Turkticaret.Net Software Services Industry and Trade Joint Stock Company Lock&Key Individual Customer Clarification Text
This Clarification Text has been prepared in accordance with Article 10 of the Personal Data Protection Law No. 6698 (“KVKK” or the “ Law”) and the Communiqué on the Procedures and Principles to be Followed in Fulfillment of the Obligation to Inform.
As Turkticaret.Net Software Services Industry and Trade Joint Stock Company (“ Data Controller” or “Turkticaret.Net”), we attach great importance to the protection and processing of your personal data and ensuring its security. In this context, sensitivity is shown regarding the processing and preservation of all kinds of personal data collected in accordance with KVKK and its secondary regulations.
Being aware of the responsibility as the “Data Controller” regarding personal data being processed by the Data Controller or upon the Data Controller's instructions as stated in the KVKK, your personal data is processed as described below and within the limits permitted by the legislation.
In accordance with KVKK No. 6698, your personal data may be processed by Turkticaret.Net Software Services Industry and Trade Joint Stock Company as the “Data Controller” within the scope described below.
Detailed information regarding the processing of your personal data processed by Turkticaret.Net can be reached through the relevant policies located at the internet address
https://www.turkticaret.net/kvkk-bilgilendirme
.
Collection, Processing, and Purposes of Processing of Personal Data
| Data Processing Activity | Data Subject | Data Category | Purpose of Processing | Collection Method | Legal Grounds |
Carrying out member processes for users who want to become members of the Lock&Key mobile application | Service Recipient | Identity(First Name and Last Name, Title, Age Range) Contact(E-Mail Address) | Execution of Activities in Accordance with Legislation, Execution of Commitment Processes to Company / Product / Services, Execution of Communication Activities, Execution / Supervision of Business Activities, Execution of Product / Service Sales Processes, Execution of Customer Relationship Management Processes | Directly from the data subject electronically | KVKK Art. 5/2 - c) Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract. |
Execution of service purchase transactions in order to use paid features through the Lock&Key mobile application | Service Recipient | Identity(First Name and Last Name) Contact(E-Mail Address, Phone Number) Customer Transaction (Payment Information) | Execution of Activities in Accordance with Legislation, Execution of Commitment Processes to Company / Product / Services, Execution of Communication Activities, Execution / Supervision of Business Activities, Execution of Product / Service Sales Processes, Execution of Customer Relationship Management Processes | Directly from the data subject electronically | KVKK Art. 5/2 - c) Processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract. |
Collection and reporting of mobile application and usage time information carried out on the smartphone with the Lock&Key mobile application | Service Recipient | Device/Technical Information(Device Type) Application Usage Information (Active Usage Information of Applications, Background Running Times of Applications, Device Session Durations, Device Inactivity Times) | Execution of Activities in Accordance with Legislation, Execution of Product / Service Sales Processes, Execution of Product / Service Production and Operation Processes, Execution of Customer Relationship Management Processes, Execution of Contract Processes, Execution of Information Security Processes, Follow-up of Requests / Complaints | Directly from the data subject electronically | KVKK Art. 5/2 - c) Processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract. KVKK Art. 5/2 - f) Processing of data is necessary for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed. |
Keeping log records for the effective operation of the Lock&Key mobile application and for transaction and information security purposes | Service Recipient | System Information (Application Entry-Exit Logs, Error (Crash) Records) | Execution of Information Security Processes, Execution / Supervision of Business Activities, Ensuring the Security of Data Controller Operations, Execution of Product / Service Production and Operation Processes, Execution of Activities in Accordance with Legislation, Execution of Storage and Archive Activities | Directly from the data subject electronically | KVKK Art. 5/2 - a) Explicitly provided for by law. KVKK Art. 5/2 - f) Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject. |
Answering complaints, suggestions, requests, and questions | Service Recipient | Comment and Complaint Information | Execution of Commitment Processes to Company / Product / Services, Reception and Evaluation of Suggestions for Improvement of Business Processes, Execution of After-Sales Support Services for Products / Services, Execution of Customer Relationship Management Processes, Execution of Activities for Customer Satisfaction, Follow-up of Requests / Complaints | Directly from the data subject electronically | KVKK Art. 5/2 - c) Processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract. KVKK Art. 5/2 - f) Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject. |
Carrying out legal transactions and dispute processes | Service Recipient | Identity(First Name and Last Name) Contact(E-Mail Address, Phone Number) Legal Transaction(Enforcement Information, Lawsuit Information) | Execution of Audit / Ethics Activities, Execution of Activities in Accordance with Legislation, Follow-up and Execution of Legal Affairs, Execution of Internal Audit / Investigation / Intelligence Activities, Providing Information to Authorized Persons, Institutions, and Organizations | Directly from the data subject electronically | 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 specified above, and in the event of a change in these purposes, you will be specifically informed about the new processing activity.
Your personal data is processed in accordance with the law and honesty principles, in an accurate and, where necessary, up-to-date manner, for specific, clear, and legitimate purposes, in connection with these purposes and limited to them, and is preserved for the periods stipulated in the relevant legislation or for the period required for the processing purpose.
Transfer of Personal Data to 3rd Parties and Transfer Purposes
Your personal data collected in order to fulfill the purposes set out in Article 2 above; may be transferred to our business partners and suppliers resident in the country and abroad within the scope of our legitimate interests, to legally authorized public institutions and legally authorized private persons within the scope of being clearly stipulated in the laws and fulfilling our legal obligations, in accordance with the data processing conditions regulated in Article 5 of the Law and 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 by the methods specified below, the Data Controller will conclude your request within the shortest possible time and at the latest within thirty days, depending on its nature, without charging any fee. However, if a fee is stipulated by the Personal Data Protection Board, a fee may be requested.
Your rights as a data subject according to Article 11 of the KVKK are as follows:
Learning the purpose of processing your personal data and whether your data is used in accordance with its purpose,
Knowing the third parties to whom your personal data is transferred in the country or abroad,
Requesting the correction of your personal data if it has been processed incompletely or incorrectly and requesting the notification of the transaction made within this scope to the third parties to whom your personal data is transferred,
Requesting the deletion or destruction of your personal data in the event that the reasons requiring its processing have disappeared, although it has been processed in accordance with the KVKK and other relevant law provisions, and requesting the notification of the transaction made within this scope to the third parties to whom your personal data is transferred,
Objecting to the occurrence of a result against you by analyzing your processed data exclusively through automated systems,
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 decisions to be given with the methods to be determined by the Personal Data Protection Board.
In accordance with the 1st paragraph of Article 13 of the KVKK, you can submit your relevant request to Turkticaret.Net by filling out the “Data Subject Application Form” which you can reach through the lockandkey.com.tr and lockandkeyapp.co.uk internet address to exercise your rights specified above.