Corporate General Information Notice on the Processing of Personal Data

CORPORATE GENERAL INFORMATION NOTICE
ON THE PROCESSING OF PERSONAL DATA

As Herca Kuyumculuk İthalat İhracat San. Tic. Ltd. Şti. (“Herca Kuyumculuk”);
within the scope of the Law No. 6698 on the Protection of Personal Data (“KVKK”), related legislation, and legal regulations, we have prepared this information notice in order to inform our Visitors, Online Visitors, Customers, Prospective Customers, Supplier Employees, and Supplier Representatives regarding the processing, storage, and transfer of their personal data.

1) What Categories of Personal Data Do We Process and For What Purposes?

Your personal data may be processed by Herca Kuyumculuk, in accordance with the principles set forth under Article 4.2 of the KVKK, namely:

(i) being in compliance with the law and the principles of good faith,
(ii) being accurate and, where necessary, up to date,
(iii) being processed for specific, explicit, and legitimate purposes,
(iv) being relevant, limited, and proportionate to the purposes for which they are processed,
(v) being retained for the period required by the relevant legislation or for the purpose for which they are processed,

within the scope of our business relationships established and maintained with our business partners (it is possible for one person to fall into more than one category), for the purposes stated below.

A. Our Visitors

The identity information of our visitors (e.g., name, surname) and physical space security information (e.g., camera recordings) shall be processed for the following purposes:

a) creating and tracking visitor records,
b) ensuring physical space security.

B. Our Online Visitors

The transaction security information of our online visitors using our website (e.g., your IP address), marketing information (e.g., shopping history, cookie records), and, if you provide them to us, your identity and contact information (e.g., your email address), shall be processed for the following purposes:

a) carrying out activities in compliance with legislation,
b) carrying out information security processes,
c) following up requests/complaints,
d) conducting communication activities,
e) providing information to authorized persons, institutions, and organizations,
f) enabling your access to our website via the internet.

C. Our Customers

The identity information, contact information, customer transaction information (e.g., order information), physical space security information, financial information (e.g., balance sheet information), legal transaction information, and marketing information (e.g., shopping history) of our real person customers or the representatives and/or employees of our legal entity customers shall be processed for the following purposes:

a) carrying out activities in compliance with legislation,
b) carrying out finance and accounting operations,
c) conducting/supervising business activities,
d) carrying out logistics activities,
e) carrying out after-sales support services for goods/services,
f) carrying out goods/services sales processes,
g) carrying out marketing analysis studies,
h) carrying out contract processes,
i) providing information to authorized persons, institutions, and organizations,
j) ensuring physical space security,
k) resolving legal disputes,
l) carrying out storage and archiving activities,
m) carrying out risk management processes,
n) carrying out processes related to loyalty to the company/products/services,
o) conducting communication activities.

D. Our Prospective Customers

The identity information, contact information, customer transaction information, physical space security information, and marketing information of our real person prospective customers or the representatives and/or employees of our legal entity prospective customers shall be processed for the following purposes:

a) managing goods/services sales processes,
b) carrying out contract processes,
c) ensuring physical space security,
d) carrying out marketing analysis studies.

E. Our Supplier Employees

The identity information, contact information, and physical space security information of our supplier employees shall be processed for the following purposes:

a) conducting communication activities,
b) conducting/supervising business activities,
c) ensuring physical space security,
d) carrying out supply chain management processes,
e) carrying out logistics activities,
f) carrying out activities in compliance with legislation,
g) carrying out occupational health and safety activities.

F. Our Supplier Representatives

The identity information, contact information, physical space security information, customer transaction information, financial information, marketing information, and legal transaction information of our real person suppliers or legal entity supplier representatives shall be processed for the following purposes:

a) conducting/supervising business activities,
b) carrying out goods/services procurement processes,
c) carrying out finance and accounting operations,
d) carrying out contract processes,
e) carrying out investment processes,
f) ensuring physical space security,
g) following up and conducting legal affairs.

