KVKK Information
INFORMATION AND CONSENT TEXT ON THE PROTECTION OF PERSONAL DATA
The necessary information regarding the protection of personal data shared with TROYARN (“TROYARN”) is provided below. TROYARN, in order to fulfill its obligation to inform users arising from Article 10 of the Law on the Protection of Personal Data No. 6698 (“LPPD”), presents the following explanations to the attention of our users and third parties using our mobile applications. TROYARN mobile reserves the right to update this Personal Data Protection Explanation text at any time within the framework of the changes that may be made in the current legislation.
1) What is the legal basis for TROYARN to collect personal data?
There are regulations in various laws regarding the use of our customers' personal data. First of all, the principles of protection of personal data are determined with the LPPD. In addition, Law No. 6563 on the Regulation of Electronic Commerce also includes provisions regarding the protection of personal data. In some cases, criminal sanctions are envisaged for the protection of personal data through the provisions of the Turkish Penal Code No. 5237.
On the other hand, data must be collected and used in order to fulfill our obligations arising from the Consumer Protection Law No. 6502 and the Distance Contracts Regulation.
2) What methods does TROYARN use to collect personal data?
The data shared with us by our customers who make transactions through the troyarn.com website, mobile applications or our customer services are processed by TROYARN with the consent of our customers and in accordance with the provisions of the legislation. The troyarn.com website, which belongs to TROYARN, is a website that uses a cookie system. The cookie system allows the device connected to the internet to be recognized when it is logged in again later, thanks to some data received from the browser of the device connected to the internet. In order to provide a higher quality service to its visitors and within the framework of its legal obligation, troyarn.com will collect, process, share with third parties and store your browsing information securely, provided that it is not used outside the purposes and scope specified in this Personal Data Protection Statement.
troyarn.com cookies can track and analyze your browsing movements on the site and data regarding your site usage history. It also stores information obtained through GIF files and/or third-party sources to create a summary of your choices/preferences. On the other hand, cookies can also be used to provide a source for improvement studies so that you can experience the website and mobile application better. troyarn.com may match the data collected from you on the site and use this information together with information received from other sources such as third parties.
In addition to persistent cookies, session cookies are also used on the troyarn.com website. While the session ID cookie expires when the browser is closed, the persistent cookie remains on your hard drive for a long time. You can remove persistent cookies. To do this, you can visit the following sites: “www.allaboutcookies.org” or www.youronlinechoices.eu. Even if you reject session cookies and persistent cookies, you can continue to use both the website and the mobile application. However, you may not be able to use all the features of the website or mobile application effectively.
3) How Are Website Cookies Used?
troyarn.com uses cookies to remember the information you enter and to personalize your use of the mobile application/website; cookies thus save you from having to enter your password every time you enter the website or mobile application. At the same time, cookies are used to determine how you use the website/mobile application, including the location from which you connect to the website, the type of content you view on the website/mobile application, and the duration of your visit, and how you use the website/mobile application. Cookies on the website are used for advertising/promotion purposes to provide content and advertisements more suitable to your interests and likes. In this way, the website offers you more suitable content, personalized campaigns and products when you use the website, and does not offer you content or opportunities that you have previously stated you do not want.
4) How does the Website use third-party cookies for advertising and retargeting?
troyarn.com cookies can be used to activate “advertising technology” in order to show you advertisements that appeal to your interests when you visit websites where the website advertises.
Advertising technology uses the information you have shared on your previous visits to the mobile application/website and the mobile application/websites where the website advertises in order to offer you advertisements that are in line with your interests and preferences. A third-party cookie may be placed on your browser so that the website can recognize you in order for this system to function properly.
5) For what purposes does TROYARN use personal data?
TROYARN may record, store, update, disclose to third parties, transfer, classify and process your personal information in the cases and to the extent permitted by the legislation.
Your personal data is used for the following purposes:
* To confirm the identity of the person who performs/has performed the transaction via the website/customer services/mobile applications,
* To record the address and other necessary information for communication,
* To communicate with our customers regarding the conditions, current status and updates of the contracts we have concluded under the relevant articles of the Distance Sales Contract and the Law on Consumer Protection, and to provide the necessary information,
* To organize all records and documents that will form the basis of the transaction in electronic (internet/mobile etc.) or paper format,
* To fulfill the obligations undertaken under the contracts we have concluded under the relevant articles of the Distance Sales Contract and the Law on Consumer Protection,
* To provide information to public officials upon request and as required by law on matters related to public safety,
* To inform our customers about our products that may be of interest to our customers “taking into account the areas of interest that our customers have informed us”, to convey campaigns,
* To get to know our customers who shop from the website and/customer services/or mobile applications, and to be able to use it in customer environment analysis, to be able to use it in various marketing and advertising activities and to organize surveys in electronic and/or physical environments through contracted institutions in order to ensure customer satisfaction in this context,
* To be able to offer suggestions to our customers by our contracted institutions and solution partners, to inform our customers about our services,
* To be able to evaluate customer complaints and suggestions about our services,
* To be able to fulfill our legal obligations and to exercise our rights arising from the current legislation.
