PRIVACY NOTICE FOR NATURAL PERSONS AND COMPANY OFFICIALS OR EMPLOYEES WHO ARE REGISTERED AS MEMBERS


Purpose and Scope of the Privacy Notice

As SWATCHLOOP, we take measures to protect your personal data within the scope of the Law No. 6698 on the Turkish Protection of Personal Data (referred to as KVKK or Law). We process your Personal Data within the scope of KVKK and relevant legislation and in our capacity as "data controller" for the reasons and methods described below.

SWATCHLOOP Privacy Notice on the Processing of Personal Data has been prepared in accordance with the article titled "Obligation of the Data Controller to Inform" in Article 10 of the KVKK; in order to inform you in the most transparent way about the identity of the data controller, the method and legal reason for collecting your personal data, the purpose for which this data will be processed, to whom and for what purpose it can be transferred, the data processing period and your rights listed in Article 11 of the KVKK. This disclosure text concerns third parties using our company website.

Data Controller

Company Title: Swatchloop Teknoloji Ve Yazılım Anonim Şirketi ("SWATCHLOOP")

Address Adatepe Mah. Doğuş Cad. No: 207z Interior Door No: 1 Buca / İZMİR

(hereinafter referred to as "Company" within the scope of this Privacy Notice)


Method and Legal Reason for Collecting Your Personal Data

Your personal data may be collected verbally, in writing or electronically by automatic or non-automatic methods, the Company's affiliated units, website, social media channels, call center, mobile applications and similar means. Your personal data may be processed by creating and updating as long as your relationship with the Company continues and may be kept in both digital and physical environment.

Your personal data may be processed and transferred in line with the purposes set out in the heading "Your Personal Data Processed and Purposes of Processing" and within the scope of the personal data processing conditions and purposes specified in subparagraphs "a, c, ç, e and f" in accordance with paragraph 1 of Article 5 of Law No. 6698 or paragraph 2 of Article 5.


Your Processed Personal Data and Purposes of Processing

Your Personal Data is processed securely in accordance with the Law on the Protection of Personal Data in accordance with legal obligations or in order to provide a more appropriate service in company business and transactions.

In this context, the following data are collected as personal data:

Contact Data: Data group that can be used to reach the person (telephone, residential address, e-mail)

Identity Data: Data group containing information about the identity of the person (Name, surname, gender)

Legal Action Data: This data category refers to data types such as information contained in correspondence with judicial authorities and consumer arbitration committees, information in the case file.

Transaction Security Data: It is the data group containing digital traces resulting from the processing of personal information (IP address information, website login and exit information, cookie information).

Marketing Data: It is a group of data used for marketing and sales purposes, including digital traces resulting from the processing of personal information (IP address information, website browsing information, cookie information for marketing,)


Your personal data collected;

• The necessary work can be carried out by our relevant business units in order for real and / or legal third parties, institutions and organizations (employees, visitors, suppliers, business partners, etc.) who have a relationship with the company to benefit from the products and services of our company and / or centers and units affiliated to our company,

• Ensuring the security of life and property and legal and commercial security of real and/or legal third party institutions and organizations in the headquarters and units where the company's business is carried out or affiliated to the company,

• Turkish Commercial Code No. 6102, Turkish Code of Obligations No. 6098, Consumer Protection Law No. 6502, Personal Data Protection Law No. 6698, Tax Procedure Law No. 213, Law No. 6563 on the Regulation of Electronic Commerce, Regulation on Commercial Communication and Commercial Electronic Messages, Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed through These Publications, the Law on Consumer Protection, the Regulation on Archival Services and all related laws and secondary regulations, to fulfill the legal and regulatory requirements that arise / may arise and to take the necessary measures in this context,

• Carrying out auditing and/or regulatory duties to be carried out by the authorized and authorized public institutions and organizations and professional organizations in the nature of public institutions,

• Fulfillment of information and document requests by judicial bodies, consumer arbitration committees and/or administrative authorities,

• To carry out listing, reporting, verification and analysis studies on the usage patterns of the products and services offered in our company and all centers and units affiliated to the company, to produce statistical and scientific information in this regard, to improve our products and services accordingly, to increase satisfaction with our products and services and to make customizations regarding the user in this context,

• To be able to conduct market research, promotion and necessary information regarding our products and services, to evaluate complaints and suggestions and to contact you directly through the communication channels shared with the Company,

• Planning and management of the financing and invoicing of all services provided,

• Taking all necessary technical and administrative measures for systems and applications within the scope of data security

purposes, within the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.


To Whom and For What Purpose Your Processed Personal Data Can Be Transferred

By ensuring that all necessary technical and administrative measures are taken to ensure the appropriate level of security in accordance with the KVKK and the relevant legislation, only when necessary, in line with the above-mentioned purposes of your Personal Data / Personal Data;


• Persons/institutions and/or organizations permitted by other relevant legislation provisions,

• Private insurance companies and banks,

• Lawyers or law partnerships for the follow-up of their legal affairs,

• Financial advisors for the purpose of conducting financial and accounting transactions,

• Our direct and indirect domestic shareholders,

• Our subsidiaries, affiliates and company branches,

• Consultants

• Business partners,

• Domestic/international organizations from which we contractually receive services and/or provide services and cooperate in order to carry out our activities


According to Article 8 of the KVK Law, in the presence of one of the conditions specified in the second paragraph of Article 5 of the KVKK and within the framework of the personal data processing conditions and purposes specified in Article 9 of the KVKK, it can be transferred by providing the explicit consent condition.


Data Processing Period and Storage Period

Your personal data, limited to the purposes specified in this Privacy Notice; It will be processed by complying with the data processing and statute of limitations periods in all relevant laws and other legal legislation to which our Company and the centers and units affiliated to our Company are subject. In case of changes in the laws regarding data processing periods, the new periods determined will be taken as basis.

As a requirement of the principle of purpose limitation, your personal data is processed limited to the fulfillment of the purposes described in this Privacy Notice and in any case, limited to the period required to be processed in accordance with the legal periods, company practices and customs of commercial life, and after the expiration of the periods, it is deleted, destroyed or anonymized. If you want to get detailed information about the storage periods of your personal data, you can contact us via the addresses in the rights section of the relevant person.


Rights of the person concerned 

As a data subject, you have the rights regulated under Article 11 of Law No. 6698 regulating the rights of the data subject. In accordance with the "Communiqué on the Procedures and Principles of Application to the Data Controller", you may submit your requests in writing to Adatepe Mah. Doğuş Cad. No: 207z Interior Door No: 1 Buca / İZMİR Turkey in writing to the address or [email protected] -posta address will be able to use the rights listed by transmitting electronically.