PERSONAL DATA PROTECTION LAW CLARIFICATION TEXT

As Kampotu İlaç Gıda San. Ve Tic. A. Ş. (to be referred to as “Kampotu”), we sensitively protect the personal data of our dear shareholders, and we execute all of our obligations in the capacity of data controller in accordance with the Personal Data Protection Law numbered 6698 (to be referred to as “KVKK”) and the relevant legislation as per the law. With this clarification text, we express within which scope the personal data of our shareholders can be processed and the rights of our shareholders.

1.    Your Personal Data and Our Obtaining Methods

Within the scope of KVKK, personal data means all information like the name, last name, Republic of Turkey ID number, tax number, address, e-mail address, IP address of the identified or identifiable natural person (“Personal Data”) and Special Category of Personal Data, a special type of it, means your data regarding race, ethnic origin, political view, philosophical belief, religion, sect or other beliefs, appearance, association, foundation or union membership, health, sexual life, criminal conviction and security measures as well as your biometric and genetic data (“Special Category of Personal Data”). The explanations made for your Personal Data within the scope of this Clarification Text also include your Special Category of Personal Data. All of your information that you share with us on the telephone or in writing or electronically is processed within the scope of KVKK.

2.    With Which Methods and For What Legal Reasons Do We Collect Your Personal Data?

We act in compliance with all obligations and principles sought in the relevant legislation, including KVKK, in all of the personal data processing activities that we conduct, and we take the necessary security measures so that your Personal Data are processed securely. As per KVKK, we collect your Personal Data via automatic or nonautomated means through those listed below, and through other channels that might be added in the future, vocally, verbally, in writing or electronically, and we process them within the scope of Article 5.1, Article 5.2, Article 6.2 and Article 6.3 of KVKK, depending on the processing purpose:

  • Within the scope of the promotional activities of all products that are produced and/or sold by Kampotu,
  • Correspondences through our e-mail addresses (“E-mail”), texts (“SMS”) or multimedia messages (“MMS”) sent regarding Kampotu, its activities and other purposes, other means of communication as well as all other communication tools (“Communication Tools”),
  • Through third persons such as the group companies, business partners, manufacturing companies which Kampotu delivers or receives services or companies to which it supplies services/products.

3.    To Whom Can the Personal Data Be Transferred?

The persons/establishments to which the personal data can be transferred for this purpose are; institutions or establishments permitted by KVKK and the other legislative provisions; Personal Data Protection Authority, our affiliate companies and/or direct/indirect domestic/international subsidiaries/partners; and other third persons which we receive services from to conduct our activities as Kampoty, with which we cooperate and with whom are jointly and severally responsible for taking data security measures such as the protection of all your personal data, prevention of unauthorized access and illegal processing. Your personal data can be transferred only to in the presence of purposes of processing that do not require your express consent to the third parties which support us in the areas of storage, archiving, information technologies support (server, hosting, program, cloud computing), safety, call center in the country and abroad including the EU countries, the USA, England, OECD countries, India, China and Russia, and all government institutions and agencies, Group Companies, business partners, supplying companies, banks, financing institutions which are cooperated with and/or deliver services, consultancy companies which provide support in areas such as law, taxes, etc. and all government agencies and institutions which they need to be transferred as per the relevant laws, other related parties and authorized agencies and institutions where transfer is necessary for the specified purposes. 

In addition, only on condition that your express consent is obtained, they can be transferred to third parties that are located domestically and in the abovementioned countries; that deliver product and service support, and that can process your personal data based on your express consent stated above. Also, based on your express consent, in the event that part of or the assets (including but not limited to the brand, domain and other commercial business elements) of Kampotu are sold, your Personal Data can be transferred to the natural or legal entities who are taking over, and to their domestic or international third parties including their shareholders, business partners, mediators, consultants to the extent as required by the transfer, and by means of the necessary assessment by these third persons throughout the process, they can be processed on a limited scale and the party that is taking over in the event of a transfer can continue to process these assets and your Personal Data, which are their related assets, as the data controller.

Our Company can share your personal data that we obtain from you on our website and via our other means of communication with the public institutions or establishments that are authorized to request these data as per legal obligation, and with contractual the domestic and international establishments as per our activities and our business partners, on condition that the adequate and effective measures are taken as per the legislative security and privacy principles.

4.    Which of Your Personal Data Do We Process?

Following are examples of your Personal Data that we process:

Personal Data That You Provide to Us: Name-last name, date of birth, R.T. ID number, tax number, telephone number, e-mail address, workplace and residence addresses, security footages and all your other personal data that you share with us via the abovementioned channels.
Other Information Including Automatically Collected Personal Data: Your personal data collected automatically with video and voice recording devices or other means.

