PRİVACY NOTİCE REGARDİNG THE PROCESSİNG OF PERSONAL DATA
Located at Esentepe Neighborhood, Kelebek Street, Marmara Tower, Block A, No: 2, Apartment No: 120, Kartal / Istanbul address, with a registered email address [email protected], and with a MERSIS number 0757-1038-1460-0001, Scotty Kurye Dağıtım ve Teknolojileri A.Ş. ("SCOTTY" or "the Company")
We, as SCOTTY, have prepared this Personal Data Processing Information Text ("Information Text") to inform the relevant individuals as data subjects about the processing, storage, and transfer of their personal data within the framework of our activities arising from the legislation and legal regulations related to the Personal Data Protection Law No. 6698 ("KVKK").
In addition, detailed information about cookies and SDKs used when you visit our website, mobile website, and/or mobile application can be found in our Cookie Policy. The personal data processed through these are explained in this Information Text.
This Information Text will be effective as of the date of publication by SCOTTY. SCOTTY reserves the right to make changes to this Information Text whenever necessary. Any changes will take effect immediately upon publication of the updated Information Text on the address www.scotty.com.tr/clarification-text.
Data Categories
1- Identity Information
Processed Personal Data:
Name – Surname, Date of Birth, Gender, Turkish
Identification Number
Purposes of Processing Personal Data:
Execution of Financial and Accounting Affairs, Execution of Communication Activities; Execution of Processes Related to Company / Product / Service Loyalty; Execution of Activities in Compliance with Legislation; Pursuit and Execution of Legal Affairs; Execution of Business Continuity Activities; Execution and Audit of Business Activities; Execution of Product / Service Sales Processes; Execution of After-Sales Support Services for Products / Services; Execution of Customer Relationship Management Processes; Execution of Activities for Customer Satisfaction; Execution of Advertising, Campaign, and Promotion Processes; Execution of Storage and Archiving Activities; Execution of Contract and Membership Processes; Tracking Requests / Complaints; Planning and Execution of Commercial and/or Business Strategies; Execution of Studies Required to Benefit from the Offered Products and Services and Execution of Relevant Business Processes; Providing Information to Authorized Persons, Institutions, and Organizations
Legal Bases for Processing Personal Data
Your personal data in this scope is processed by SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the KVKK;
For cases that are not covered by the purposes mentioned above, your personal data is processed based on your explicit consent as specified in the Consent Text.
Methods of Collecting Personal Data:
The above-mentioned personal data is collected through membership forms on our website, email communication, fields that can be optionally filled in the content of the website, requests and applications, contracts, campaigns, and third-party identity verification systems (e.g., Google Login, Facebook Login, etc.).
2- Contact Information
Processed Personal Data:
Email Address, Invoice & Delivery Addresses,
Mobile Phone Number
Purposes of Processing Personal Data:
Execution of Financial and
Accounting Affairs; Execution of
Communication Activities; Execution of Business Activities; Execution of Processes Related
to Company / Product /
Service Loyalty; Pursuit and Execution of Legal Affairs; Execution of Product / Service
Sales Processes; Execution
of After-Sales Support Services for Products / Services; Execution of Customer Relationship
Management Processes;
Execution of Activities for Customer Satisfaction; Execution of Marketing Analysis Studies;
Execution of
Advertising, Campaign, and Promotion Processes; Tracking Requests / Complaints; Execution of
Product / Service
Marketing Processes; Execution of Storage and Archiving Processes; Providing Information to
Authorized Persons,
Institutions, and Organizations
Legal Bases for Processing Personal Data
Your personal data in this scope
is processed by SCOTTY
based on the legal grounds specified in the relevant legislation and Article 5 of the KVKK;
For cases that are not covered by the purposes mentioned above, your personal data is processed based on your explicit consent as specified in the Consent Text.
Methods of Collecting Personal Data:
The above-mentioned personal data is collected through membership pages on our website, contracts, account pages, and other areas within the content of our website that can be optionally filled, requests and applications, contracts, campaigns, and third-party identity verification systems (e.g., Google Login, Facebook Login, etc.).
