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 importance to the protection of your Personal Data and that we take measures and steps in this area in compliance with the legal regulations.
Our Company takes the necessary measures to protect the personal data of our valued members and customers, franchisees, dealers, business partners, shareholders and employees, and of other natural persons who establish a relationship with us by applying for a job, visiting our website or in any other way, and has prepared this Personal Data Protection and Privacy Policy (the "Privacy Policy") in order to inform you about our Company rules and policies on the processing of personal data and the use of cookies and similar technologies within the framework of the Personal Data Protection Law No. 6698 ("KVKK").
We would like to remind you that, with regard to the confidentiality, protection, processing, use and modification of member and customer information, communications and other matters at our Company and on its website and mobile application, you will be 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 that you accept the 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 provided to the data subject may contain matters that differ from or are additional to the explanations in this Privacy Policy, and the data subject should give priority to the specific policies and notices provided to them.
1) LEGAL BASIS AND GENERAL PRINCIPLES
1.1. The protection of personal data is regulated primarily by Law No. 6698, as well as by Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications, Law No. 6563 on the Regulation of Electronic Commerce and the related secondary legislation. In addition, the Turkish Penal Code No. 5237 also provides for a number of criminal sanctions for the protection of personal data.
1.2. In this context, an examination of the Personal Data Protection Law shows that the definition of “personal data” covers 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, in turn, means any operation performed on personal data, such as obtaining, recording, storing, retaining, altering, reorganizing, disclosing, transferring, taking over, making retrievable, classifying or preventing the use of personal data, whether by fully or partially automated means or by non-automated means provided that they form part of a data filing system.
1.4. Taking the measures necessary to protect confidentiality and in compliance with all legal principles relating to the processing of personal data, our Company processes personal data within the scope of the purposes specified 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 for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
2) 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 provided for in Articles 5 and 6 of the KVKK, without explicit consent. Although the general and special categories of data processed by our Company are exemplified below, which data will be processed for each individual data subject may vary depending on various factors, such as the type and nature of the relationship between the data subject and our Company (member-customer, employee, business partner, service provider, etc.) 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 types of data specified below, depending on the type and nature of the relationship between the data subject and our Company (for example, a member, customer, employee, business partner, service supplier or dealer relationship with our Company):
2.3. Data for identifying the data subject, such as first name, surname, occupation, title, employer institution/organization, educational background, employment history, gender, marital status, citizenship status, tax liability status and, if any, information on parents, guardians and proxies,
2.4. Data contained in identification documents such as identity cards, passports and driving licenses, such as date of birth, place of birth, identity number, blood group, religion and photograph,
2.5. Contact details such as the address, telephone number, email address and fax number of the 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 that the data subject has consented to share through those channels,
2.7. Communication records, such as telephone 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, referring URL, internet log information, location information, sites visited, and information on transactions and actions performed through our websites, platforms, internet network and advertising and email content.
3) PURPOSES OF USE OF PERSONAL DATA
3.1. Where and to the extent permitted by the legislation, the Company may process personal data for the purposes set out below, and such data may be retained for as long as these purposes require.
3.2. Fulfilling legal and administrative obligations and exercising rights arising from the legislation in force,
3.3. Providing information to public officials on matters relating to 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 agreements between our Company and member customers and performing the obligations undertaken under the distance sales agreement and contracts concluded under the relevant articles of the Law on Consumer Protection),
3.5. Verifying the identity details of Customers who shop, or have others shop on their behalf, via the website/mobile applications, and recording the address and other information necessary for communication,
3.6. Providing customers with a better shopping experience, identifying suitable products that may interest customers based on their interests and informing customers about such products, informing them about campaigns, promotions and benefits, and providing effective customer service,
3.7. Enabling our contracted 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 and providing the necessary information regarding the terms, current status and updates of the distance sales agreement and the contracts we have concluded under the relevant articles of the Law on Consumer Protection,
3.9. Preparing all records and documents that will serve as the basis for transactions in electronic (internet/mobile, etc.) or paper form,
3.10. Increasing customer satisfaction, getting to know our customers who shop via the website and/or mobile applications and using this in customer base analysis and in various marketing and advertising activities, and in this context conducting surveys electronically and/or physically through contracted 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 the units of our Company,
3.13. Ensuring the security of the website and other electronic systems and physical premises used by our Company,
3.14. Notifying changes in the legislation or in 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 future 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 job applicants,
3.20. Developing and improving our Company's human resources, public relations and marketing policies,
3.21. Where data processing is necessary for the establishment, exercise or protection of a right,
3.22. Protecting the legitimate interests of our Company, provided that this does not harm the fundamental rights and freedoms of the data subject.
