KVKK Clarification Text

ABOUT THE PROCESSING OF PERSONAL DATA

CLARIFICATION TEXT

VLM 4 YAPI SİSTEMLERİ YATIRIM A.Ş., which owns the CONSERA GROUP brand and the website www.conseragroup.com, takes the highest possible security measures to ensure that your personal data is collected, stored and shared in accordance with the law and to protect your privacy.

Our aim is to inform you in the most transparent way about the ways your personal data are collected, the purposes of processing, the persons shared, the legal reasons and your rights in accordance with Article 10 of the Personal Data Protection Law No. 6698 and in line with your satisfaction.

1. a) Data Controller

Pursuant to Law No. 6698 on the Protection of Personal Data ("Law No. 6698"), your personal data is collected and processed by VLM 4 YAPI SİSTEMLERİ YATIRIM A.Ş. ("COMPANY") as the data controller within the scope described below.

Title : VLM 4 YAPI SİSTEMLERI YATIRIM A.Ş.

Mersis Number : 0925-0718-1480-0001

Address : Huzur Mah. Ayazaga Cad. 4B/601 Maslak -Sarıyer / Istanbul

Phone: +90 212 212 06 74

E-mail address : [email protected]

Registered Electronic Mail (REM) : [email protected]

1. b) Which Personal Data and Purposes of Processing
2. Your Processed Personal Data

• Our Visitors

In case you are a visitor/guest; (a) your personal data such as your identification number, name and surname information, camera recording images outside the privacy areas, your entry and exit information to the Company building; (b) if you have used the internet access service during your stay in our buildings and facilities (COMPANY headquarters and branches, CONSERA GROUP showrooms, head office), your phone number data and internet traffic information and IP information regarding your internet access;

• Our Online Visitors and Wifi Users

Transaction security information (IP address) of our online visitors using our website
your information), marketing information (shopping history information, cookie logs), and (if you provide us with
If you notify us) identification information, contact information (your e-mail address, your full address,
your phone number);

If you are a Wi-Fi service user, your (a) phone number data and (b) internet traffic information and IP information regarding your internet access;

• Our Customers

Authorized representatives of our natural person customers or legal entity customers and/or
employee credentials, contact information, customer transaction information (such as order information),
financial information (such as bank information), risk management, occupational information, billing, legal process information, user traffic information, location, marketing information (such as shopping history information);

• Potential Customers

Authorized representatives of our natural person customers or legal entity customers and/or
employees' identity information, contact information, occupational information, customer transaction information, marketing information;

• Business Partners / Solution Partners

Authorized representatives of our natural person solution partners or legal person solution partners and/or
employees' identity information, contact information, dealer transaction information (order information, etc.), financial
information (balance sheet information, etc.), legal transaction information, risk information, marketing information (shopping history
information);

• Supplier Authorized

Identity information, contact information, customer transaction information, financial information, marketing information, legal transaction information, risk information, location of our natural person suppliers or legal person supplier authorities;

• Supplier Employee

Identity details, contact details, professional experience details, location of the supplier employee (e.g. vocational training details);

• Employee Candidates

In case you are a candidate employee; (a) the information in your identity card, photograph, your personal data such as residence, military service status information, driver's license, educational documents and information, professional experience, e-mail address, career goals, information on previous employment, references, telephone number; (b) if you have used the internet access service during your stay in our buildings and facilities (COMPANY headquarters and branches, CONSERA GROUP showrooms, head office), telephone number data and internet traffic information and IP information regarding your internet access; (c) your entry and exit information to and from the Company building, your camera recording images outside the privacy areas;

• Our Employees

If you are an employee; (a) the information in your identity card, photograph, residence, marital status, military status information, driver's license, educational documents and information, e-mail address, telephone number, legal transaction, professional experience, financial experience, finance (bank information, etc.), location, risk management, vehicle / license plate), location, risk management, vehicle / license plate; your personal data of special nature related to health and criminal convictions and security measures in the presence of your explicit consent, except for the cases listed in the law; (b) if you have benefited from the internet access service during your stay in our buildings and facilities (COMPANY headquarters and branches, CONSERA GROUP showrooms, head office), telephone number data and internet traffic information and IP information regarding your internet access; (c) your entry and exit information to the Company building, camera recording images outside the privacy areas

is being processed.

In the processes related to our corporate customers, we also process signature circulars and title-position information.

