LPPD clarification

According to the Law on Protection of Personal Data no 6698 (“LPPD”), our company URLA GROUP LIMITED COMPANY (“Istanbul Office Address: Pinartepe Mh. Gurgen Sk. 3B, Pinar Kent Villaları A Blok, Buyukcekmece, Istanbul”) is the Data Controller. As URLA GROUP LTD , we give importance to the confidentiality and security of your personal data. In the context, numbered 6698 In order to fulfill our disclosure obligation arising from Article 10 of the Law on the Protection of Personal Data (“Law No. 6698”), we make the following explanations to the attention of our valued customers and 3rd Parties / Visitors who use our website.

In the Clarification Text, you will be informed in the clearest way about the identity of the data controller, the ways in which personal data is collected, the data collection purposes and procedures of processing, the cause of action for the collection of data, to whom and for what purpose personal data can be transferred, and the data owners’ rights.
The Clarification Text is valid suppliers, employee candidates, former employees, subcontractor,subcontractor employees or corporate customer representatives and to those who apply for a job at URLA GROUP, those who want to be informed about URLA GROUP products and services, real persons, customers and prospects who call the website and URLA GROUP to make requests, suggestions and complaints about products and services.

1. What are the Lawful Bases for Collecting Your Personal Data?

“LPPD” has entered into force for protecting the data of individuals in a legal way, which are inconvenient to be seized by third parties in order to ensure the privacy of their private life. Our company is subject to this law, and all data processed in all business processes are evaluated within this scope and considered as personal data and are protected as per the law. Our company is attentive to take all necessary technical and administrative measures in order to prevent unlawful access to and preserve personal data collected within the framework of the principle of respect for privacy and fundamental rights and freedoms, in accordance with the “LPPD” and the secondary regulations under the law. .
Your collected personal data is in accordance with the “LPPD”;

• It is clearly stipulated in the laws (art.5/2.a)
• It is necessary to process the personal data of the parties of the agreement, provided that it is directly related to the establishment or performance of a contract (art.5/2.c) 
• In order for the data controller to fulfill its statutory obligation that is mandatory ( art. 5/2.c)
• Data processing is mandatory for the establishment, exercise or protection of a right (art. 5/2.d)
• Data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject. Communication, membership and similar online forms on the websites of the Company (article 5/2.f) , your information containing feedback and similar content that you have added with your own consent, in addition to the information required for the said forms, the information you share through our call centers, by natural or legal persons authorized by the Company, who process data, by e – mail, telephone, website, various contract Documents can be processed verbally, in writing or electronically, by automatic or non-automatic methods, by means such as forms and minutes kept in paper media. 

2. The Purpose of Processing Your Personal Data

Your personal data may be processed by URLA GROUP. Company may also record, store, update, disclose, transfer, classify your personal information to third parties in cases and to the extent permitted by the legislation and in accordance with the provisions of the “LPPD” 5/2.a, 5/2.c, 5/2.ç, 5/2. .d, 5/2.f and 6, within the scope of the personal data processing conditions, will be able to process for the following purposes; Data to be shared by visitors/users who use/access URLA GROUP’s website during this use/access and that can be processed by us; 

• Cable Request Form (Name-Surname, Phone, Email, Location, Message)
• Contact Form (Name-Surname, Phone, Email, Location, Message)
• Newsletter Membership  
• Job Application Form (Name-Surname , Phone, Email, Message, CV Document) The purposes of processing and using your personal data are as follows;
• To carry out commercial relations, to determine and implement commercial and business strategies, 
• To confirm the identity information of the transacter, 
• To record the address and other necessary information for communication, to be able to communicate with data owners,
•  From contracts, distance sales contract and Consumer Protection Law ‘s to perform undertaken obligations in accordance with all agreements on which we conclude under the relevant substances, 
• Electronic (internet / mobile, etc.) or be the mainstay of treatment in the paper medium to organize all records and documents, 
• Product / service to offer proposals, product sales, marketing and information activities To construct and perform, to carry out all kinds of information, advertisement – promotion, promotion, sales and marketing activities, to prepare orders, to deliver and to carry out the necessary processes, to carry out special advertisement, campaign and other promotional sales and marketing activities for customer profiles in case of explicit consent. irmak customer based upon the data obtained “classification” to do their work, surveys, applications, data, and statistical and to make risk analysis, internal audit, reporting, conduct market research and profiling studies, newsletters and send invitations,
• Customer complaints and dealing with our products and services To evaluate the proposals, to increase the service quality,
• To evaluate job applications and to manage human resources processes and employment policies in this context, 
• To ensure the physical safety and control of the workplaces and factories of URLA GROUP, 
• To be able to fulfill our obligations arising from KVKK and to use our rights arising from the legislation and to be able to carry out the activities performed by the company in accordance with the relevant legislation and Company policies,
• To provide better service to our users on our website and to improve our services,

