As Uğurlu Finisaj Sistemleri (“UFS”); within the scope of the activities arising from the Personal Data Protection Law No. 6698 (“KVKK”), the European Union General Data Protection Regulation (“GDPR”), and the relevant legislation and legal regulations, we have prepared this disclosure statement to inform our visitors, online visitors, customers, potential customers, supplier employees, supplier officials, and job candidates in the recruitment and placement process regarding the processing, storage, and transfer of your personal data.
1) What Are the Categories of Your Personal Data We Process and For What Purposes Do We Process Them?
Your personal data may be processed by Uğurlu Finisaj Sistemleri in accordance with the principles stipulated in Article 4.2 of the KVKK; namely, being in compliance with the law and good faith, being accurate and, when necessary, up to date, being processed for specific, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purposes for which they are processed. The personal data may be processed within the scope of our business relationships established and ongoing with our business partners for the purposes specified below (it is possible for a person to fall into more than one category).
- Our Visitors
The identity information of our visitors (e.g., name, surname, Turkish ID number, place, and date of birth) will be processed for the purpose of creating and tracking visitor records.
- Our Online Visitors
The transaction security information (e.g., IP address information) of our online visitors using our website, marketing information (e.g., shopping history information, cookie records), and, if you provide them to us, identity information, contact information (your email address, physical address, phone number); will be processed for the purposes of ensuring compliance with the legislation, conducting information security processes, tracking requests/complaints, conducting communication activities, providing information to authorized persons, institutions, and organizations, and enabling your access to our website through the internet.
- Our Customers
The identity information, contact information, customer transaction information (e.g., order information), financial information (e.g., balance sheet information), legal transaction information, marketing information (e.g., shopping history information) of our real person customers or the representatives and/or employees of our legal entity customers; will be processed for the purposes of ensuring compliance with the legislation, conducting finance and accounting works, conducting/inspecting business activities, conducting logistics activities, conducting after-sales support services, conducting product/service sales processes, conducting marketing analysis studies, conducting contract processes, providing information to authorized persons, institutions, and organizations, resolving legal disputes, conducting storage and archiving activities, conducting risk management processes, conducting advertisement/campaign/promotion processes, sending commercial electronic messages, conducting processes related to loyalty to the company/products/services, and conducting communication activities.
- Our Potential Customers
The identity information, contact information, customer transaction information, marketing information of our real person customers or the representatives and/or employees of our legal entity customers; will be processed for the purposes of managing product/service sales processes, conducting contract processes, conducting advertisement/campaign/promotion processes, sending commercial electronic messages, and conducting marketing analysis studies.
- Our Solution Partners
The identity information, contact information, dealership transaction information (e.g., order information), financial information (e.g., balance sheet information), legal transaction information, marketing information (e.g., shopping history information) of our real person solution partners or the representatives and/or employees of our legal entity solution partners; will be processed for the purposes of ensuring compliance with the legislation, conducting finance and accounting works, conducting/inspecting business activities, conducting logistics activities, conducting after-sales support services, conducting product/service sales processes, conducting marketing analysis studies, conducting contract processes, providing information to authorized persons, institutions, and organizations, resolving legal disputes, conducting storage and archiving activities, conducting risk management processes, conducting advertisement/campaign/promotion processes, sending commercial electronic messages, conducting end-consumer service processes, and conducting communication activities.
- Our Supplier Employees
The identity information, contact information, professional experience information (e.g., in-service training information) of our supplier employees; will be processed for the purposes of conducting communication activities, conducting/inspecting business activities, conducting supply chain management processes, conducting logistics activities, ensuring compliance with the legislation, and conducting occupational health and safety activities.
- Our Supplier Representatives
The identity information, contact information, customer transaction information, financial information, marketing information, legal transaction information of our real person suppliers or the representatives of our legal entity suppliers; will be processed for the purposes of conducting/inspecting business activities, conducting product/service procurement processes, conducting finance and accounting works, conducting contract processes, conducting investment processes, and following and conducting legal affairs.
- Our Job Candidates in the Recruitment and Placement Process
You can access the details regarding the processing of the personal data of our job candidates in the recruitment and placement process here.
Elbette, işte "Kişisel Verilere İlişkin Aydınlatma Metni"nin devamının İngilizce çevirisi:
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**2) What Are the Methods of Collecting Your Personal Data?**
The personal data specified in the categories above are collected through physical means such as order forms, contracts, visitor forms, or through information systems and electronic devices (e.g., telecommunication infrastructure, computers, and phones), third parties, our website, and other documents declared by the relevant person, either automatically or non-automatically.
**3) How Long Do We Retain Your Personal Data?**
Your personal data, specified in the categories above, are retained for the period stipulated in the relevant legislation if such a period is stipulated; if no such period is stipulated, they are retained for as long as our legitimate interest continues, taking into account the following criteria:
- UFS practices
- Commercial customs applied
- Statute of limitations stipulated in the relevant legislation
At the end of these periods, the retained personal data are deleted, destroyed, or anonymized.
