technologies that can be used by our company. Cookies; stores the information it collects through log files, blank gif files and/or third-party sources to create a summary of your preferences, and to make special promotions, offer promotions and marketing offers to you, improve the content of the website or mobile application for you, and/or determine your preferences; can monitor your browsing information and/or your usage history on the site. 1889's website (www.toptanesarpvesal.com) analyzes and interprets visitor movements and preferences, which it monitors during the use of the site, apart from the e-mail addresses and the personal information requested in the membership forms through "cookies". cookie; It is a file consisting mostly of letters and numbers, which allows the device to be detected by being stored in the internet browser or hard disk of the device being used.1889's website (wwwtoptanesarpvesal.com) will collect, process, share with third parties and securely store your browsing information, in order to provide better service to its visitors and within the framework of its legal obligation, provided that it is not used outside of the purposes and scope specified in the text of this Statement on the Protection of Personal Data. Since all kinds of data collected through cookies may not be personal data, it should be taken into account that the data obtained through cookies will only be evaluated within the scope of this Privacy Policy and KVK Law to the extent that they constitute personal data within the framework of Turkish law. Types of Cookies and Use of Third Party Cookies Our company may match the information collected from you on the website (www.toptanesarpvesal.com) through different methods, such as information collected online and offline, or at different times, and use this information together with information obtained from other sources such as third parties. Cookies can be classified in terms of duration or according to the domain name they belong to. Cookies are divided into two as session cookies and permanent cookies if they are classified in terms of duration. Session cookies refer to cookies that are deleted when the user closes the browser, while persistent cookies are cookies that remain on the user's computer/device for a predetermined period of time. Our company uses session cookies and permanent cookies on the website and mobile applications of its brand (1889's). If cookies are classified according to the domain they belong to, they are divided into two as related party cookies and third party cookies. Cookies placed by the visited domain are called related party cookies, while cookies placed by a different domain visited are referred to as third party cookies. In the event that people outside the visited area place a cookie on the user's device through the visited area, a third party cookie is in question. In this context, our Company's cookies also; may use "advertising technology" in order to present you with advertisements that it thinks may be of interest to you when you visit the search engines, website, mobile application and/or websites where the website advertises. Advertising technology uses information about your previous visits to the website/mobile application and websites/mobile applications where the website advertises, in order to present you with tailored advertisements. When serving these ads, a unique third-party cookie may be placed in your browser so that the website can recognize you. Purposes of Use of Cookies by Our Company Our company mainly uses cookies; stores the information it collects through log files, blank gif files and/or third-party sources to create a summary of your preferences, and to make special promotions, offer promotions and marketing offers to you, improve the content of the website or mobile application for you, and/or determine your preferences; uses cookies in order to monitor your browsing information and/or your usage history on the site and thus to provide better services and standards. However, our Company may benefit from the cookies it uses on its website, platform, applications, advertisements and messages for the following purposes.
  1. Use for operational purposes:Our company may use cookies that it deems necessary for the administration and security of its website, platform, application and services. Cookies used to detect irregular behavior in media can be displayed.
  2. Uses for functionality:Our company may use cookies to facilitate the use of its website, platform, application and services and to customize them for users. Technologies that enable us to remember user information and preferences can be given as examples to cookies that are used for functionality.
  • Performance-oriented uses:Our company may also use cookies to increase and measure the performance of its website, application, platform and services. Examples of cookies used for this purpose are technologies that enable us to understand how users use our Company's website, application, platform and services, and to analyze user behavior, and to understand whether the messages we send are interacted with.
  1. Use for advertising purposes:We may use related party cookies and third party cookies for the purpose of transmitting advertisements and similar content for the interests of users through the websites, platforms and applications of our company or third parties. Examples of uses for advertising purposes are cookies that measure the effectiveness of ads, and cookies that show whether a particular ad has been clicked or how many times the ad has been viewed.
Rejecting and Deleting Cookies Although most browsers allow the use of cookies, users can refuse or delete cookies at any time by changing their browser settings. You can remove persistent cookies and reject both session cookies and persistent cookies by following the instructions given in the "help" file of your internet browser or by visiting “www.allaboutcookies.org” or “www.youronlinechoices.eu”. However, the method of changing the settings varies according to the browser used, and how to disable cookies should be learned from the service provider for the browser used. If cookies are disabled. You can continue to use the website, mobile application, but you may not be able to access all the functions of the website, mobile application, or because your access may be limited, some features of our Company's website, application, platform and services may be unavailable. Authorized Service Providers We can get help from some service providers that we have authorized for the execution and promotion of our company's website, platform and applications and services. These service providers will also be able to place cookies and similar technologies (third party cookies) on users' computers/devices and collect information such as IP address, unique identifier and device identifier to identify the user's device. SITE, PRODUCTS AND SERVICES OF THIRD PARTIES Our company's website, platform and applications may contain links to third-party websites, products and services.The links in question are subject to the privacy policies of third parties, and we would like to inform you that the third parties and sites belonging to third parties are independent of our Company and our Company is not responsible for the privacy practices of third parties. CHANGES Our company can make changes in this Personal Data Protection and Privacy Policy at any time and the change becomes effective upon its publication on the website (www.toptanesarpvesal.com). Changes made by our company will be notified to the relevant parties on the website. For this reason, the current version of the Privacy Policy can be accessed from our Company's website, and any changes to the Privacy Policy can be followed from our Company's website. As a rule, the changes will be made by uploading them to our Company's website and will become effective as of this date. However, our Company may also notify the changes in other ways it deems appropriate. PERMISSION REGARDING COMMUNICATIONS AND PERSONAL DATA By accepting this Privacy/Personal Data Protection Policy and Communication Permission, your personal data, for which you have consented to be shared with our Company, are for the purposes stated in this Privacy Policy (providing and presenting various advantages and for personal promotion, promotion, advertisement, sales, marketing, survey and similar purposes). by making all kinds of electronic communication via telephone, short message (SMS), e-mail and similar means and sending other communication messages, etc.); You consent to the collection, storage, processing, use and transfer to third parties with whom our Company has a contractual relationship and whose details are stated above.