1. Purposes of Processing Personal Data

Your personal data collected;

• Creation and follow-up of visitor records,
• Ensuring the legal, technical and commercial-business security of the relevant persons who have a business relationship with the Company, ensuring the physical security and supervision of the Company's locations;
• Providing your access to our website via the Internet, as well as the Law No. 5651 on the Regulation of Publications on the Internet and the Fight Against Crimes Committed through These Publications ("Law No. 5651") and the legislation regulated in accordance with this law, as well as the fulfillment of the mandatory provisions of other laws,
• Execution of activities in accordance with the legislation, information security processes
  execution, follow-up of requests/complaints,
• Providing the products and services of the COMPANY, fulfilling our obligations to you, carrying out after-sales support services for goods/services, carrying out the sales processes of goods/services, organizing records and documents, complying with information retention, reporting, information, tax and other obligations stipulated by local and international legal legislation,
• Follow-up and resolution of customer complaints,
• Establishing communication in order to provide you with the necessary information about IT requirements, system structure, the necessity of IT support services received, and these services and products,
• Conducting traffic measurement, statistical analysis, segmentation/profiling and CRM studies for sales and marketing activities,
• Receiving your orders, realizing your payment transactions, providing logistics cooperation with 3rd parties and ensuring product delivery,
• Managing our customer portfolio,
• Use in products and services to be offered within the scope of the relevant legislation,
• Execution of contract processes, fulfillment of the requirements of the contracts and fulfillment of the legal obligations to which the COMPANY is subject in relation to the utilization of these services,
• In line with the purpose of determining and implementing the commercial and business strategies of the COMPANY; managing the financial operations, communication, market research and social responsibility activities, purchasing operations (demand, proposal, evaluation, order, budgeting, contract), internal system and application management operations, legal operations carried out by the COMPANY,
• Conducting financial and accounting affairs, conducting/supervising business activities,
• Execution of investment processes,
• Follow-up and execution of legal affairs,
• Execution of supply chain management processes,
• Execution of risk management processes, strategic planning activities,
• Evaluating job application requests and suitability for the relevant position, conducting and finalizing recruitment processes within the framework of the COMPANY's human resources policies, and carrying out the necessary procedures if the person is accepted for the relevant position;
• Preparation of personnel files, ensuring that payroll transactions are carried out, making salary payments to employees, making official notifications, making payments regarding salary garnishment deductions, carrying out occupational health/safety activities, fulfilling court decisions, making justified/unjustified distinction of the customer in customer complaints, increasing customer satisfaction, understanding customer needs and improving customer-related processes, monitoring and reporting sales performances, Confirming that the employee to whom the vehicle is allocated or made to drive is competent to drive and has not lost his/her driver's license for any reason, creating the employee's work e-mail by entering employee data into Outlook, conducting research projects related to employees, ensuring communication for celebration purposes, planning training, reporting trainings, preparing training certificates, tracking employees who participated in the trainings, tracking the development processes of employees as a result of the trainings they received, communicating with the relevant people in case of emergencies
• Reviewing, evaluating and responding to requests from official authorities or you

in connection with, limited to and proportionate to its purposes

In the presence of your explicit consent,

• In accordance with the Regulation on Commercial Communication and Commercial Electronic Messages, your identity and communication data for the realization of promotions, bulletins, collection promotions, events, advantages, discounts, information communications regarding campaigns and commercial electronic messages within the scope of sales and marketing activities to be carried out to increase service and product quality,

• Your identity, communication, customer transaction, transaction security, marketing data in order to carry out the marketing processes of our Company's products and services by contacting you, to recommend and promote the products and services offered by our Company, including profiling and analysis activities, by customizing them according to your tastes, usage habits and needs, to measure and increase customer satisfaction, to receive your opinions and suggestions regarding new services and products,

• Your identity, communication, customer transaction and marketing data may be processed for the purpose of conducting research, survey and review studies for customer satisfaction and sending promotions and gifts.

Your explicit consent is also asked to you independently of this clarification text and even if you give your consent, you have the right to withdraw this consent at any time. Even if you do not give explicit consent, you can continue to benefit from all our sales and after-sales services that do not have a legal basis of explicit consent.

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Your personal data are processed in accordance with the general principles set out in Article 4 of the Law, in accordance with the law and good faith, accurate and, where necessary, up-to-date, for specific, explicit and legitimate purposes, in connection with the purpose for which they are processed, limited and measured, and retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

1. c) To whom and for what purpose the processed personal data can be transferred

Your personal data collected; limited to the realization of the processing purposes specified in section b) above and to be valid for all of them;

Within the framework of the provisions on the transfer of personal data specified in Article 8 of the KVKK No. 6698; to the business partners, shareholders, affiliates of the COMPANY in the country; in cases where the obligations arising from the law are fulfilled and in case of a legal dispute, to legally authorized public institutions and organizations and judicial and administrative authorities; natural or legal persons, manufacturers, suppliers, business/solution partners, program partner institutions and organizations, institutions and service providers that we have contracted to send the messages we send to our customers; cargo companies that deliver the orders placed or our gifts, promotions, catalogs to you.