3. Is Your Personal Data Transferred to Third Parties?
The sharing of your personal data with third parties takes place within the framework of the express consent of the personal data owners and as a rule, personal data is not transferred to third parties without the consent of the personal data owners. Your personal data, due to and limited to our legal obligations, with the program partner institutions and organizations we cooperate with in order to carry out the activities of the courts and other public institutions and URLA GROUP and/or its subsidiaries, affiliates, joint ventures and all their branches and offices, and to provide you with a better service. In order to provide services and ensure customer satisfaction, it can be shared with the companies we work with within the scope of various marketing activities, with other domestic/foreign third parties and related business partners, in line with your express consent or in accordance with the provisions of the legislation.
Your collected personal data, in accordance with the terms of the transfer of personal data specified in Articles 8 and 9 of the “LPPD”; 

• To carry out our activities in accordance with the relevant legislation and our policies, 
• To provide better service to our users on our website and to improve our services , 
• To perform product/service offer, all kinds of information, advertisement – promotion, promotion, sales and marketing activities, 
• To meet the interests of our customers and their preferences, by us or our group companies, 
• Preparation of your orders, delivery and execution of the necessary processes by our business units, 
• Ensuring the legal and commercial security of people who have or have a business relationship with URLA GROUP, 
• Product, service or the necessary work to be done by our business units in order to benefit you depending on the commercial activity;
• It can be transferred to our business partners, affiliate companies, suppliers, legally authorized public institutions for the purposes of determining and implementing commercial and business strategies.

4.Which Methods Do We Use to Collect Personal Data?

 It may differ depending on the type and nature of the relationship between URLA GROUP and the data owner, the communication channels used and the mentioned purpose information. By URLA GROUP as data controller, within the framework of our legal obligations arising from the “LPPD” and other relevant legislation; With the methods in the service processes performed in different channels such as the website, mobile applications, switchboard, call center, commercial areas within the scope of security/consulting offices, social media channels, direct or authorized communication channels and physical channels; By using these channels, to provide you with our quality services and to carry out our business and commercial activities within this framework, within the framework of legal reasons arising and executed based on the relevant legislation, contract, demand, commercial practice and honesty rules, oral, written or Your personal data may be collected by electronic means, including sensitive personal data, by the methods specified below; 

• Membership form that you fill in electronically or physically, 
• Social networks that allow you to sign up as a member during membership or login to our websites, 
• Contact forms on our websites or third-party websites that you fill in to contact us, 
• Online shopping applications, Cookies used to recognize you, our mobile applications,
• Various contracts you have signed with our company, and e-mails, faxes and letters you have sent to our Company , 
• Third party firm(s) that processes data on behalf of our company or supports our company at any stage of the membership program process ), 
• Our employees, customer service channels, 
• Social media channels, Google etc. the use of search engines,
• Membership agreements and other agreements, campaigns, applications, forms, offers,
• Data in our factories, branches and offices at URLA GROUP , 
• Information obtained from participants participating in activities such as fairs, events, market research carried out by URLA GROUP and media organs, web sites of local government members, web sites of URLA GROUP used for blogs, contests, surveys, games, campaigns and similar purposes . , basic personal contact information, past work experience, talents and skills, reference information obtained through companies operating in the field of human resources, 
• Telephone calls and records, e-mail correspondence with customers using URLA GROUP products through all kinds of communication channels and basic contact information of prospective customers 

5. What are the Rights of the Data Owner within the Scope of “LPPD” ? 

In accordance with the “LPPD”, you can exercise the following rights about your personal data by applying to URLA GROUP: 

• To learn whether personal data is processed,
• To learn the purpose of processing personal data and whether they are used in accordance with its purpose,
• To know the third parties in the country or abroad to whom personal data is transferred,
• To know whether personal data is processed. Requesting their correction in case of incomplete or incorrect processing, 
• Requesting the deletion or destruction of personal data, 
• Objecting to the emergence of a result against the person by analyzing the processed data exclusively through automated systems, 
• In case of loss of personal data due to unlawful processing to demand compensation for the damage. In this context, requests submitted to URLA GROUP will be finalized free of charge within thirty (30) days at the latest .