4) PROTECTION, SECURITY AND AUDIT OF PERSONAL DATA
Within the scope of the relevant legislation, our Company, as the data controller, takes the necessary technical and administrative measures 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 the safekeeping of personal data. In this context, it is ensured that our Company's business processes and activities are carried out in accordance with the internal policies and rules prepared for the protection of personal data. Activities are carried out to raise employees' awareness of personal data protection legislation and of the internal policies and rules prepared accordingly; the necessary declarations and undertakings for the confidentiality and protection of data are obtained from employees and from the persons and organizations processing 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 the measures taken is checked at regular intervals with the aim of continuously improving the existing data security system.
5) SHARING OF PERSONAL DATA WITH THIRD PARTIES IN TÜRKIYE AND ABROAD AND RETENTION PERIOD
5.1. Provided that we comply with the general principles listed in Article 4 of the KVKK and the conditions set out in Articles 8 and 9 thereof and take the necessary security measures, we may transfer personal data to third parties in Türkiye and abroad for the purposes indicated under the heading “Purposes of Processing Personal Data” of this Privacy Policy, and may process and store them on servers or other electronic media 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 in order to carry out our activities; with persons and organizations in Türkiye or abroad whose services we use to store data and from which we obtain physical server and/or cloud services; with companies in Türkiye or abroad from which we obtain services for sending commercial electronic messages; with the Interbank Card Center; 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 achieve the purposes specified in this Privacy Policy. Personal data whose retention period has expired are erased, destroyed or anonymized by our Company in accordance with Article 7 of the KVKK.
6) RIGHTS OF THE DATA SUBJECT UNDER THE PERSONAL DATA PROTECTION LAW
6.1. As a data subject, pursuant to 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 the processing of personal data and whether they are used in accordance with that purpose,
- know the third parties in Türkiye or abroad to whom your personal data are transferred,
- request the rectification of personal data if they have been processed incompletely or inaccurately,
- request the erasure or destruction of personal data if the reasons requiring their processing no longer exist,
- request that rectification and erasure operations be notified to the third parties to whom the personal data have been transferred,
- object to a result arising to your detriment from the analysis of the processed data exclusively by means of automated systems,
- claim compensation if you suffer damage due to the unlawful processing of personal data
6.2. If you wish to exercise any of the rights set out above as a data subject, you must fill in the Application Form available at https://troydepo.com/bilgi-edinme-basvuru-formu/ and either (i) deliver a copy of the form bearing your wet-ink signature to Maslak, Büyükdere Cad. No:255 Nurol Plaza B.02, 34450 Sarıyer/İstanbul in person or through a notary public, or (ii) send the form with your secure electronic signature to the registered electronic mail address [email protected]. (Note: Notifications made using an electronic signature to registered electronic mail (KEP) addresses have the same legal effect as notifications made on paper through a notary public.)
6.3. Requests from data subjects will be assessed and concluded 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 requests from data subjects may be communicated to the data subjects in writing or electronically. Although requests from data subjects will, as a rule, be concluded 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.
7) METHOD AND LEGAL BASIS FOR COLLECTING PERSONAL DATA
7.1. Your personal data may be obtained in writing, verbally, by audio or video recording or in other physical or electronic forms, for the purposes specified in this Privacy Policy and 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 premises where data subjects may make contact, the website, mobile applications, social media and other public channels, or through trainings, conferences and similar events organized, or by means of 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, they may also be obtained through the business partners we work with; persons, institutions and organizations given as references in job applications or appearing in the applicant's employment and educational history; recruitment platforms; and persons and organizations represented by or representing the data subject.
8) USE OF COOKIES AND SIMILAR TECHNOLOGIES
8.1. When users access our Company's website, electronic platforms or applications, or email messages or advertisements sent by our Company, small data files that enable certain data to be recorded and collected may be placed on users' computers, mobile phones, tablets or other devices used. 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 for data storage purposes. The term “cookie” is used to refer to 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 usage history on the site in order to provide personalized promotion, offer 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 https://troydepo.com/ website analyzes and interprets visitor movements and preferences tracked during use of the site, in addition to the email addresses and personal information requested in membership forms. A cookie is a file, mostly consisting of letters and numbers, that is stored in the internet browser or on the hard disk of the device in use and enables 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 https://troydepo.com/ website will collect, process, share with third parties and securely store your browsing information, provided that it is not used outside the purposes and scope determined in this Personal Data Protection Statement.
