GDPR Clarification Text
Last updated: 18 July 2022
As Tenflex Teknoloji Çözümleri A.Ş. ("Tenflex" or the "Company"), we attach importance to and take due care in protecting the privacy and security of your personal data. Accordingly, pursuant to Article 10 of the Turkish Law No. 6698 on the Protection of Personal Data (the "Law"), published in the Official Gazette dated 7 April 2016 and numbered 29677, titled "Obligation of the Data Controller to Inform", and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform, published in the Official Gazette dated 10 March 2018 and numbered 30356, this Notice aims to inform you about the personal data processed by the Company.
a) Identity of the Data Controller
Tenflex has the status of "Data Controller" within the scope of the Law and the relevant legislation, and you may contact us through the communication details provided below.
Address: Yenikoy Merkez Mah. Vatan Cad. Teknopark No: 83 Ic Kapi No: B39 Basiskele / Kocaeli
Email: bilgi@tenflex.net
b) Personal Data Processed
Within the scope of your relationship with Tenflex, the following personal data may be processed:
- Identity Data: First name, last name
- Contact Data: Email address, phone number, address information
- Location Data: Location information of the place where you are present
- Transaction Security Data: IP address information, website login and logout information, log records, username and password information
- Financial Data: Bank account information
- Marketing Data: Request history information, cookie records
c) Purposes of Processing Personal Data and Legal Grounds
Your personal data obtained within the scope of your relationship with Tenflex is processed for the purposes listed below based on the legal grounds set out in Article 5 of the Law:
- Within the scope of your membership relationship, your identity data, contact data, location data, transaction data, transaction security data, financial data, marketing data and customer service voice recordings are processed by Tenflex on the legal grounds that "processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract", "it is mandatory for the data controller to fulfill its legal obligation", and "it is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject", and are retained for the periods prescribed by the legislation for the following purposes:
- Carrying out activities in compliance with legislation
- Carrying out finance and accounting affairs
- Carrying out communication activities
- Carrying out / auditing business activities
- Carrying out after-sales support services for goods / services
- Carrying out sales processes for goods / services
- Carrying out production and operational processes for goods / services
- Carrying out customer relationship management processes
- Carrying out contract processes
- Carrying out marketing processes for products / services
- Within the scope of your membership relationship, your identity data, contact data, location data, carrier transaction data, transaction security data, financial data, cookie records and customer service voice recordings are processed by Tenflex on the legal grounds that "processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract", "it is mandatory for the data controller to fulfill its legal obligation", and "it is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject", and are retained for the periods prescribed by the legislation for the following purposes:
- Carrying out activities in compliance with legislation
- Carrying out finance and accounting affairs
- Carrying out communication activities
- Carrying out / auditing business activities
- Carrying out after-sales support services for goods / services
- Carrying out sales processes for goods / services
- Carrying out production and operational processes for goods / services
- Carrying out customer relationship management processes
- Carrying out contract processes
- Carrying out marketing processes for products / services
- If you use the Tenflex website and applications without becoming a member, your IP address information, website login and logout information, log records and cookie records are processed by Tenflex on the legal grounds that "it is expressly provided for by law", "it is mandatory for the data controller to fulfill its legal obligation", and "it is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject", for the purposes of ensuring transaction security and carrying out activities in compliance with legislation, and are retained for 2 years as required by legislation.
d) Transfer of Personal Data
Within the scope of your membership relationship, your identity data, contact data, location data and request data will be transferred for the purpose of carrying out the requested transaction, based on the legal ground that "processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract".
Within the scope of your membership relationship, your identity data and financial data will be transferred to business partner payment service providers for the purpose of carrying out the payment related to the requested transaction, based on the legal ground that "processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract".
Your personal data may be shared, in accordance with the provisions of the Law on the transfer of personal data, for the legal grounds and purposes stated above, with authorized public institutions and organizations, courts and enforcement offices, suppliers and other business partners providing services such as information technology support and security services, the Company's shareholders, our group companies and affiliates.
Your processed personal data may be transferred abroad in accordance with Article 9 of the Law.
e) Methods of Collecting Personal Data
Tenflex collects your personal data, primarily through registration and update actions carried out via the Tenflex website and applications, as well as from you and the relevant business partners during the establishment of your relationship with the Company and throughout the continuation of that relationship, through internet, telephone, email, and physical, written, verbal and electronic channels, to be processed for the purposes stated above.
f) Rights of the Data Subject
Pursuant to Article 11 of the Law regulating the rights of the relevant person, by applying to us you have the right to:
- Learn whether your personal data is being processed
- Request information if your personal data has been processed
- Learn the purpose of processing and whether it is used in accordance with that purpose
- Know the third parties to whom it is transferred domestically or abroad
- Request correction if it has been processed incompletely or inaccurately
- Request its deletion or destruction within the conditions set out in the Law
- Request notification of correction, deletion or destruction transactions to third parties to whom it has been transferred
- Object to a result that is to your detriment arising from analysis exclusively by automated systems
- Request compensation if you suffer damage due to unlawful processing
g) Application to the Data Controller
You may submit your requests regarding your rights under the Law, within the framework of the Communiqué on the Procedures and Principles of Application to the Data Controller, in writing to the address above by proving your identity in person or through a notary public. You may also send them to bilgi@tenflex.net by using a secure electronic signature, mobile signature, or the email address that you have previously notified to Tenflex and that is registered in our system.
Applications made within this scope will be accepted following the identity verification to be carried out by us, and your requests will be concluded as soon as possible and within 30 days at the latest, depending on the nature of the request, in accordance with the Law.
h) Changes
Tenflex may update this Notice on the Processing of Personal Data at any time in the event of any change in its processes. You may access the latest updated version of the Notice on the Processing of Personal Data at www.tenflex.net/en/pages/kvkk.html.