Turkticaret.Net Yazılım Hizmetleri Sanayi ve Ticaret Anonim Şirketi Lock&Key Corporate Customer Clarification Text
This Clarification Text has been prepared in accordance with Article 10 of the Personal Data Protection Law No. 6698 (“KVKK” or “ Law”) and the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Clarification Obligation.
As Turkticaret.Net Yazılım Hizmetleri Sanayi ve Ticaret Anonim Şirketi (“ Data Controller” or “Turkticaret.Net”), extreme importance is attached to the protection and processing of your personal data and ensuring its security. In this context, sensitivity is shown to the processing and preservation of all kinds of personal data collected in accordance with the KVKK and its secondary regulations.
Being aware that as the Data Controller, we are responsible for the personal data being processed by the Data Controller or with the instruction of the Data Controller as specified in the KVKK, your personal data is processed as explained below and within the framework of the limitations permitted by the legislation.
In accordance with KVKK No. 6698, your personal data may be processed by Turkticaret.Net Yazılım Hizmetleri Sanayi ve Ticaret Anonim Şirketi as "Data Controller" within the scope described below.
You can access detailed information regarding the processing of your personal data processed by Turkticaret.Net through the relevant policies located at the internet address
https://www.turkticaret.net/kvkk-bilgilendirme
.
Collection and Processing of Personal Data and Processing Purposes
| Data Processing Activity | Data Subject | Data Category | Processing Purpose | Collection Method | Legal Grounds |
|---|---|---|---|---|---|
Execution of membership processes for corporate users who want to become members of the Lock & Key mobile application | Corporate Customer Official/Employee/Representative | Identity(Name and Surname, Title) Contact(E-Mail Address) | Conducting Activities in Accordance with LegislationConducting Loyalty Processes for Company/Product/ServicesConducting Communication ActivitiesExecution/Audit of Business ActivitiesConducting Goods/Service Sales ProcessesConducting Customer Relationship Management Processes | Electronically directly from the data subject | KVKK Art. 5/2 - c) Provided that it is directly related to the establishment or performance of a contract, the processing of personal data of the parties to the contract is necessary. |
Execution of purchasing transactions of the service in order to use paid features through the Lock & Key mobile application | Corporate Customer Official/Employee/Representative | Identity(Name and Surname) Contact(E-Mail Address, Phone Number) Customer Transaction (Payment Information) | Conducting Activities in Accordance with LegislationConducting Loyalty Processes for Company/Product/ServicesConducting Communication ActivitiesExecution/Audit of Business ActivitiesConducting Goods/Service Sales ProcessesConducting Customer Relationship Management Processes | Electronically directly from the data subject | KVKK Art. 5/2 - c) Provided that it is directly related to the establishment or performance of a contract, the processing of personal data of the parties to the contract is necessary. |
Collection and reporting of mobile application and usage period information performed by memberships linked to the corporate customer on the smartphone with the Lock & Key mobile application | Users Defined by Corporate Customer | Device/Technical Information(Device Type) Application Usage Information (Active Usage Information of Applications, Background Running Times of Applications, Device Session Times, Device Inactive Times) | Conducting Activities in Accordance with LegislationConducting Goods/Service Sales ProcessesConducting Goods/Service Production and Operation ProcessesConducting Customer Relationship Management ProcessesConducting Contractual ProcessesConducting Information Security ProcessesFollow-up of Requests / Complaints | Electronically directly from the data subject | KVKK Art. 5/2 - c) Provided that it is directly related to the establishment or performance of a contract, the processing of personal data of the parties to the contract is necessary. KVKK Art. 5/2 - f) Provided that it does not harm the fundamental rights and freedoms of the data subject, the processing of data is mandatory for the legitimate interests of the data controller. |
Keeping log records for transaction and information security purposes with the effective operation of the Lock & Key mobile application | Corporate Customer Official/Employee/Representative | System Information(App Login-Logout Logs, Error (Crush) Records) | Conducting Information Security ProcessesExecution/Audit of Business ActivitiesEnsuring the Security of Data Controller OperationsConducting Goods/Service Production and Operation ProcessesConducting Activities in Accordance with LegislationConducting Storage and Archive Activities | Electronically directly from the data subject | KVKK Art. 5/2 - a) Clearly provided for in the laws. KVKK Art. 5/2 - f) Provided that it does not harm the fundamental rights and freedoms of the data subject, the processing of data is mandatory for the legitimate interests of the data controller. |
