REGARDING THE PROCESSING OF PERSONAL DATA CORPORATE GENERAL DISCLOSURE TEXT

“Elit Elektronik Pazarlama San. ve Tic. Ltd. Sti.” has been prepared to inform you with this clarification text, our Online Visitors, our Customers, our Potential Customers, our Supplier employees and our Supplier Authorities as Dear guests regarding the processing, storage and transfer of your data within the framework of the Personal Data Protection Law No. 6698 ("KVKK") and the activities arising from the relevant legislation and legal regulations. 

1) What Are Your Categories of Personal Data We Process, and For What Purposes Do We Process Them?

Your personal information is stored in Elit Elektronik Pazarlama San. ve Tic. Ltd. Sti. as stipulated in Article 4.2 of the KVKK;

(i) Complying with the law and good faith,

(ii) Being accurate and, where necessary, up-to-date;

(iii) Processing for specific, explicit and legitimate purposes,

(iv) be relevant, limited and proportionate to the purpose for which they are processed,

(v) Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed; under its principles, it is also possible that a person may fall into more than one category within the scope of our established and ongoing business relations with our business partners and may be processed for the purposes set out below.

A. Our Visitors

Our visitors' physical location security information (e.g., camera recordings);

a)      It will be processed to ensure the security of the physical space.

B. Our Online Visitors

Transaction security information (e.g. your IP address information), marketing information (e.g. purchase history information, cookie records) and (if you tell us about them*) identification information, contact information (e.g. your e-mail address) of our online visitors who use our website;

a) Carrying out the activities under the legislation,

b) Execution of information security processes,

c) Follow-up of requests/complaints,

d) Carrying out communication activities,

e) Providing information to authorised persons, institutions and organisations,

f) to enable you to access our website via the Internet.

C. Our Customers

Identification information, contact information, customer transaction information (e.g., order information), physical location security information, financial information (e.g., balance sheet information), legal transaction information, marketing information (e.g., purchase history information), of our natural person customers or officers and/or employees of our legal entity customers;

a) Carrying out the activities under the legislation,

b) Execution of financial and accounting affairs,

c) Conduct/supervision of business activities,

d) Carrying out logistics activities,

e) Carrying out after-sales support services for goods/services,

f) Execution of goods/services sales processes,

g) Conducting marketing analysis studies,

h) Execution of contract processes,

i) Providing information to authorized persons, institutions and organizations,

j) Ensuring the security of physical spaces,

k) Settlement of legal disputes,

l) Carrying out storage and archive activities,

m) Carrying out risk management processes,

n) Execution of advertising/campaign/promotion processes,

o) Carrying out the processes of loyalty to the company/product/services,

p) will be processed to carry out communication activities.

D. Our Potential Customers

Identity information, contact information, customer transaction information, physical location security information, marketing information of our natural person customers or legal entity customers' officers and/or employees;

a) Managing the sales processes of goods/services,

b) Execution of contract processes,

c) Ensuring the security of the physical space,

d) Execution of advertising/campaign/promotion processes,

e) will be processed to conduct marketing analysis studies 

E. Our Supplier Employee

Identity information, contact information, physical location security information of our supplier employee, 

a) Carrying out communication activities,

b) Conduct/supervision of business activities,

c) Ensuring the security of the physical space,

d) Execution of supply chain management processes,

e) Carrying out logistics activities,

f) Carrying out the activities under the legislation,

g) will be processed to carry out occupational health/safety activities.

F. Our Supplier Officer

Identity information, contact information, physical location security information, customer transaction information, financial information, marketing information, legal transaction information of our natural person suppliers or legal entity supplier officials;

a) Conduct/supervision of business activities,

b) Carrying out the procurement processes of goods/services,

c) Execution of financial and accounting affairs,

d) Execution of contract processes,

e) Execution of investment processes,

f) Ensuring the security of the physical space,

g) It will be processed to follow up and carry out legal affairs.