3- Legal Process Information
Processed Personal Data:
Information in Lawsuit Files in Case of
Disputes, Warning Letters, Information in Correspondence with Judicial and Administrative
Authorities
Purposes of Processing Personal Data:
Pursuit and Execution of Legal Affairs; Execution and Oversight of Business Activities; Providing Information to Authorized Persons, Institutions, and Organizations; Execution of Activities in Compliance with Legislation; Execution of Storage and Archiving Activities; Execution of Risk Management Processes; Execution of Contract Processes; Tracking Requests / Complaints; Ensuring the Security of Data Controller Operations
Legal Bases for Processing Personal Data
Your personal data within this scope is processed by SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the KVKK;
based on the legal reasons.
Methods of Collecting Personal Data:
The above-mentioned personal data is collected through official letters from judicial and administrative authorities and other printed / electronic documents.
4- Customer Transaction Information
Processed Personal Data:
Invoice Information, Request Information, Order
Information, Product Information, Shipping Information, Authorized Service Information
Purposes of Processing Personal Data:
Execution of Supply Chain Management Processes; Execution and Oversight of Business Activities; Providing Information to Authorized Persons, Institutions, and Organizations; Execution of Activities in Compliance with Legislation; Execution of Financial and Accounting Affairs; Execution of Storage and Archiving Activities; Execution of Contract Processes; Execution of Product / Service Sales Processes; Execution of After-Sales Support Services for Products / Services; Execution of Customer Relationship Management Processes; Execution of Activities for Customer Satisfaction; Execution of Marketing Analysis Studies; Execution of Advertising, Campaign, and Promotion Processes; Tracking Requests / Complaints, Execution of Product / Service Marketing Processes
Legal Bases for Processing Personal Data
Your personal data within this scope is processed by SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the KVKK;
based on the legal reasons. For cases not covered by the purposes mentioned above, your personal data is processed based on your explicit consent as specified in the Consent Text.
Methods of Collecting Personal Data:
The above-mentioned personal data is
collected through
printed/electronic forms, call center records, emails, customer management, and financial
programs.
5- Processing Security Information
Processed Personal Data:
IP Address Information, Website Entry / Exit
Information, User Name
Information, Password Information, Traffic Data (Connection Time / Duration, etc.)
Purposes of Processing Personal Data:
Execution of Information Security Processes; Execution of Audit / Ethical Activities; Execution and Oversight of Business Activities; Execution of Storage and Archiving Activities; Ensuring the Security of Data Controller Operations; Providing Information to Authorized Persons, Institutions, and Organizations; Execution of Activities in Compliance with Legislation; Pursuit and Execution of Legal Affairs; Execution of Product / Service Sales Processes; Tracking Requests / Complaints
Legal Bases for Processing Personal Data
Your personal data within this scope is processed by SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the KVKK;
based on the legal reasons. For cases not covered by the purposes mentioned above, your personal data is processed based on your explicit consent as specified in the Consent Text.
Methods of Collecting Personal Data:
The above-mentioned personal data is
collected through
information security systems and electronic devices.
6- Financial Information
Processed Personal Data:
Encrypted Credit Card Information, Bank Account
/ IBAN Number
Information
Purposes of Processing Personal Data:
Execution of Activities in Compliance with Legislation; Pursuit and Execution of Legal Affairs; Execution of Financial and Accounting Affairs; Execution of Return Processes; Execution and Oversight of Business Activities; Execution of Product / Service Sales Processes; Execution of Storage and Archiving Activities; Execution of Risk Management Processes; Execution of Contract Processes; Providing Information to Authorized Persons, Institutions, and Organizations
Legal Bases for Processing Personal Data
Your personal data within this scope is processed by SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the KVKK;
Methods of Collecting Personal Data:
The above-mentioned personal data is
collected through
printed and electronic forms, emails, and requests and messages within the website.
7- Visual and Auditory Recording Information
Processed Personal Data:
Call Center Voice Recordings
Purposes of Processing Personal Data:
Execution of Loyalty Processes
Related to Company Products
and Services; Execution of Customer Relationship Management Processes; Execution of
Activities for Customer
Satisfaction; Execution of After-Sales Support Services for Products / Services; Execution
of Storage and Archiving
Activities; Tracking Requests / Complaints; Execution of Product / Service Marketing
Processes; Execution of
Customer Relationship Management Processes; Execution of Marketing Analysis Studies;
Providing Information to
Authorized Persons, Institutions, and Organizations
Legal Bases for Processing Personal Data
Your personal data within this scope is processed by SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the KVKK;
Processed based on legal grounds.