**4) What Is the Legal Basis for Collecting Your Personal Data?**
Your personal data are processed by Uğurlu Finisaj Sistemleri for the realization of the purposes explained above based on the legal reasons specified in Article 5 of the KVKK:
- Explicitly stipulated by law,
- Necessity for the processing of personal data of the parties to a contract, provided that it is directly related to the establishment or performance of the contract,
- Necessity for the data controller to fulfill its legal obligation,
- Necessity for data processing for the establishment, exercise, or protection of a right,
- Necessity for data processing for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person.
The identity and contact data of our Solution Partners, Customers, and Potential Customers will be processed based on their explicit consent for advertising, campaigns, promotions, and sending commercial electronic messages. You always have the right to request the cessation of communication regarding advertising, campaigns, promotions, and sending commercial electronic messages, and to withdraw your explicit consent. If you no longer wish to be contacted for advertising, campaigns, promotions, and sending commercial electronic messages, you can use your cancellation right through the contact information you have shared with us.
**5) Do We Transfer Your Personal Data to Third Parties?**
- The personal data of our visitors may be shared with law enforcement and judicial authorities for the purpose of resolving legal disputes and if requested by relevant legislation.
- The personal data of our online visitors may be shared with judicial authorities and authorized public institutions and organizations for the purpose of resolving legal disputes and if requested by relevant legislation.
- The personal data of our customers may be transferred to authorized public institutions and organizations within the scope of legal regulations, for the follow-up and execution of legal affairs, ensuring compliance with legislation, and providing information to authorized persons, institutions, and organizations; to our group companies, solution partners, cargo companies, suppliers, banks, and financial advisors to the extent necessary for the execution/inspection of business activities, execution of risk management processes, and proper fulfillment of our services. Additionally, these personal data may be transferred to the law firm we receive services from and judicial authorities for the purpose of being used as evidence in future legal disputes.
- The personal data of our potential customers may be transferred to our solution partners to the extent necessary for the proper fulfillment of our services and to the law firm we receive services from and judicial authorities for the purpose of being used as evidence in future legal disputes.
- The personal data of our solution partners may be transferred to authorized public institutions and organizations within the scope of legal regulations, for ensuring compliance with legislation, providing information to authorized persons, institutions, and organizations; to our solution partners, cargo companies, suppliers, banks to the extent necessary for the execution/inspection of business activities, execution of risk management processes, follow-up, and execution of legal affairs, and proper fulfillment of our services. Additionally, these personal data may be transferred to the law firm we receive services from and judicial authorities for the purpose of being used as evidence in future legal disputes.
- The personal data of our supplier employees may be transferred to authorized public institutions and organizations within the scope of legal regulations, for ensuring compliance with legislation, providing information to authorized persons, institutions, and organizations, follow-up, and execution of legal affairs, execution/inspection of business activities; to our group companies, cargo companies, suppliers, financial advisory office, and banks to the extent necessary for the proper fulfillment of the service. Additionally, these personal data may be transferred to the law firm we receive services from and judicial authorities for the purpose of being used as evidence in future legal disputes.
- The personal data of our supplier representatives may be transferred to authorized public institutions and organizations within the scope of legal regulations, for ensuring compliance with legislation, follow-up, and execution of legal affairs, providing information to authorized persons, institutions, and organizations, execution/inspection of business activities; to our group companies, suppliers, cargo companies, banks, and financial advisors to the extent necessary for the proper fulfillment of the service. Additionally, these personal data may be transferred to the law firm we receive services from and judicial authorities for the purpose of being used as evidence in future legal disputes.
**6) Do We Transfer Your Personal Data Abroad?**
Your personal data may be shared with third parties abroad, our business partners/suppliers, based on the rules within the framework of Article 9 of the KVKK.
**7) How Can You Exercise Your Rights Regarding Your Personal Data?**
**Right to Rectification:** If you believe that any of your personal data is incorrect, you have the right to request its correction from our company. You also have the right to request the completion of any incomplete personal data you think is missing.
**Right of Access:** You have the right to request a copy of your personal data from our company. A fee may be charged for this activity.
**Right to Withdraw Consent:** You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.
**Right to Erasure:** In certain situations, you have the right to request the deletion of your personal data from our company.
**Right to Data Portability:** In certain situations, you have the right to request the transfer of your personal data obtained by our company to another organization or directly to you.
**Right to Restrict Processing:** In certain situations, you have the right to request the restriction of the processing of your personal data by our company.
**Right to Object to Processing:** In certain situations, you have the right to object to the processing of your personal data by our company.
**Right to Lodge a Complaint with a Supervisory Authority:** If you believe that we are processing your personal data in violation of applicable data protection guidelines, you have the right to lodge a complaint with a competent supervisory authority, primarily in the Member State of your habitual residence or place of work or the place where the alleged infringement occurred if you reside in the European Union.
You can submit your requests regarding the rights mentioned above and your requests within the scope of Article 11 of the KVKK, which regulates the rights of the relevant persons, to us through the “Data Controller Application Form” prepared to facilitate your convenience available at “http://www.ugurlu.com.tr”.
**Data Controller:** Uğurlu Finisaj Sistemleri
**Address:** Bursa Deri İhtisas ve Karma Organize Sanayi Bölgesi Badırga Mah. 8. Sk. No:2 16290 Nilüfer Bursa/Turkey
**Email:** ugurlu@ugurlu.com.tr