Other Information Including Personal Data From Other Sources: Your personal data such as the updated delivery and address information; account information that our business partners, suppliers and other third persons share with us based on your prior consent.

5.    Why Do We Process Your Personal Data?

We process your Personal Data without your express consent in exceptional circumstances permitted under KVKK, and with your express consent for some of your data stated in the law.

These data of yours are collected and processed within the scope of Article 5/2 and Article 6/3 of KVKK under the following circumstances of;

  • The purpose of fulfilling our legal obligations,
  • Compliance with the information storage, reporting, informing obligations stipulated by the legislation, the relevant regulative institutions and other authorities,
  • Selling, supplying, delivering transportation services, products or services,
  • Establishing or performing an agreement like taking your questions and complaints, replying you, and using them in case of a possible conflict or in the purpose of fulfilling our legal obligations or establishing or protecting a right, and protecting our legitimate interests like customer satisfaction provided that your fundamental rights and freedoms are not harmed, lowering the costs, productive use of resources.

Your Personal Data which are collected via the abovementioned means with the abovementioned channels can be processed in the purpose of sending you promotional and informative messages about our new and existing products, processing them to create new service models, using cookies in this purpose, corporate communication and organizing other events and invitations within this scope, and informing about them.

6.    How Long Do We Process Your Personal Data?

Your Personal Data shall be processed in all circumstances in line with the relevant legislation on personal data protection including KVKK and the durations required in the other legislations, unless the legitimate purposes above are removed.

7.    Conditions Under Which Your Personal Data Can Be Processed

As stated in the article 5 of KVKK,

  • The presence of your express content,
  • When explicitly stipulated in the law,
  • When mandatory to protect the life or bodily integrity of self or someone else who is unable to express their consent due to physical impossibility or whose consent is not legally validated,
  • When it is necessary to process the personal data of the parties of the contract, provided that it is directly related to the establishment or performance of a contract,
  • When mandatory for the data controller to fulfill their legal obligation,
  • When made public by the relevant person themselves,
  • When data processing is mandatory to establish, exercise or protect a right,
  • Provided that the fundamental rights and freedoms of the relevant person stay unharmed, as long as at least one of the processing conditions exist such as the necessity of data processing for the legitimate interests of the data controller, we collect, records, store, protect, update to continue our services, edit, transfer and process your information.

8.    Your Rights as the Data Owner

As stated in the article 11 of KVKK, as the data owner, you have the rights to,

  • Learn whether your personal data are processed,
  • Requesting information if your personal data have been processed,
  • Learning the purpose for processing your personal data and whether they have been used relevantly,
  • Knowing the third persons to whom your personal data have been transferred domestically or internationally,
  • In the event of incomplete or incorrect processing of your personal data, requesting their correction,
  • Requesting that your personal data are deleted or destroyed within the framework of the conditions stipulated in the article 7 of the law,
  • Requesting that the third persons to whom your personal data are transferred are informed of the procedures conducted as per the two articles above,
  • Contesting to a consequence against you by analyzing the processed data exclusively by means of automatic systems,
  • In the event that you suffer losses due to illegal processing of your personal data, requesting that the losses are recovered.

Within this scope, you can fill out the application form with your requests about your said rights on our website called “www.kampotu.com” and send it to the e-mail address “[email protected]”. In addition, you should be sending this Application Form to our e-mail address with the PEC extension to be notified to you with secure e-signature, or to our mailing address below with your identification documents with wet signature or through a notary. Kampotu will finalize your request as soon as possible after receiving the relevant documents and free of charge within 30 (thirty) days at the latest. In the event that any costs occur de to the fulfilling of your request, we can only request from you the fees in the tariff as specified by the Personal Data Protection Authority.

Mailing Address: İAYOSB Aydınlı Mah. Gazi Bulvarı No:50/A Tuzla/Istanbul (Istanbul Trade Registry No: 838272, Central Registration System No: 0494 0586 4950 0001)

E-Mail Address: [email protected]

For further information on the subject, you can review the Personal Data Protection Law numbered 6698, and visit the website www.kvkk.gov.tr.

Respectfully,

Kampotu İlaç Gıda San. Ve Tic. A.Ş. (“Kampotu”)

Address: İAYOSB Aydınlı Mah. Gazi Bulvarı No: 50/A Tuzla/Istanbul
Telephone: +90 (216) 266 20 06
E-mail: [email protected]

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