6) How does TROYARN protect your personal data?
Personal data shared with TROYARN is under the supervision and control of TROYARN. TROYARN has assumed the responsibility as the data controller to establish the necessary organization and to take and adapt technical measures in order to protect the confidentiality and integrity of information in accordance with the relevant legislation in force. Being aware of our obligation in this regard, penetration tests are carried out at periodic intervals in accordance with international and national technical standards regarding data confidentiality and we would like to inform you that we always update our data processing policies in this context.
7) Does TROYARN share your personal data?
The sharing of personal information belonging to our users with third parties is carried out with the consent of our users and, as a rule, personal data is not transferred to third parties without the consent of our users. On the other hand, personal data is shared with courts and other public institutions in accordance with and limited to our legal obligations. Necessary technical and legal measures are taken to prevent violations of rights during data transfer to third parties. However, TROYARN is not responsible for violations that occur due to the data protection policies of the third party receiving personal data and in the risk area under the responsibility of the third party. Your personal data may be shared with TROYARN shareholders, our direct/indirect domestic/international affiliates, program partner institutions and organizations that we cooperate with to carry out our activities, domestic/international persons and organizations from which we receive data storage services in the cloud environment, domestic/international organizations with which we have agreements regarding sending commercial electronic messages to our customers, the Interbank Card Center, banks with which we have agreements, and various domestic and international agencies, advertising companies and survey companies and domestic/international third parties and our relevant business partners within the scope of various marketing activities in order to provide you with better service and ensure customer satisfaction.
8) What are your rights arising from the Personal Data Protection Law?
According to the KVKK, your personal data;
* To learn whether or not it has been processed,
* To request information if it has been processed,
* To learn the purpose of processing and whether it is used in accordance with its purpose,
* To know the third parties to whom it was transferred domestically / abroad,
* To request correction if it has been processed incompletely / incorrectly,
* To request deletion / destruction within the framework of the conditions stipulated in Article 7 of the KVKK,
* To request notification of the transactions made pursuant to clauses (d) and (e) listed above to the third parties to whom it was transferred,
* To object to the emergence of a result against you due to analysis exclusively by automated systems,
* To request compensation for the damages in case you suffer damages due to processing in violation of the KVKK.
9) How can I be informed about the changes in the legislation regarding personal data?
The rights you have under the KVKK are the obligations of TROYARN. We would like to inform you that we process your personal data with this awareness and to the extent required by the legislation, that in case of any legal changes, we will update this information on our page in accordance with the new legislation, and that you can always easily follow the updates made on this page.
10) How can I be sure that the data is kept up-to-date and accurate?
In accordance with Article 4 of the KVKK, TROYARN is obliged to keep your personal data accurate and up-to-date. In this context, in order for TROYARN to fulfill its obligations arising from the current legislation, our customers must share their accurate and up-to-date data with TROYARN. In the event that your data changes in any way, we kindly request that you update your data by contacting us through the communication channels specified below.
11) Would you like to ask TROYARN questions about your personal data?
You can reach us at any time by e-mail at info@troyarn.com for all your questions and opinions regarding your personal data.
Personal Data to be Processed Based on the Explicit Consent of Customers and Processing Purposes:
In accordance with the relevant law on the protection of personal data; in the following cases where the personal data processing conditions stipulated in Articles 5/2 and 6/3 of the Law cannot be met, the explicit consent of the customers must be obtained in order for TROYARN to process personal data. Within this scope, personal data of customers may be processed in line with the approval of the Customer within the scope of planning and executing sales and marketing processes of TROYARN's products and/or services, planning and executing processes of creating and/or increasing loyalty to products and/or services offered by TROYARN, including creating campaigns for customers, performing cross-selling, determining target audience, carrying out activities to increase user experience by tracking Customer movements, improving the operation of TROYARN's website and mobile application and personalizing it according to Customer needs, carrying out direct and indirect marketing, personalized marketing and remarketing activities, carrying out personalized segmentation, targeting, analysis and in-house reporting activities, planning and executing market research, customer satisfaction activities and planning and executing customer relations management processes, and may be shared with the parties specified in this Information and Consent Text.
