This text is a translation provided for information purposes only. The legally binding text is the Turkish version of this document. View the Turkish version
Personal Data Protection and Privacy Policy
As Troy Depo Lojistik ve Teknoloji Hizmetleri A.Ş. (the "Company"), we would like to inform you that we attach great importance to the protection of your Personal Data and that we take the measures and steps required by the applicable legal regulations in this area.
Our Company takes the necessary measures to protect the personal data of our valued members and customers, franchisees, dealers, business partners, shareholders and employees, as well as of any other natural persons who establish a relationship with us by applying for a job, visiting our website or in any other way. We have prepared this Personal Data Protection and Privacy Policy (the "Privacy Policy") to inform you about our Company's rules and policies on the processing of personal data and the use of cookies and similar technologies under Personal Data Protection Law No. 6698 (the "KVKK").
We would like to remind you that the confidentiality, protection, processing, use and modification of member and customer information, communications and all other related matters on our Company's website and mobile application are subject to the privacy policy set out in this text, and that you should review this text each time you use our website to make sure you accept its terms.
Depending on the type and nature of the relationship between our Company, as the data controller, and the data subject, our Company may provide the data subject with personal data policies and/or notices that differ from this text. In that case, such specific policies and notices may contain provisions that differ from, or are in addition to, the statements in this Privacy Policy, and the data subject should give priority to the specific policies and notices provided to them.
LEGAL BASIS AND GENERAL PRINCIPLES
1.1. The protection of personal data is governed primarily by Law No. 6698, as well as by Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed Through Such Publications, Law No. 6563 on the Regulation of Electronic Commerce and the related secondary legislation. In addition, Turkish Penal Code No. 5237 also provides for a number of criminal sanctions to protect personal data.
1.2. In this context, the Law on the Protection of Personal Data defines "personal data" as any information relating to an identified or identifiable natural person. Accordingly, anonymous information, anonymized information and other data that cannot be associated with a specific person are not considered personal data under this Privacy Policy.
1.3. Data processing means any operation performed on personal data, such as obtaining, recording, storing, retaining, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, whether wholly or partly by automated means, or by non-automated means provided that they form part of a data filing system.
1.4. Our Company takes the measures required to protect confidentiality and processes personal data in compliance with all legal principles governing the processing of personal data, for the purposes set out in this Privacy Policy and in accordance with the principles listed below:
1.5. Lawfulness and fairness; accuracy and, where necessary, being kept up to date; processing for specified, explicit and legitimate purposes; being relevant, limited and proportionate to the purposes for which they are processed; and retention only for the period stipulated in the relevant legislation or required for the purposes for which they are processed.
DATA PROCESSED BY THE COMPANY
2.1. Our Company may process general and special categories of personal data with the explicit consent of the data subject or, in the cases set out in Articles 5 and 6 of the KVKK, without explicit consent. Examples of the general and special categories of data processed by our Company are given below; however, exactly which data are processed for each data subject may vary depending on various factors, such as the type of relationship between the data subject and our Company (member-customer, employee, business partner, service provider, etc.), its nature and the communication channels used.
2.2. In line with the relevant legislation and the principles set out in this Privacy Policy, our Company may process the following types of data, depending on the type of relationship between the data subject and our Company (for example, a member, customer, employee, business partner, service supplier or dealer relationship) and its nature:
2.3. Data that identify the data subject, such as first name, last name, occupation, title, employer, educational background, employment history, gender, marital status, citizenship status, tax liability status and, where applicable, information about parents, legal guardians and attorneys;
2.4. Data contained in identity documents such as ID cards, passports and driver's licenses, including date of birth, place of birth, ID number, blood type, religion and photograph;
2.5. Contact information such as the address, telephone number, email address and fax number of the data subject's home, workplace or temporary residence;
2.6. Where the data subject (customer-member) connects to our Company's website through their social media accounts, the information the data subject has agreed to share through those channels;
2.7. Communication records such as phone calls and email correspondence relating to products purchased by the data subject, as well as other audio and visual data;
2.8. Internet protocol (IP) address, device ID, unique identifier information, device type, advertising ID, unique device token, statistics on web page views, inbound and outbound traffic information, referral URL, internet log information, location information, sites visited, and information on transactions and actions performed through our websites, platforms, network, advertisements and email content.
PURPOSES FOR WHICH PERSONAL DATA ARE USED
3.1. Where and to the extent permitted by law, the Company may process personal data for the purposes listed below and retain them for as long as these purposes require.