2) What are the Methods of Collecting Your Data?

Your data specified in the categories above is collected by automated or non-automated means through physical means such as order forms, contracts, visitor forms or through information systems and electronic devices (e.g. telecommunications infrastructure, computers and telephones), third parties (e.g. KKB and Findeks), our website and other documents declared by the person concerned.

3) What is the Legal Reason for Collecting Your Data?

Elit Elektronik Pazarlama San ve Tic. Ltd. Şti. will process your data in line with the realisation of the purposes described above, which is specified in Article 5 of the KVKK;

(i) It is explicitly stipulated in the laws,

(ii) Provided that it is directly related to the conclusion or performance of a contract, it is necessary to process the personal data of the parties to the agreement,

(iii) It is mandatory for the data controller to fulfil its legal obligation,

(iv) Data processing is mandatory for the establishment, exercise or protection of a right,

(v) Provided that it does not harm the fundamental rights and freedoms of the data subject, it is processed based on the legal grounds that the data processing is mandatory for the data controller's legitimate interests.

When the data processing activity cannot be based on one of the above legal reasons, your data is processed based on your explicit consent.

4) Do We Transfer Your Data To A Third Party?

a) Our visitors' data may be shared with law enforcement agencies and judicial authorities to resolve legal disputes under the relevant legislation upon request.

b) The personal data of our online visitors may be shared with judicial authorities and authorised public institutions and organisations to resolve legal disputes upon request under the relevant legislation.

c) The personal data of our customers are sent to authorised public institutions and organisations to carry out the activities under the legislation, following and conducting the legal affairs, providing information to the authorised persons, institutions and organisations within the scope stipulated by the legal regulations; business activities are carried out/audited, risk management processes are carried out and transferred to our group companies, suppliers, cargo companies, insurance companies, banks and our financial advisors to the extent necessary for the proper performance of our services. In addition, Elit Elektronik Pazarlama San. ve Tic. Ltd. Sti. may transfer these personal data to the law office and judicial authorities we receive services from to be used as evidence in future legal disputes.

d) The personal data of our potential customers may be transferred to the law office and judicial authorities from which we receive services to be used as evidence in legal disputes that may arise in the future.

e) The personal data of our supplier employee shall be transferred to the authorised public institutions and organisations to carry out the activities under the legislation, follow up and conduct the legal affairs, provide information to the authorised persons, institutions and organisations, and conduct / auditing the business activities within the scope stipulated by the legal regulation; It is transferred to the group companies, suppliers, cargo companies, banks and our financial advisor to the extent necessary for the service to be appropriately performed. In addition, these personal data may be transferred to the law office and judicial authorities that we receive services from to be used as evidence in future legal disputes.

f) The personal data of our supplier authority shall be transferred to the authorised public institutions and organisations to carry out the activities under the legislation, follow up and conduct the legal affairs, provide information to the authorised persons, institutions and organisations, and conduct/auditing the business activities within the scope stipulated by the legal regulations; It is transferred to the group companies, suppliers, cargo companies, banks and our financial advisor to the extent necessary for the service to be appropriately performed. In addition, these personal data may be transferred to the law office and judicial authorities that we receive services from to be used as evidence in future legal disputes.

5) How Can You Exercise Your Rights Regarding Your Data?

Your requests within the scope of Article 11 of the KVKK, which regulates the rights of the relevant persons, are submitted to "Elit Elektronik Pazarlama San. ve Tic. Ltd. Sti." Under the "Communiqué on the Procedures and Principles of Application to the Data Controller" at the "elit@elitweb.com" address, you can forward it to us through the "Application Form to the Data Controller" prepared for your convenience.

Data Controller: Hüseyin Hüsnü Dernek

Address: İkitelli Organize San. Böl. Mutsan San. Sit. M-10 Blok No: 31 34490 Başakşehir / İstanbul - TURKEY

E-mail: elit@elitweb.com