8.5. Since not all data collected through cookies may qualify as personal data, it should be noted 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.
9) TYPES OF COOKIES AND USE OF THIRD-PARTY COOKIES
9.1. Our Company may match information collected from you on the site by different methods or at different times, such as information collected online and offline on the website, 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 are divided into two types: session cookies and persistent cookies. Session cookies are cookies that are deleted when the user closes the browser, while persistent cookies are cookies that remain on the user's computer/device for a predetermined period. Our Company uses session cookies and persistent cookies on the website and mobile applications of its brand.
9.3. When classified by the domain to which they belong, cookies are divided into two types: first-party cookies and third-party cookies. Cookies placed by the domain visited are called first-party cookies, while cookies placed by a different domain are referred to as third-party cookies. Third-party cookies arise where persons other than the visited domain place cookies on the user's device via the visited domain.
9.4. In this context, our Company may also use cookies to activate “advertising technology” in order to present you with advertisements that it believes may interest you when you visit search engines, the website, the mobile application and/or the 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 presenting these advertisements, a unique third-party cookie may be placed in your browser so that the website can recognize you.
10) PURPOSES OF USE OF COOKIES
10.1. Our Company essentially 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 provide personalized promotion, offer 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 it employs on its website, platform, applications, advertisements and messages for the purposes set out below.
10.3. Operational uses: Our Company may use cookies that 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. Functionality uses: Our Company may use cookies to facilitate the use of its website, platform, applications and services and to customize them for users. Examples of cookies used for functionality include technologies that allow us to remember user information and preferences.
10.5. Performance uses: Our Company may also use cookies to improve and measure the performance of its website, applications, platform and services. Examples of cookies used for this purpose include cookies that allow us to understand how users use our Company's website, applications, platform and services and to analyze user behavior, as well as technologies that enable us to understand whether the messages we send have been interacted with.
10.6. Advertising uses: Our Company may use first-party cookies and third-party cookies in order to deliver advertisements and similar content tailored to users' interests through websites, platforms and applications belonging to our Company or to 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 displayed.
11) REJECTING AND DELETING COOKIES
11.1. Although most browsers allow the use of cookies, users may 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 internet browser's "help" file or by visiting “www.allaboutcookies.org” or “www.youronlinechoices.eu”. However, the method of changing the settings varies depending on the browser used, and you should find out from the service provider of the browser used how cookies can be disabled.
11.2. If cookies are disabled, you can continue to use the website and mobile application, but you may not be able to access all functions of the website and mobile application, or your access may be limited, and as a result it may not be possible to use some features of our Company's website, applications, platform and services.
12) AUTHORIZED SERVICE PROVIDERS
We may obtain assistance from certain service providers that we authorize for the operation and promotion of 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 may collect information for identifying the user's device, such as the IP address, unique identifier and device identifier.
13) THIRD-PARTY SITES, PRODUCTS AND SERVICES
Our Company's website, platform and applications may contain links to websites, products and services belonging to third parties. Such links are subject to the privacy policies of those third parties, and we would like to point out that third parties and third-party sites are independent of our Company and that our Company is not responsible for the privacy practices of third parties. If you visit linked websites, we recommend that you read the privacy policies of those sites.
14) 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. Amendments made by our Company will be notified to those concerned via the website. Accordingly, the current version of the Privacy Policy is available on our Company's website, and any amendments to the Privacy Policy can be followed on our Company's website.
14.2. As a rule, amendments will be made by uploading them to our Company's website and will become effective as of that date; however, our Company may also announce amendments in other ways it deems appropriate.
15) COMMUNICATION AND PERSONAL DATA CONSENT
By accepting this Privacy/Personal Data Protection Policy and Communication Consent, you have consented to the collection, storage, processing and use of the personal data you have agreed to share with our Company, and to their transfer to the third parties with whom our Company has a contractual relationship and whose details are set out above, for the purposes stated in this Privacy Policy (providing and offering various benefits, carrying out all kinds of electronic communications for personalized promotion, sales promotion, advertising, sales, marketing, surveys and similar purposes by telephone, short message (SMS), email and similar means, sending other communication messages, etc.).