3.2. Fulfilling legal and administrative obligations and exercising rights arising from applicable legislation;
3.3. Providing information to public officials on matters of public security upon request and as required by law;
3.4. Negotiating, concluding and performing contracts that have been or are intended to be concluded (for example, concluding distance sales contracts between our Company and member-customers, and performing the obligations undertaken under distance sales contracts and contracts concluded under the relevant articles of the Consumer Protection Law);
3.5. Verifying the identity of customers who shop, or have others shop on their behalf, through the website/mobile applications, and recording the address and other information required for communication;
3.6. Providing customers with a better shopping experience, identifying suitable products that may interest customers based on their interests and informing them about such products, keeping them informed of campaigns, promotions and benefits, and providing effective customer service;
3.7. Enabling our partner institutions and solution partners to offer suggestions and solutions to our customers, and informing our customers about the services we provide;
3.8. Contacting our customers to provide the necessary information about the terms, current status and updates of the contracts we conclude as distance sales contracts and under the relevant articles of the Consumer Protection Law;
3.9. Preparing all records and documents on which transactions are based, in electronic (internet/mobile, etc.) or paper form;
3.10. Increasing customer satisfaction; getting to know the customers who shop on our website and/or mobile applications and using this information in customer base analysis and in various marketing and advertising activities; and, in this context, conducting surveys electronically and/or physically through partner organizations;
3.11. Evaluating customer complaints and suggestions regarding our products and services;
3.12. Ensuring and improving coordination, cooperation and efficiency within and between our Company's units;
3.13. Ensuring the security of the website and other electronic systems used by our Company, as well as of our physical premises;
3.14. Notifying changes to legislation or to the rules and policies adopted by our Company, or making other notifications concerning the data subject;
3.15. Investigating, detecting and preventing breaches of contract and of the law, and reporting them to the relevant administrative or judicial authorities;
3.16. Resolving existing and potential legal disputes;
3.17. Responding to requests and questions;
3.18. Meeting staffing needs and conducting, developing and improving recruitment processes within the framework of our Company's human resources policies;
3.19. Assessing the suitability of job applications, finalizing them and contacting applicants;
3.20. Developing and improving our Company's human resources, public relations and marketing policies;
3.21. Cases where data processing is necessary for the establishment, exercise or protection of a right;
3.22. Protecting our Company's legitimate interests, provided that this does not harm the fundamental rights and freedoms of the data subject.
PROTECTION, SECURITY AND OVERSIGHT OF PERSONAL DATA
Within the scope of the relevant legislation, our Company, as the data controller, takes the technical and administrative measures necessary to ensure an appropriate level of security in order to ensure that personal data are processed lawfully, to prevent unlawful access to the data and to ensure that personal data are kept safe. In this context, our Company ensures that its business processes and activities are carried out in accordance with the internal policies and rules prepared to protect personal data.
Awareness-raising activities are carried out for employees regarding personal data protection legislation and the internal policies and rules prepared accordingly; declarations and undertakings regarding the confidentiality and protection of data are obtained from employees and from the persons and institutions that process data on behalf of our Company, and breaches of these declarations and undertakings are subject to certain sanctions.
The necessary information security measures are implemented to prevent unauthorized persons from accessing personal data, and the adequacy of these measures is reviewed periodically with the aim of continuously improving the existing data security system.
DOMESTIC AND INTERNATIONAL SHARING OF PERSONAL DATA WITH THIRD PARTIES, AND RETENTION PERIOD
5.1. Provided that we comply with the general principles set out in Article 4 of the KVKK and the conditions set out in Articles 8 and 9, and take the necessary security measures, we may transfer personal data to third parties in Türkiye and abroad for the purposes set out under the heading "Purposes for Which Personal Data Are Used" in this Privacy Policy, and may process and store such data on servers or in other electronic environments located in Türkiye and abroad.
5.2.
In this context, your personal data may be shared with the program partner institutions and organizations we cooperate with to carry out our activities; with the persons and institutions in Türkiye or abroad whose services we use to store data and from which we obtain physical server and/or cloud services; with the companies in Türkiye or abroad from which we obtain services for sending commercial electronic messages; with the Interbank Card Center (BKM); with the banks we have agreements with; with internationally certified payment institutions; and,
within the scope of marketing activities aimed at enhancing the customer experience and providing better service, with various advertising companies, agencies and survey companies in Türkiye or abroad, or with our other business partners in Türkiye or abroad.
5.3. Except where a longer period is required or permitted by law, our Company retains personal data only for the period necessary to fulfill the purposes set out in this Privacy Policy. Personal data whose retention period has expired are deleted, destroyed or anonymized by our Company in accordance with Article 7 of the KVKK.