9. of the KVKK numbered 6698. Within the framework of the provisions on the transfer of personal data specified in Article 9 of KVKK No. 6698, in order to ensure legal and commercial security, to service providers whose servers are located abroad, business partners, shareholders, affiliates of the COMPANY located abroad; natural or legal persons, manufacturers, suppliers, business/solution partners abroad, from whom we receive services and cooperate in the execution of business activities, product/service comparison, analysis, evaluation, advertisement and realization of our aforementioned purposes; program partner institutions and organizations abroad, institutions that we have contracted to send the messages we send to our customers.

ç) Method and Legal Grounds for Collecting Personal Data

Your Personal Data may be processed both wholly or partly by automated means and by means that are part of a data recording system but not automated;

Through communication and information access channels such as applications made directly by you or persons authorized to act on your behalf, through the website or contracted websites or physically, business cards shared, visits made, our customer service call center line, e-mail addresses, social media channels and WhatsApp support service line, In addition, as a result of membership agreements, sales agreements and other agreements, campaigns, applications, written and electronic media through interviews and forms communicated through our Dealers, information request forms you have filled out at fairs and your requests for information in verbal, written or electronic media;

As set out in Articles 5 and 6 of the Law;

• It is clearly stipulated in the law,
• It is mandatory for our company to fulfill the legal obligation,
• It is directly related to the conclusion or performance of the contract and processing is necessary,
• Processing is mandatory for the legitimate interest of our Company, provided that it does not harm your fundamental rights and freedoms,
• The fact that it has been made public by you,
• Processing is necessary for the establishment, exercise or protection of a right,
• Explicit consent

on the basis of legal grounds such as.

11. d) Rights of the Personal Data Owner listed in Article 11 of Law No. 6698

As personal data owners, if you submit your requests regarding your rights by the methods set out below, the COMPANY will finalize the request as soon as possible and within thirty days at the latest, depending on the nature of the request. No fee will be charged for up to ten pages in the response. A transaction fee of 1 Turkish Lira will be charged for each page over ten pages. If the response to the application is given in a recording medium such as CD, flash memory, the fee that may be requested by our company will not exceed the cost of the recording medium.

In this context, personal data owners;

• Learn whether personal data is being processed,
• Request information if their personal data has been processed,
• To learn the purpose of processing personal data and whether they are used for their intended purpose,
• To know the third parties to whom personal data are transferred domestically or abroad,
• To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
• Although it has been processed in accordance with the provisions of Law No. 6698 and other relevant laws, to request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
• To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
• In case of damage due to unlawful processing of personal data, it has the right to demand compensation for the damage.

In accordance with paragraph 1 of Article 13 of the Law No. 6698 and the Communiqué on the Procedures and Principles of Application to the Data Controller No. 30356 and dated 10.03.2018, you can submit your request to exercise your rights mentioned above in Turkish and in writing or by using the registered electronic mail (KEP) address, secure electronic signature, mobile signature or the e-mail address previously notified to the COMPANY and registered in our system. In the applications, only information about the applicant will be provided and it will not be possible to obtain information about other family members and third parties. The COMPANY reserves the right to verify your identity before responding.

In your application;

1. a) Your name, surname and signature if the application is in writing,
2. b) For citizens of the Republic of Turkey, your Turkish ID number; if you are a foreigner, your nationality, passport number or ID number, if any,
3. c) Your residential or workplace address for notification,

ç) Your e-mail address, telephone and fax number, if any,

1. d) The subject of your request,

and information and documents on the subject, if any, must also be attached to the application.

You can submit your written applications by attaching the necessary documents to the address of our Company as the data controller "Huzur Mah. Ayazağa Cad. 4B/601 Maslak -Sarıyer / Istanbul" address. You can download the application form from the "Data Subject Application Form" link at the bottom of this page.

You can find our e-mail addresses to which you can send your applications via e-mail in the "Data Subject Application E-mail Addresses" section at the bottom of this page.

Depending on the nature of your request, information and documents that will enable identification must be provided to us completely and accurately. If the requested information and documents are not provided as required, there may be problems in the full and qualified execution of the investigations to be carried out by the COMPANY based on your request. In this case, the COMPANY declares that it reserves its legal rights. For this reason, your application must be sent completely and in a manner to include the requested information and documents according to the nature of your request.

Data Subject Contact Methods:

Written Application:

"Huzur Mah. Ayazaga Cad. 4B/601 Maslak -Sarıyer / Istanbul" address.

Email Application:

[email protected] e-mail or [email protected] KEP address mail.