1 – Introduction
Eximecs İnş. İth. İhr. ve dan. Ltd. Şti. (“Company”) would like to inform you in order to fulfill our disclosure obligation arising from Article 10 of the Personal Data Protection Law No. 6698 (“LPPD”) regarding the personal data we process through the website and/or mobile application where we conduct our commercial activities. Personal data means any information that determines or makes your identity identifiable. Your processed personal data, the purposes for which they are processed, the recipient groups to which they can be transferred, the collection method, the legal reason, and your rights regarding the personal data in question are listed below.
We would like to inform you about your personal data processed if you accept the Membership Agreement and become a “Platform Member” in order to benefit from the services (collectively, the “Platform Services”) offered on our company’s mobile applications and/or websites (collectively, the “Platform”).
2 – What personal data do we process?
If you become a Platform Member, the following personal data is processed.
• Your User Account Information: Your name, surname, customer number, membership e-mail address and, if you add it to your user information, your phone number, gender, date of birth, height and weight information, your Turkish Republic Identity Number (processed in accordance with the relevant legislation only if you purchase certain product groups.)
• Your Customer Transaction Information: Your order and invoice information, your transaction history regarding your purchases, your request and complaint information, your Platform usage information, the information you share in your comments and questions if you comment and/or ask questions regarding the products on the Platform, your score and evaluation information, information regarding the content of conversations made through the chat channel, your cancellation/return information.
• Your Delivery Information: Your phone number and delivery address information you added for the delivery of the product you ordered, your delivery transaction information,
• Your Payment Information: Information regarding your payments and payment methods, your registered card information,
• Your Transaction Security Information: your device information, IP address information, password and passcode information, cookie information, platform access records, your login method (via Google/Facebook),
• Your Legal Transaction Information: Information in correspondence with authorized persons, institutions and organizations, information in lawsuit and enforcement files, information regarding your legal information requests,
• Your Auditory Recording Information: Your voice recording if you contact the call center.
3 – What are the legal reasons, purposes and collection methods for processing your personal data?
Your personal data is collected by our Company through fully or partially automatic means or non-automatic means provided that it is part of any data recording system, electronically through mobile applications or websites where the Platform Service belonging to our Company that you benefit from is available within the scope of our membership agreement; electronically through the channel you contact when you contact us through live help, call center or e-mail channels, and physically when it is sent to our Company via printed forms, notification, mail or notified by legal authorities. The processed personal data, the purposes of processing and legal reasons are given below.
3.1 Membership and Account Creation Process:
Your personal data processed in this category: Your user account information, your customer transaction information, your transaction security information.
Objectives
• Carrying out the processes for the establishment and execution of the membership agreement,
• Managing the creation and closing processes of the platform member profile/account,
• Verification of contact information,
• Carrying out activities to carry out your purchase transactions through the Platform,
• Conducting and auditing the Company’s business activities,
• Ensuring the security of platform operations,
• Fulfilling the obligations arising from the legislation to which our Company is subject, especially the Law on Regulation of Electronic Commerce No. 6563, the Turkish Commercial Code No. 6102, the Turkish Penal Code No. 5237 and the Consumer Protection Law No. 6502,
• Carrying out platform activities in accordance with the legislation,
• Our Company fulfills its data sharing and storage obligations in accordance with our obligations arising from the legislation.
Legal Reasons: It is clearly stated in the laws, It is mandatory for the fulfillment of our Company's legal obligations, It is necessary for the performance of our membership agreement with you.
If you benefit from the Platform Services as a Guest member, your personal data is processed in the same way.
3.2 Order, Delivery and Cancellation/Return Processes:
Your personal data processed in this category: Your user account information, your delivery information, your customer transaction information, your payment information, your transaction security information.
Objectives
• Placing orders and creating orders,
• Establishment and execution of distance sales contracts,
• Carrying out delivery and logistics activities,
• Carrying out cancellation/refund processes,
• Carrying out payment and invoice processes,
• Fulfilling the legal obligations specified in the legislation to which our Company is subject, especially the Regulation on Distance Contracts and the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce, and/or in the decisions, guides and guides published by the competent authorities,
• Carrying out the purchasing processes of product/service groups on the Platform.
Legal Reasons: It is mandatory for the fulfillment of our company's legal obligations, It is necessary for the performance of our membership agreement with you.
3.3 Customer Experience Improvement Processes:
Your personal data processed in this category: Your user account information, your customer transaction information, your delivery information, your transaction security information, your legal transaction information, your audio recording information.
Objectives
• Ensuring that you can quickly and easily access products that suit your preferences and interests,
• Providing a better user experience in service transitions between our Company's Platform Services,
• Developing and improving our user experience,
• Improving our service quality,
• Conducting analysis and reporting studies,
• Carrying out communication activities,
• Evaluating requests, complaints and suggestions regarding our products and services,
• Carrying out after-sales support services for goods and services.
Legal Reasons: It is necessary for the performance of our membership agreement with you, and data processing is mandatory for the legitimate interests of our Company.
3.4 The Company's Information Security, Risk, Audit and Control Processes:
Your personal data processed in this category: Your user account information, your customer transaction information, your delivery information, your payment information, your transaction security information.