Methods of Collecting Personal Data:
The above-mentioned personal data is
collected
electronically during calls made to our call center.
8- Location Information
Processed Personal Data:
Location Information
Purposes of Processing Personal Data:
Execution of Customer Relationship
Management Processes;
Execution of Marketing Analysis Studies; Execution of Advertising / Campaign / Promotion
Processes; Execution of
Activities for Customer Satisfaction; Execution of Product / Service Marketing Processes;
Execution of Product /
Service Sales Processes; Execution of Product / Service Production and Operation Processes
Legal Bases for Processing Personal Data
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK, as detailed in
the Consent Text that you can access;
Processed based on legal grounds.
Methods of Collecting Personal Data:
The above-mentioned personal data is
collected based on your
preference in the internet browser you use and in our Company's mobile application.
Transfer of Personal Data
Personal data belonging to customers can be transferred to our affiliates and subsidiaries, in compliance with the rules stated in Article 8 titled "Transfer of Personal Data" and/or Article 9 titled "Transfer of Personal Data Abroad" of the KVKK, by taking necessary technical and administrative measures, only to the extent necessary for the realization of the relevant purpose;
1- Information Security Data
Processed Personal Data:
IP Address Information, Internet Site Entry and
Exit Information,
Password and Passcode Information, Computer Screen Records, Device IMEI Number, Device MAC
Address
Purposes of Processing Personal Data:
Execution of Information Security
Processes; Execution of
Activities in Compliance with Legislation; Management of Customer Relationship Management
Processes; Tracking
Requests and Complaints; Providing Information to Authorized Individuals, Institutions, and
Organizations
Legal Bases for Processing Personal Data
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK;
Processed based on legal grounds.
Methods of Collecting Personal Data:
The above-mentioned personal data is
collected through
internet applications, information systems, and electronic devices (telecommunication
infrastructure, computers, and
phones, etc.) and other documents declared by you.
Transfer of Personal Data
Personal data belonging to online users can be transferred to authorized individuals and official institutions in accordance with legal regulations and legislation to fulfill our legal obligations, and can be recorded to the programs and/or systems provided by our technology infrastructure providers, by taking necessary technical and administrative measures, only to the extent necessary for the realization of the relevant purpose;
Data Categories
1- Identity Information
Processed Personal Data:
First Name - Last Name, Republic of Turkey
Identification Number, Copy
of Identification
Purposes of Processing Personal Data:
Execution of Communication
Activities; Execution and
Supervision of Business Activities; Planning and Execution of Commercial and/or Business
Strategies; Tracking
Requests and Complaints; Providing Information to Authorized Individuals, Institutions, and
Organizations; Execution
of Activities in Compliance with Legislation; Execution of Contract Processes
Legal Bases for Processing Personal Data
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK;
Processed based on legal grounds.
Methods of Collecting Personal Data:
The above-mentioned personal data is
collected through
business cards, contracts, face-to-face meetings, electronic forms, and calls made to our
call center.
2- Contact Information
Processed Personal Data:
Email Address, Mobile Phone Number, Address
Purposes of Processing Personal Data:
Execution of Communication
Activities; Execution and
Supervision of Business Activities; Planning and Execution of Commercial and/or Business
Strategies; Tracking
Requests and Complaints; Providing Information to Authorized Individuals, Institutions, and
Organizations; Execution
of Activities in Compliance with Legislation; Execution of Contract Processes
Legal Bases for Processing Personal Data
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK;
Processed based on legal grounds.
Methods of Collecting Personal Data:
The above-mentioned personal data is
collected through
business cards, contracts, and face-to-face meetings.
3- Transaction Information
Processed Personal Data:
Request Information
Purposes of Processing Personal Data:
Execution and Supervision of
Business Activities; Providing
Information to Authorized Individuals, Institutions, and Organizations; Execution of
Activities in Compliance with
Legislation; Execution of Financial and Accounting Operations; Conducting Storage and
Archive Activities; Execution
of Contract Processes
Legal Bases for Processing Personal Data
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK;
Processed based on legal grounds.
