As ŞMS KOPUZ GIDA PAZ SAN TİC A.Ş., in accordance with the Personal Data Protection Law No. 6698 (“KVKK”), we, in our capacity as the Data Controller, have prepared this “Information Notice” to inform you, in accordance with Article 10 titled “The Data Controller’s Obligation to Provide Information” and Article 11 titled “Rights of the Data Subject” of the KVKK; We would like to provide you with information regarding the purposes for which your personal data will be processed, to whom and for what purposes your processed personal data may be transferred, the method and legal basis for the collection of your personal data, and your other rights as listed in Article 11 of the Personal Data Protection Law (KVKK):
As the Data Controller, we process, record, transfer, share, and store your personal data as explained below and within the limits prescribed by applicable laws and regulations.
Our company reserves the right to update this “Privacy Notice” at any time in light of changes to applicable laws and regulations.
Our company, which operates in the areas specified in detail in its Articles of Incorporation, collects and processes your personal data—whether verbal, written, or electronic—in connection with these activities, in accordance with the regulations of the Presidency of the Tourism and Revenue Administration and other relevant institutions, as well as the contracts we have entered into.
Your personal data will be used to provide services related to our company’s areas of operation and to improve the quality of these services, to carry out our company’s sales, marketing, and other activities, and to comply with our data retention, reporting, and disclosure obligations.
In addition, your personal data may be used as part of initiatives such as CRM (Customer Relationship Management) applications for sales and marketing activities, as well as to improve the quality of the services we provide to you.
Your personal data will not be used for any purposes other than those specified above without your explicit consent, and will not be shared with or transferred to third parties, except as required by law or to government agencies or institutions.
Our company processes your personal data solely: based on the explicit consent of our customers or in other cases provided for in Article 5(f)(2) of the Personal Data Protection Law (KVKK), as well as in accordance with the legislation to which we are subject, for the purpose of providing our customers with value-added services, opportunities, and benefits, and improving service quality, with our affiliates, directly or indirectly related companies, and joint ventures, both domestically and abroad; with public institutions or organizations authorized to request such data pursuant to a legal obligation; and, provided that adequate safeguards are in place, with institutions, suppliers, authorized dealers/distributors, and business partners, both domestically and abroad, with whom we have contractual relationships in the course of our business operations.
While your personal data may vary depending on the services, products, or commercial activities provided by our Company, it may be collected verbally, in writing, or electronically—whether through automated or non-automated methods—via our offices, branches, dealers, call center, website, social media channels, mobile applications, and similar tools. As long as you use our Company’s products and services, your personal data may be processed by being created and updated.
In addition, with the intention of using our Company’s services:
a. When you use our call center or website,
b. When you visit our Company, our website, or our social media channels,
c. When you participate in training sessions, seminars, or events organized by our Company, your personal data may be processed. Your personal data, obtained with your consent or based on other legal grounds as stipulated by the laws of the Republic of Turkey;
(I) To enable our business units to carry out the necessary work so that you can benefit from the products and services offered by our company;
(II) To customize the products and services offered by our company based on your preferences, usage habits, and needs, and to recommend them to you;
(III) Ensuring the legal and commercial security of our Company and individuals with whom our Company has a business relationship (administrative operations related to communications conducted by our Company; ensuring the physical security and oversight of Company locations; evaluation processes for business partners, customers, and suppliers (including their authorized representatives or employees); legal compliance processes; financial affairs, etc.);
(IV) Improving the quality of the services provided by our Company and developing our quality policy,
(V) To keep you informed about and allow you to benefit from the general and special campaigns, promotions, offers, discounts, and similar benefits offered by our company;
(VI) To process the data collected when you log in with your username and password to access services through the platforms offered by our company—including your personal data, preferences, transactions, and browsing duration on those platforms—in order to provide you with the information and services you have requested;
(VII) To send notifications regarding any loyalty cards issued and/or to be issued by our Company and its affiliated companies/organizations, as well as regarding memberships on the websites of our Company and its affiliated companies/organizations (renewal, expiration, etc.); to establish any form of communication with you; and to inform you about new services and products, as well as any changes, updates, and similar matters in our personal data policies and membership terms;
(VIII) To provide you with information regarding the information, events, and services you request from our company;
(IX) To determine and implement our company’s commercial and business strategies;
(X) To ensure the implementation of our company’s human resources policies; and
(XI) Where expressly provided for in the legislation or where necessary to fulfill a legal obligation established by law, personal data may be processed by our Company and its affiliated companies/entities, as well as by other natural and/or legal persons specified in Section (C) below, in accordance with the conditions and purposes of personal data processing set forth in Articles 5 and 6 of the Personal Data Protection Law.
Your personal data is collected—whether verbally, in writing, or electronically—for the purposes specified in the above provisions, so that we, as a Company, can provide our products and services within the established legal framework and, in this context, fully and accurately fulfill our contractual and legal obligations.
Your personal data collected on this legal basis is processed, recorded, transferred, shared, and stored in accordance with the conditions and purposes of personal data processing set forth in Articles 5 and 6 of the Personal Data Protection Law, for the purposes specified in Section (B) of this document.