Objectives
• Execution and auditing of finance and accounting processes,
• Carrying out billing processes,
• Carrying out information security processes and investigating suspicious transactions,
• Ensuring the security of operations regarding the Platform,
• Control, development and improvement of the quality of the products and services offered by our company,
• Conducting risk identification and analysis, complaint management,
• Preventing fraud,
• Carrying out legal and financial due diligence activities for our Company in possible mergers, acquisitions, joint ventures, divisions and other structural changes.
Legal Reasons: It is necessary for the performance of our membership agreement with you, and data processing is mandatory for the legitimate interests of our Company.
3.5 Process of Carrying Out Legal Procedures:
Your personal data processed in this category: Your user account information, your customer transaction information, your delivery information, your payment information, your transaction security information, your legal transaction information, your audio recording information.
Objectives
• Carrying out legal and litigation matters, responding to your legal requests, examining and responding to your applications in accordance with the procedure as a relevant person,
• Carrying out activities in accordance with the legislation and fulfilling the obligations arising from the legislation to which our Company is subject,
• Carrying out legal consultancy processes,
• Sharing information with authorized persons, institutions and organizations upon request,
• Exercise and protect a right in case of a legal dispute.
Legal Reasons: Data processing is mandatory for the establishment, exercise or protection of a right, or it is mandatory for our Company to fulfill its legal obligations.
3.6 Processes Conducted Based on Explicit Consent:
Your personal data processed in this category: Your user account information, your customer transaction information, your delivery information, your payment information.
Objectives
• Carrying out marketing, advertising and promotion activities,
• Conducting financial proposal processes,
• To present you with special advantageous offers, to carry out activities to increase your satisfaction by getting to know you better, and to send commercial electronic messages within this scope.
Legal Reason: Your explicit consent.
We would like to emphasize that if you wish to withdraw your consent, you can submit your request to the Company using the methods listed under the heading “7-Communication for Your Rights and Requests”.
4 – To whom and for what reasons does the company transfer your personal data?
Our company takes care to process your personal data in accordance with the “need to know” and “need to use” principles, by ensuring the necessary data minimization and by taking the necessary technical and administrative security measures.
Our Company shares your personal data domestically with the recipient groups specified in detail below, based on the legal grounds that “it is clearly prescribed by law, it is mandatory for our Company to fulfill its legal obligations, it is necessary for the establishment or execution of a contract, data processing is mandatory for the establishment, exercise or protection of a right and/or it is mandatory for the legitimate interests of our Company” in accordance with Article 8 of the KVKK.
In cases where your personal data is transferred abroad by our company, it is shared with the recipient groups specified in detail below, based on the legal reasons of “Provision of appropriate security with a standard contract or, provided that it is incidental, the existence of one of the situations regulated in paragraph 6 of article 9 of the KVKK” regulated in Article 9 of the KVKK and the Regulation on the Procedures and Principles Regarding the Transfer of Personal Data Abroad.
Legal Reason: Necessary for the establishment or performance of the contract, Providing appropriate security with a standard contract.
4.2. Order, Delivery and Cancellation/Return Processes:
• With the seller or service provider of the product you wish to purchase, in order to ensure that you benefit from the Platform Services, to carry out the purchasing and billing processes, and to fulfill the obligations arising from the legislation to which our Company and the seller from whom you purchased the product are subject,
• With product sellers, cargo companies, private couriers to carry out logistics activities and follow up delivery processes,
• With banks and other payment institutions that we have agreements with for the execution and monitoring of your payment processes,
• Our business partners from whom we receive bulk SMS/e-mail services to inform you about issues such as the delivery of the product you purchased,
• Yurt dışından ürün sipariş vermeniz halinde, sipariş teslimat ve iade süreçlerinin yürütülmesi, lojistik ve tedarik zinciri süreçlerinin yürütülmesi, gümrük süreçlerinin yürütülmesi, Platform operasyonlarının yürütülmesi amaçlarıyla yurt dışında yerleşik kargo ve lojistik şirketleri, satın aldığınız ürünün satıcısıyla ve gümrük danışmanlık şirketleriyle,
shared.
Legal reason: Fulfillment of our company’s legal obligations, Being necessary for the establishment or execution of the contract, Providing appropriate security with a standard contract.
4.3. Customer Experience Improvement Processes:
• Our business partners who provide call center services and service providers who provide customer support services for the purpose of providing sales and after-sales support services for goods and services, ensuring customer satisfaction, and meeting demands and complaints.
• It is shared with our affiliates, group companies, business partners and consultants that provide IT infrastructure, software and technology services, service providers located abroad, in order to provide Platform services and to carry out Platform operations, in order to carry out activities aimed at developing and improving the products and services offered by our company.
Legal reason: Necessity for the establishment or performance of the contract, Provision of appropriate security with a standard contract, Existence of one of the situations regulated in Article 9, Subparagraph 6 of the KVKK, provided that it is incidental.