Answering complaints, suggestions, requests and questions | Corporate Customer Official/Employee/Representative | Comment and Complaint Information | Conducting Loyalty Processes for Company/Product/ServicesReceiving and Evaluating Suggestions for Improvement of Business ProcessesConducting After-Sales Support Services for Goods/ServicesConducting Customer Relationship Management ProcessesConducting Customer Satisfaction Oriented ActivitiesFollow-up of Requests/Complaints | Electronically directly from the data subject | KVKK Art. 5/2 - c) Provided that it is directly related to the establishment or performance of a contract, the processing of personal data of the parties to the contract is necessary. KVKK Art. 5/2 - f) Provided that it does not harm the fundamental rights and freedoms of the data subject, the processing of data is mandatory for the legitimate interests of the data controller. |
Execution of legal transactions and dispute processes | Corporate Customer Official/Employee/Representative | Identity(Name and Surname) Contact(E-Mail Address, Phone Number) Legal Action(Execution Information, Lawsuit Information) | Conducting Audit / Ethics ActivitiesConducting Activities in Accordance with LegislationFollow-up and Execution of Legal AffairsConducting Internal Audit / Investigation / Intelligence ActivitiesProviding Information to Authorized Persons, Institutions and Organizations | Electronically directly from the data subject | KVKK Art. 5/2 - e) Data processing is mandatory for the establishment, use or protection of a right. |
Your collected personal data will be collected and processed by Turkticaret.Net only within the scope of the purposes stated above, and in the event of a change in these purposes, you will be informed separately regarding the new processing activity.
Your personal data is processed in accordance with the law and the principles of honesty, accurately and when necessary, in a up-to-date manner, for specific, clear, and legitimate purposes, in connection with and limited to these purposes, and is preserved for the periods stipulated in the relevant legislation or for the period necessary for the purpose of processing.
Transfer of Personal Data to 3rd Parties and Transfer Purposes
Your personal data collected in line with the fulfillment of the purposes set out in Article 2 above; within the scope of our legitimate interests, can be transferred to our business partners and suppliers located in Turkey and abroad, and within the scope of being clearly provided for in the laws and the fulfillment of our legal obligations, to legally authorized public institutions and legally authorized private persons within the framework of the data processing conditions regulated in Article 5 of the Law and in accordance with the rules regarding the transfer of personal data specified in Articles 8 and 9 of the Law.
As a data subject, if you submit your requests regarding your rights to the Data Controller through the methods specified below, the Data Controller will conclude your request within thirty days at the latest and free of charge, depending on its nature. However, if a fee is stipulated by the Personal Data Protection Board, a fee may be requested.
According to Article 11 of the KVKK, your rights as a data subject are as follows:
To learn the purpose of the processing of personal data and whether this data is being used in compliance with such purpose,
To know the third parties to whom personal data is transferred in Turkey or abroad,
To request the rectification of personal data if it has been processed incompletely or inaccurately and to request the notification of such rectification to third parties to whom personal data has been transferred,
To request the erasure or destruction of personal data in the event that the reasons for its processing no longer exist, despite being processed in accordance with the Law and other relevant legal provisions, and to request the notification of such operation to third parties to whom personal data has been transferred,
To object to the occurrence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,
To request compensation for the damages in case the person incurs damages due to the unlawful processing of personal data.
The Data Controller reserves the right to make changes within the scope of this Clarification Text due to changes that may occur in the KVKK and the methods to be determined and the decisions to be made by the Personal Data Protection Board.
In accordance with the 1st paragraph of Article 13 of the KVKK, in order to exercise your rights stated above, you can submit your relevant request to Turkticaret.Net by filling out the "Data Subject Application Form" which you can access via the lockandkey.com.tr and lockandkeyapp.co.uk internet address.