 6. How Long Do We Keep Personal Data?

 In accordance with the “LPPD”, although it has been processed in accordance with the provisions of the “LPPD” and other relevant laws, the personal data is deleted, destroyed or anonymized by the data controller or upon the request of the person concerned, in case the reasons requiring processing are eliminated. 

Use of Cookies 

As URLA GROUP, we use cookies, like most websites, to provide you a better, faster and safer experience. A cookie is a small text file that is stored on your device (such as computer or mobile phone) when you visit a website. Cookies may be stored on your device through your browser during your first visit to a website. When you visit the same site again with the same device, your browser checks whether there is a cookie stored on your device for the site. If there is a record, it transmits the data in the record to the website you are visiting. In this way, the website understands that you have visited the site before and determines the content to be delivered to you accordingly. Some cookies enable the website to remember the preferences you used in your previous visits, allowing your next visits to offer a much more user-friendly and personalized experience. Any cookies used on our website do not process data that will help identify you. You can refuse cookies if you wish. To change your preferences for the use of cookies, or to block or delete cookies, simply change your browser settings. However, please note that if you change the cookie settings, some functions of our website may not work properly. There are Google Analytics cookies on URLA GROUP website(s) (urlagroup.com). Google Analytics is Google’s free analytics tool that helps website and app owners understand what visitors are doing on their websites and apps. It may use a set of cookies to collect information and report website usage statistics to Google without identifying visitors. In addition to reporting website usage statistics, Google Analytics may also be used, along with some of the advertising cookies described above, to help show you more relevant ads on Google properties (such as Google Search) and across the web. Learn more about Analytics cookies and privacy information.


Privacy and Security Policy

 All text, graphics, logos, pictures, photographs, figures, technical drawings published on the Website, All rights of video recordings, films, software and electronic materials are reserved. Using, copying, renting, lending, duplicating, making changes, uploading to another computer, posting, distribution, transfer, republishing of these elements in whole or in part, directly or indirectly, in kind or in another way, without the written permission of URLA GROUP. It is forbidden to display, adapt, process, represent, hold for commercial purposes, sell or encourage or facilitate the acts listed. However, it may allow the materials (such as promotional films, visuals, etc.) on the site to be copied to personal computers for non-professional or commercial use. However, any legal responsibility that may arise as a result of this use belongs to the person who violates it. URLA GROUP cannot be held responsible for any errors, damages or other possible consequences that may occur in computer hardware, software or other assets due to accessing the site or downloading any documents from the site. URLA GROUP will make every effort to ensure the accuracy and up-to-dateness of the information specified on the site. However, it does not take responsibility for the accuracy of the information used on the site. URLA GROUP can change or cancel all information and rules at any time. It is the user’s responsibility to follow these issues. All kinds of content, equipment, options, prices, payment terms, technical drawings, technical specifications, visuals, explanations and news on the website are for promotional and informational purposes only. URLA GROUP  may make changes in the price, type, technical document and definition it recommends on its products without prior notice. Although the information on this site may differ from country to country, the user accepts that he is responsible for obtaining the up-to-dateness and accuracy of this information from URLA GROUP. The information stated on the site does not constitute any guarantee or commitment. URLA GROUP does not bear any responsibility for all kinds of actions and actions of companies that try to operate to serve their brands by using the URLA GROUP name and logo, despite having no legal relationship. If a criminal complaint or an official investigation request is received from the official authorities and/or it is determined that the user has made any electronic sabotage or attack that will prevent the operation of URLA GROUP’s systems or change its operation, URLA GROUP will investigate the user’s identity information and notify the legal authorities. Completing the forms on the site does not give the user any rights or give the user the opportunity to claim vested rights regarding any application. If incomplete, incorrect or invalid information is entered in the forms, no claim can be made from URLA GROUP regarding the opportunities that can be provided as a result of promotional activities. As URLA GROUP, we process the data regarding the sections that users/visitors visit/access when they enter the website, for purposes such as increasing the quality of use, increasing the benefit from the use by facilitating the use of the site, and improving our website and preventing the possibility of security vulnerabilities. The User/Visitors accept and declare that they have been informed that the data mentioned so far has been processed, starting from the moment they log in to the site and ending with their leaving, including using the contact form, and that they have consented to the data processing process to be carried out by URLA GROUP.

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