RIGHTS OF THE DATA SUBJECT UNDER THE PERSONAL DATA PROTECTION LAW
6.1. As a data subject, under Article 11 of the KVKK, you have the right to:
- learn whether your personal data are being processed,
- request information if your personal data have been processed,
- learn the purpose of processing your personal data and whether they are used in line with that purpose,
- know the third parties in Türkiye or abroad to whom your personal data have been transferred,
- request the correction of your personal data if they have been processed incompletely or inaccurately,
- request the deletion or destruction of your personal data if the reasons requiring their processing no longer exist,
- request that corrections and deletions be notified to the third parties to whom your personal data have been transferred,
- object to any outcome to your detriment that results from the analysis of the processed data exclusively by automated systems,
- claim compensation if you suffer damage as a result of the unlawful processing of your personal data.
These rights are guaranteed to you by law.
6.2. If you wish to exercise any of the rights listed above as a data subject, you must complete the Troy Depo Application Form and either (i) deliver a wet-ink signed copy of the form in person or via a notary to Maslak, Büyükdere Cad. No:255 Nurol Plaza B.02, 34450 Sarıyer/Istanbul, or (ii) send the form, signed with your secure electronic signature, to our registered electronic mail (KEP) address [email protected]. (Note: Notifications sent with an electronic signature to registered electronic mail (KEP) addresses have the same legal effect as notifications made on paper via a notary.)
6.3. Requests from data subjects will be assessed and finalized within thirty days at the latest, depending on the nature of the request, in accordance with Article 13 of the KVKK. Positive or negative responses to data subjects' requests may be communicated to them in writing or electronically. Although data subjects' requests are, as a rule, handled free of charge, if responding to a request entails an additional cost, a fee may be charged in the amounts determined under the relevant legislation.
METHOD AND LEGAL BASIS FOR COLLECTING PERSONAL DATA
7.1. Your personal data may be obtained in written or verbal form, as audio or video recordings, or in other physical or electronic forms for the purposes set out in this Privacy Policy, within the framework of the conditions set out in Articles 5 and 6 of the KVKK. Personal data may be collected through stores and other physical locations where data subjects can contact us, the website, mobile applications, social media and other public channels, training sessions, conferences and similar events we organize, or through investigation.
7.2. Although we generally obtain personal data from the data subjects themselves, within the framework of the conditions set out in Articles 5 and 6 of the KVKK, personal data may also be obtained through the business partners we work with; persons, institutions and organizations listed as references in job applications or appearing in the applicant's employment and educational history; recruitment platforms; and persons and institutions that represent, or are represented by, the data subject.
USE OF COOKIES AND SIMILAR TECHNOLOGIES
8.1. When you access our Company's website, electronic platforms or applications, or the email messages or advertisements sent by our Company, small data files that allow certain data to be recorded and collected may be placed on users' computers, mobile phones, tablets or other devices. These data files placed on computers and other devices may be cookies, pixel tags, flash cookies and web beacons, as well as other similar technologies used for data storage. The term "cookie" is used to refer to the cookies and similar technologies that may be used by our Company.
8.2. Cookies store information collected through log files, clear GIF files and/or third-party sources in order to create a summary of your preferences, and may track your browsing information and/or your usage history on the site in order to show you personalized promotions, offer you promotions and marketing offers, tailor the content of the website or mobile application to you and/or determine your preferences.
8.3. Through "cookies," the website https://troydepo.com/ (.com) analyzes and interprets visitor movements and preferences tracked during site use, in addition to the email addresses and personal information requested in membership forms. A cookie is a file, usually made up of letters and numbers, that is stored in the internet browser or on the hard drive of the device being used and allows that device to be identified.
8.4. In order to provide better service to its visitors and within the framework of its legal obligations, the website https://troydepo.com/ (.com) will collect, process, share with third parties and securely store your browsing information, provided that it is not used outside the purposes and scope set out in this Personal Data Protection Disclosure.
8.5. Since not all data collected through cookies necessarily qualify as personal data, please note that data obtained through cookies will be assessed under this Privacy Policy and the KVKK only to the extent that they constitute personal data under Turkish law.
TYPES OF COOKIES AND USE OF THIRD-PARTY COOKIES
9.1. Our Company may match information collected from you on the website (.com) through different methods or at different times, such as information collected online and offline, and may use this information together with information obtained from other sources, such as third parties.
9.2. Cookies can be classified by duration or by the domain to which they belong. When classified by duration, cookies fall into two types: session cookies and persistent cookies. Session cookies are deleted when the user closes the browser, while persistent cookies remain on the user's computer/device for a predetermined period. Both session cookies and persistent cookies are used on the website and mobile applications of our Company's brand.