Methods of Collecting Personal Data: The above-mentioned personal data is collected through printed/electronic forms, call center records, emails, and financial and customer management programs.
4- Financial Information
Processed Personal Data:
Bank Account / IBAN Number Information, Invoice
Information, Request
Information
Purposes of Processing Personal Data:
Execution of Financial and
Accounting Operations; Execution
and Supervision of Business Activities; Execution of Activities in Compliance with
Legislation; Providing
Information to Authorized Individuals, Institutions, and Organizations
Legal Bases for Processing Personal Data
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK;
Processed based on legal grounds.
Methods of Collecting Personal Data: The above-mentioned personal data is collected through electronic and printed forms.
5- Legal Transaction Information
Processed Personal Data:
Information in Lawsuit Files in Case of
Disputes, Notices, Information
in Correspondence with Judicial and Administrative Authorities
Purposes of Processing Personal Data:
Pursuit and Execution of Legal
Affairs; Execution and
Supervision of Business Activities; Providing Information to Authorized Individuals,
Institutions, and
Organizations; Execution of Activities in Compliance with Legislation; Conducting Storage
and Archive Activities;
Execution of Risk Management Processes; Execution of Contract Processes; Tracking Requests
and Complaints
Legal Bases for Processing Personal Data
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK;
Processed based on legal grounds.
Methods of Collecting Personal Data:
The above-mentioned personal data is
collected through
official letters from judicial and administrative authorities, and other printed /
electronic documents.
6- Risk Management Information
Processed Personal Data:
Information Processed for Managing Commercial
Risks
Purposes of Processing Personal Data:
Execution and Supervision of
Business Activities;
Conducting Storage and Archive Activities; Execution of Risk Management Processes; Execution
of Contract Processes;
Tracking Requests and Complaints; Conducting Internal Audit Activities; Conducting
Intelligence Activities
Legal Bases for Processing Personal Data
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK;
Processed based on legal grounds.
Methods of Collecting Personal Data:
The above-mentioned personal data is
collected through
participation in a meeting or event, during the sales process, through contracts, and
through documents provided by
the relevant individual.
7- Visual and Audio Recording Information
Processed Personal Data:
Call Center Voice Recordings
Purposes of Processing Personal Data:
Execution of Information Security
Processes; Providing
Information to Authorized Individuals, Institutions, and Organizations; Execution of
Activities in Compliance with
Legislation; Conducting Audit / Ethical Activities; Execution of Product / Service Sales
Processes; Execution of
Advertising / Campaign / Promotion Processes; Conducting Storage and Archive Activities;
Tracking Requests and
Complaints; Execution of Product / Service Marketing Processes
Legal Bases for Processing Personal Data
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK;
Processed based on legal grounds.
Methods of Collecting Personal Data:
The above-mentioned personal data is
collected
electronically during calls made to our call center.
Transfer of Personal Data
Personal data of business partner officials and employees are transferred to authorized individuals and official institutions in compliance with the rules of Article 8 titled "Transfer of Personal Data" or Article 9 titled "Transfer of Personal Data Abroad" of the KVKK, and with the necessary technical and administrative measures, only to the extent necessary for the realization of the relevant purpose;
Data Categories
1- Identity Information
Processed Personal Data:
Name, Surname, Turkish Identification Number
(T.C. Kimlik No), Tax
Identification Number (Vergi Kimlik No)
Purposes of Processing Personal Data:
Execution of Product/Service Sales
Processes, Execution of
Contract Processes, Execution of Communication Activities, Providing Information to
Authorized Individuals,
Institutions, and Organizations
Legal Bases for Processing Personal Data
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK;
Methods of Collecting Personal Data:
Your above-mentioned personal data
is collected through
electronic forms.
2- Contact Information
Processed Personal Data:
Mobile Phone Number, Email Address
Purposes of Processing Personal Data:
Execution of Product/Service Sales
Processes, Execution of
Contract Processes, Execution of Communication Activities, Providing Information to
Authorized Individuals,
Institutions, and Organizations
Legal Bases for Processing Personal Data
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK;
Methods of Collecting Personal Data:
Your above-mentioned personal data
is collected through
electronic forms.