Under the Personal Data Protection Law, data regarding an individual’s race, ethnic origin, political views, philosophical beliefs, religion, denomination, or other beliefs; attire; membership in associations, foundations, or labor unions; health; sex life; criminal convictions; and security measures, as well as biometric and genetic data, are considered special-category personal data.
Our company takes adequate measures, as determined by the Personal Data Protection Board, when processing special category personal data. In order to provide better service, our company will process individuals’ special category personal data only with the consent of the data subject and solely for the purpose for which it was collected.
Your collected personal data may be transferred to AAK Turizm Emlak İnş. Tic. Ltd. Şti., as well as to our shareholders, business partners, suppliers, legally authorized public institutions, and private individuals, for the purposes specified in Section (B), in accordance with the conditions and purposes for processing personal data set forth in Articles 8 and 9 of the Personal Data Protection Law.
Our company is authorized to transfer personal data abroad in accordance with the conditions set forth by the Personal Data Protection Board under the Personal Data Protection Law, subject to the other conditions stipulated in the law, and after obtaining the individual’s explicit consent for this purpose.
Under the Personal Data Protection Law, we acknowledge that the data subject has the right to be informed and to give consent prior to the processing, recording, transfer, sharing, and storage of their personal data, and that they have the right to determine the fate of their data after it has been processed, recorded, transferred, shared, and stored.
In this context, if you, as data subjects, submit requests regarding your rights to our Company using the methods set forth below in this “Privacy Notice Regarding the Processing of Personal Data,” our Company will process the request free of charge within thirty days at the latest, depending on the nature of the request.
In accordance with the Communiqué on the Procedures and Principles for Applications to the Data Controller, published by the Personal Data Protection Board, regarding your requests concerning your rights as data subjects:
I. If a written response is provided to your application, no fee will be charged for up to ten pages. A processing fee of 1 Turkish Lira may be charged for each page exceeding ten pages.
II. If the response to the request is provided on a storage medium such as a CD or flash drive, any fee that may be charged by our Company, as the data controller, may not exceed the cost of the storage medium.
In this context, data subjects have the right to:
a. Find out whether their personal data is being processed,
b. Request information regarding the processing of their personal data, if it has been processed,
c. Find out the purpose of the processing of their personal data and whether it is being used in accordance with that purpose,
d. Know the third parties to whom their personal data has been transferred, whether within the country or abroad,
e. To request the correction of personal data if it has been processed incompletely or incorrectly, and to request that the third parties to whom the personal data has been transferred be notified of the action taken in this regard,
f. To request the erasure, destruction, or anonymization of personal data in accordance with the conditions set forth in Article 7 of the Personal Data Protection Law, and to request that the third parties to whom the personal data has been transferred be notified of the action taken in this regard,
g. The right to object to a decision made solely through the automated processing of personal data that adversely affects the individual,
h. The right to request compensation for damages suffered as a result of the unlawful processing of personal data.
However, individuals have no rights regarding anonymized data within the Company. Our Company may share personal data with relevant institutions and organizations as required by business and contractual relationships, or for the purpose of fulfilling a judicial duty or in connection with the exercise of statutory authority by a government authority.
In accordance with the Personal Data Protection Law, your personal data processed for the purposes specified in this “Information Notice Regarding the Processing of Personal Data ” will be deleted, destroyed, or anonymized and continued to be used by us once the purpose requiring their processing under Article 7/f.1 of the Personal Data Protection Law no longer exists and/or the statutory limitation periods for our obligation to process your data have expired.
Pursuant to Article 5 of the KVKK, our Company may process your personal data—as specified above and collected in accordance with the law—without your explicit consent in the following cases: Cases expressly provided for by law;
I. Where, due to actual impossibility, you are unable to express your consent as the data subject, or where your consent is not legally valid, and the processing of your personal data is necessary to protect your own life or physical integrity or that of another person,
II. Where the processing of personal data belonging to the parties to a contract you have entered into with our Company and its affiliated companies/entities, or with other natural and/or legal persons specified in Clause (C), is necessary, provided that such processing is directly related to the conclusion or performance of said contract,
III. Where it is necessary for our Company to fulfill a legal obligation,
IV. Your personal data has been made public by you,
V. Data processing is necessary for the establishment, exercise, or defense of a legal claim,
VI. Data processing is necessary for the legitimate interests of our Company, provided that such processing does not infringe upon your fundamental rights and freedoms.
Pursuant to Article 13, Paragraph 1 of the Personal Data Protection Law, you may submit your request to exercise the rights listed above to our Company using the method(s) determined or to be determined by the Personal Data Protection Board. Alternatively, if you prefer, you may also submit your request to our Company in writing in accordance with the Personal Data Protection Law.
To exercise your rights as set forth in Article 11 of Law No. 6698, you may contact us at any time by sending an email to info@smskopuz.com.tr. You must use only the email address info@smskopuz.com.tr for matters related to your personal data; requests and notifications received through channels other than this address will not be considered.
Rights regarding personal data may only be exercised with respect to an individual’s own data. Requests concerning the data of individuals other than the person who completed the form and attached official identification documents will not be considered. Forms without attached official identification documents will not be considered. Please be advised that even if requests for data deletion are fulfilled, we are obligated to share the data with official authorities if requested to do so by them.