4.4. The company's information security, risk, audit and control processes:
• Our business partners, consultants and service providers, banks, e-invoice business partners, cargo and courier companies, special integrators, independent auditing, customs, financial advisor/accounting service providers for the purposes of carrying out the billing processes, sending the e-invoice to the customer electronically, making physical contract or invoice delivery, managing financial and accounting processes, identifying and evaluating risks, and preventing fraud.
• With our business partners who provide independent auditing, customs, financial advisory/accounting services, our community companies, affiliates, group companies, special integrators, technology companies, business partners and service providers for the purposes of ensuring the security of company operations, controlling and improving the quality of products and services offered by our company and performing risk detection and analysis.
• In order to carry out the legal and financial due diligence activities of our Company in possible mergers, acquisitions, joint ventures, divisions and other structural changes, it is shared with potential buyers, sellers or other parties involved in the transaction and their employees, consultants and database service providers who are under a confidentiality obligation and who are involved in the relevant process.
Legal reasons: It is necessary for the fulfillment of our company's legal obligations, the establishment or execution of the Agreement, and the legitimate interests of our company.
4.5. Process of Carrying Out Legal Procedures:
• With regulatory and supervisory authorities, authorized public institutions and organizations such as courts and enforcement offices, mediators, in order to fulfill the obligations arising from the legislation to which our company is subject and to carry out the Platform activities in accordance with the legislation, to inform authorized persons, institutions and organizations, to follow up and carry out legal affairs, and to exercise and protect a right in case of a legal dispute.
• With lawyers, auditors, tax consultants, forensic computer experts, cyber security consultants, tax consultants, our group companies, our affiliates, other third parties and business partners from whom we receive consultancy and service, for the purposes of conducting our company's audit activities, conducting legal consultancy processes, ensuring the security of company operations, and conducting investigations into suspicious transactions.
• It is shared with authorized public institutions and organizations upon request in order to provide information to authorized persons, institutions and organizations abroad and to exercise and protect a right in case of a legal dispute.
Legal reasons: Being clearly prescribed by law, Fulfillment of our Company’s legal obligations, Processing to establish, exercise or protect a right, Being necessary for the establishment or performance of a contract, Existence of one of the situations regulated in Article 9, Subparagraph 6 of the KVKK, provided that it is incidental.
4.6. Processes Conducted Based on Explicit Consent:
• It is shared with affiliates, group companies, service providers and business partners for the purposes of carrying out marketing, advertising and promotional activities, presenting you with special advantageous offers, and carrying out activities to increase your satisfaction by getting to know you better.
Legal Reason: Your explicit consent.
5 – How Does the Company Protect Your Personal Data?
Personal data shared with our Company is under the supervision and control of the Company. The Company has assumed responsibility as the data controller to establish the necessary organization and to take and adapt technical measures in order to protect the confidentiality and integrity of information in accordance with the relevant legislation in force. Being aware of our obligation in this regard;
• Risk analyses regarding personal data processing activities are regularly conducted and actions are taken to reduce risks.
• Access and authorization controls are implemented to prevent unauthorized access to personal data.
• Data processing policies are updated at regular intervals.
6 – Your Rights Regarding the Protection of Your Personal Data
By applying to our Company using the methods in the “Communication for Your Rights and Requests” section of this information text,
• Learning whether your personal data is being processed,
• Requesting information about your personal data if it has been processed,
• Learning the purpose of processing your personal data and whether they are used in accordance with their purpose,
• Knowing the third parties to whom the data is transferred, either domestically or abroad,
• Request correction of personal data if it is processed incompletely or incorrectly,
• Request the deletion or destruction of your personal data within the framework of the conditions stipulated in the KVKK,
• Request that the actions taken in accordance with your rights of correction, deletion and destruction specified above be notified to third parties to whom personal data has been transferred,
• To object to a result that is to your detriment as a result of your processed personal data being analyzed exclusively by automated systems,
• You have the right to demand compensation for your damages if you suffer damages due to your personal data being processed in violation of the relevant legislation.
7 – Contact Us for Your Rights and Requests
You can submit your questions and requests regarding your personal data by submitting a petition prepared in accordance with the conditions specified in the Communiqué on the Procedures and Principles of Application to the Data Controller, using the following methods.
| Application Method | Address to Apply |
| Written Application in Person** | Söğütözü Mah. Söğütözü Cad. No. 2-A, İç Kapı No: 13, Çankaya / Ankara |
| Notary | Söğütözü Mah. Söğütözü Cad. No. 2-A, İç Kapı No: 13, Çankaya / Ankara |
| From your e-mail address previously notified to our company and registered in the system. | mailto:info@northcure.com |
*We kindly request that you write “Personal Data Protection Law Related Person Request” in the notification envelope of the application form or in the subject section of the e-mail.
As personal data owners, if you submit your requests regarding your rights to the Company, the Company will finalize your request free of charge within 30 (thirty) days at the latest. However, if the response to your application requires a cost in accordance with the legislation, the Company may charge a fee in the tariff determined by the Personal Data Protection Board.
8 – About the Information Text
The Company reserves the right to update this Information Text on the Protection of Personal Data at any time, within the framework of any changes that may be made to the current legislation.