9.3. When classified by the domain to which they belong, cookies fall into two types: first-party cookies and third-party cookies. Cookies placed by the domain being visited are called first-party cookies, while cookies placed by a different domain are called third-party cookies. A third-party cookie is involved when parties other than the visited domain place cookies on the user's device through the visited domain.
9.4. In this context, our Company may also use cookies to activate "advertising technology" in order to show you advertisements it believes may interest you when you visit search engines, the website, the mobile application and/or websites on which the website advertises. Advertising technology uses information about your previous visits to the website/mobile application and to the websites/mobile applications on which the website advertises in order to show you personalized advertisements.
When these advertisements are shown, a unique third-party cookie may be placed in your browser so that the website can recognize you.
PURPOSES OF USING COOKIES
10.1. Our Company mainly uses cookies to store information collected through log files, clear GIF files and/or third-party sources in order to create a summary of your preferences, and to track your browsing information and/or usage history on the site in order to show you personalized promotions, offer you promotions and marketing offers, tailor the content of the website or mobile application to you and/or determine your preferences, thereby offering better services and standards.
10.2. In addition, our Company may use the cookies on its website, platform, applications, advertisements and messages for the purposes set out below.
10.3. Operational uses: Our Company may use the cookies it deems necessary for the administration and security of its website, platform, applications and services. Examples of cookies used for operational purposes include technologies that enable the use of functions on the website, applications and platforms, and cookies used to detect irregular behavior on these channels.
10.4. Functional uses: Our Company may use cookies to make its website, platform, applications and services easier to use and to personalize them for users. Examples of cookies used for functionality include technologies that allow us to remember user information and preferences.
10.5. Performance-related uses: Our Company may also use cookies to measure and improve the performance of its website, applications, platform and services. Examples of cookies used for this purpose include cookies that help us understand how users use our Company's website, applications, platform and services and analyze user behavior, as well as technologies that let us understand whether users have interacted with the messages we send.
10.6. Advertising uses: Our Company may use first-party and third-party cookies to deliver advertising and similar content tailored to users' interests through websites, platforms and applications owned by our Company or by third parties. Examples of advertising uses include cookies that measure the effectiveness of advertisements and cookies that show whether a particular advertisement has been clicked or how many times it has been viewed.
REJECTING AND DELETING COOKIES
11.1. Although most browsers allow the use of cookies, users can reject or delete cookies at any time by changing their browser settings. You can remove persistent cookies and reject both session cookies and persistent cookies by following the instructions in your browser's "help" file or by visiting www.allaboutcookies.org or www.youronlinechoices.eu. However, the method for changing these settings varies by browser, so you should check with your browser provider how to disable cookies.
11.2. If you disable cookies, you can continue to use the website and mobile application; however, you may not be able to access all of their functions, or your access may be limited, so some features of our Company's website, applications, platform and services may not be available to you.
AUTHORIZED SERVICE PROVIDERS
We may receive assistance from certain service providers we authorize to operate and promote our Company's website, platform, applications and services. These service providers may also place cookies and similar technologies (third-party cookies) on users' computers/devices and collect information such as IP address, unique identifier and device identifier in order to identify the user's device.
THIRD-PARTY WEBSITES, PRODUCTS AND SERVICES
Our Company's website, platform and applications may contain links to third-party websites, products and services. Such links are subject to the privacy policies of the respective third parties; please note that third parties and their websites are independent of our Company and that our Company is not responsible for the privacy practices of third parties. If you visit a linked website, we recommend that you read that site's privacy policy.
CHANGES
14.1. Our Company may amend this Personal Data Protection and Privacy Policy at any time, and amendments take effect upon publication on the website. Changes made by our Company will be communicated to the persons concerned through the website. The current version of the Privacy Policy is therefore always available on our Company's website, where any changes to the Privacy Policy can also be followed.
14.2. As a rule, changes will be made by publishing them on our Company's website and will take effect as of that date; however, our Company may also announce changes in any other manner it deems appropriate.
COMMUNICATION AND CONSENT REGARDING PERSONAL DATA
By accepting this Privacy/Personal Data Protection Policy and Communication Consent, you consent to the collection, storage, processing and use of the personal data you have agreed to share with our Company for the purposes set out in this Privacy Policy (including providing and offering various benefits; carrying out all kinds of electronic communication by telephone, text message (SMS), email and similar means for personalized promotion, sales promotion, advertising, sales, marketing, survey and similar purposes; and sending other communication messages),
and to their transfer to the third parties detailed above with whom our Company has a contractual relationship.
Last Updated: 01.17.2025