3- Customer Transaction Information
Processed Personal Data:
Trade name, product category to be transported
Purposes of Processing Personal Data:
Execution of Product/Service Sales
Processes, Execution of
Contract Processes, Providing Information to Authorized Individuals, Institutions, and
Organizations
Legal Bases for Processing Personal Data:
Your personal data within this
scope is processed by
SCOTTY based on the legal grounds specified in the relevant legislation and Article 5 of the
KVKK;
Methods of Collecting Personal Data:
Your above-mentioned personal data
is collected through
electronic forms.
Transfer of Personal Data
Personal data of Potential Business
Partner/Authorized Person is
transferred to our Technology Partners in compliance with the rules of Article 8 titled
"Transfer of Personal Data"
or Article 9 titled "Transfer of Personal Data Abroad" of the KVKK, and with the necessary
technical and
administrative measures, only to the extent necessary for the realization of the relevant
purpose;
STORAGE AND DESTRUCTION POLICY FOR PERSONAL DATA:
Our company has created a Storage and Destruction Policy for storing and deleting personal data. Storage and destruction processes related to your personal data are carried out under this policy. Accordingly, if a period is determined in the KVKK or relevant laws and other relevant legislation for the storage of the data, the said data must be stored for at least this period. At the end of the specified period, the data is deleted, destroyed, or anonymized.
If a period has not been specified for the storage of the data we process in the legislation, taking into account possible disputes arising from our relationship, your data will be deleted, destroyed, or anonymized without the need for any request from you, after the expiration of the 10-year statute of limitations for legal action from the termination of our legal relationship.
If all the processing conditions of personal data have ceased or if the storage period specified by us or determined within the scope of the legislation has expired, your data will be deleted, destroyed, or anonymized ex officio on the first periodic destruction date or at the latest within 6 months. If you request the deletion of your data for a valid reason, your data will be deleted within 30 days at the latest in accordance with the law. If you request the deletion or destruction of your data before the specified storage period determined in the legislation, your request cannot be fulfilled.
RIGHTS OF THE PERSONAL DATA SUBJECT:
Within the scope of the KVKK and relevant legislation, regarding your personal data;
WAYS TO APPLY FOR PERSONAL DATA:
You can apply for your personal data and requests using the Application Form of the Relevant Person if you wish;
According to the Communique on Application Methods and Principles to the Data Controller, it is mandatory for the relevant individuals to include the following information in their applications: name-surname, signature if the application is in writing, Turkish identification number (if the person applying is a foreigner, passport number), the residential or workplace address for notifications, if any, the electronic mail address for notifications, telephone number, and fax number, and information about the request.
The data subject, the relevant person, must clearly indicate the requested matter in the application, which should include the explanations related to the right they want to exercise and the requested information and documents related to the application must be attached.
Although the subject of the request must be related to the applicant's person, if the request is made on behalf of someone else, the applicant must have special authorization in this regard and this authorization must be documented (special power of attorney). In addition, the application must contain the applicant's identity and address information and identity verification documents must be attached to the application.
Requests made by unauthorized third parties on behalf of others will not be evaluated.
Your requests regarding your personal data will be evaluated, and a response will be provided within 30 days at the latest from the date it reaches our Company. In case your application is negatively evaluated, the reasoned reasons for rejection will be communicated to you through electronic mail or by mail to the address you specified in the application, if possible, using the method used for the request.
Commercial Electronic Message Disclosure Statement
The Commercial Electronic Message Disclosure Statement has been prepared by Scotty Kurye Dağıtım ve Teknolojileri A.Ş., acting as the Data Controller, for the purpose of informing our customers within the scope of the Personal Data Protection Law about the commercial electronic messages to be sent by Scotty for the promotion, advertising, promotion, sale, and marketing of various products/services and opportunities, conducting satisfaction surveys, tracking requests/complaints, and for the announcement of various products/services and opportunities, conducting satisfaction surveys for customer satisfaction, tracking requests/complaints, conducting promotions, advertisements, promotions, sales, and marketing purposes; Your personal data will be processed based on the legal reason of "explicit consent" provided that you give your permission for Scotty to send commercial electronic messages to you by e-mail, SMS, or telephone call in accordance with the Law No. 6563 on Regulation of Electronic Commerce. Under the same purposes and legal basis, your data can be transferred to Scotty's business partners, authorized individuals, institutions, organizations, and the Message Management System Anonymous Company.