2) What Are the Methods of Collecting Your Personal Data?

Your personal data listed above by category are collected through physical means such as order forms, contracts, and visitor forms, as well as through information systems and electronic devices (e.g., telecommunication infrastructure, computers, and phones), third parties (e.g., KKB and Findeks), our website, and other documents declared by the relevant person, by automatic or non-automatic means.

3) What Is the Legal Basis for the Collection of Your Personal Data?

Your personal data are processed by Herca Kuyumculuk, in line with the realization of the purposes explained above, based on the legal grounds specified in Article 5 of the KVKK:

(i) where explicitly provided for by the laws,
(ii) where 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,
(iii) where it is necessary for the data controller to fulfill its legal obligations,
(iv) where processing is necessary for the establishment, exercise, or protection of a right,
(v) where processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

4) Do We Transfer Your Personal Data to Third Parties?

a) Personal data belonging to our visitors may be shared with law enforcement authorities and judicial authorities for the purpose of resolving legal disputes and if requested in accordance with the relevant legislation.

b) Personal data belonging to our online visitors may be shared with judicial authorities and authorized public institutions and organizations for the purpose of resolving legal disputes and if requested in accordance with the relevant legislation.

c) Personal data belonging to our customers may be transferred, within the scope prescribed by legal regulations, to authorized public institutions and organizations for the purposes of carrying out activities in compliance with legislation, following up and conducting legal affairs, and providing information to authorized persons, institutions, and organizations; and, to the extent necessary for the proper performance of our services, to our group companies, IT company, suppliers, cargo companies, insurance companies, banks, and financial advisor for the purposes of conducting/supervising business activities and carrying out risk management processes. In addition, such personal data may be transferred to the law firm from which we receive services and to judicial authorities in order to be used as evidence in potential future legal disputes.

d) Personal data belonging to our prospective customers may be transferred to the law firm from which we receive services and to judicial authorities in order to be used as evidence in potential future legal disputes.

e) Personal data belonging to our supplier employees may be transferred, within the scope prescribed by legal regulations, to authorized public institutions and organizations for the purposes of carrying out activities in compliance with legislation, following up and conducting legal affairs, providing information to authorized persons, institutions, and organizations, and conducting/supervising business activities; and, to the extent necessary for the proper performance of the service, to group companies, the IT company, suppliers, cargo companies, banks, and our financial advisor. In addition, such personal data may be transferred to the law firm from which we receive services and to judicial authorities in order to be used as evidence in potential future legal disputes.

f) Personal data belonging to our supplier representatives may be transferred, within the scope prescribed by legal regulations, to authorized public institutions and organizations for the purposes of carrying out activities in compliance with legislation, following up and conducting legal affairs, providing information to authorized persons, institutions, and organizations, and conducting/supervising business activities; and, to the extent necessary for the proper performance of the service, to group companies, the IT company, suppliers, cargo companies, banks, and our financial advisor. In addition, such personal data may be transferred to the law firm from which we receive services and to judicial authorities in order to be used as evidence in potential future legal disputes.

5) Do We Transfer Your Personal Data Abroad?

As Herca Kuyumculuk, we do not transfer your personal data abroad.

6) How Can You Exercise Your Rights Regarding Your Personal Data?

You may submit your requests within the scope of Article 11 of the KVKK, which regulates the rights of data subjects, to Herca Kuyumculuk İthalat İhracat San. Tic. Ltd. Şti. through the “Data Controller Application Form” prepared to facilitate your application, in accordance with the “Communiqué on the Procedures and Principles of Application to the Data Controller” available at “https://herca.net/”.

Data Controller:
Herca Kuyumculuk İthalat İhracat San. Tic. Ltd. Şti.

Address:
Yenibosna Merkez Mah. Kuyumcukent Sok. No:4/3248
Kuyumcukent 4th Factory Block, 3rd Floor
Bahçelievler / Istanbul

Email:
herman@hercajewellery.com