ARTICLE 1 - INTRODUCTION
For Jetconnect Perakende Lojistik Anonim Şirketi (“Company”) as the data controller, the protection of personal data belonging to persons receiving products and services, employees, business partners, and other natural persons with whom it maintains relationships is of paramount importance. The objective of this Jetconnect Perakende Lojistik Anonim Şirketi Personal Data Protection and Processing Policy (“Policy”) regarding the personal data processing and protection processes is to ensure the lawful processing and protection of personal data belonging to our customers, employees, employee candidates, visitors, employees of institutions with which we cooperate, and third parties who establish a relationship with the Company. In this context, necessary administrative and technical measures are taken by the Company for the processing and protection of personal data in accordance with the Personal Data Protection Law No. 6698 (“Law”) and relevant legislation.
ARTICLE 2 - DEFINITIONS
Explicit Consent: Consent regarding a specific subject, based on information, and expressed with free will.
Anonymization: The modification of personal data in such a manner that it loses its quality as personal data and this state cannot be undone. E.g.: Rendering personal data unable to be linked with an identified or identifiable natural person through techniques such as masking, aggregation, data distortion, etc.
Application Form: The “Application Form Regarding Applications to be Made to the Data Controller by the Data Subject Pursuant to the Personal Data Protection Law No. 6698” containing the application to be submitted by data subjects whose personal data is processed in order to exercise their rights.
Employee Candidate: Natural persons who have applied for employment with JETCONNECT PERAKENDE LOJİSTİK ANONİM ŞİRKETİ by any means or who have disclosed their résumé and related information.
Employees, Shareholders, and Authorized Representatives of Cooperating Institutions: Natural and legal persons, including shareholders and authorized officers of such institutions, who work at institutions with which the Company maintains any business relations (such as, but not limited to, business partners and suppliers).
Business Partner: Parties with whom the Company establishes a business partnership for purposes such as conducting various projects independently or jointly, or receiving services while conducting its activities.
Processing of Personal Data: Any operation performed on personal data, such as collection, recording, storage, preservation, alteration, reorganization, disclosure, transferring, acquisition, making retrievable, classification, or prevention of use, wholly or partly by automated means or non-automated means provided that it is part of any data filing system.
Data Subject: The natural person whose personal data is processed. For example; visitor, staff member, customer, etc.
Personal Data: Any information relating to an identified or identifiable natural person. (For example; name-surname, TR ID No., email, address, date of birth, credit card number, etc.) Processing of data pertaining to legal entities is not within the scope of the Law.
Special Categories of Personal Data: Data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and clothing, membership in associations, foundations, or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.
Supplier: Parties who provide services to the Company on a contractual basis, in accordance with the orders and instructions of JETCONNECT PERAKENDE LOJİSTİK ANONİM ŞİRKETİ, while JETCONNECT PERAKENDE LOJİSTİK ANONİM ŞİRKETİ carries out its business operations.
Third Party: Natural persons whose personal data are processed within the scope of the Policy and who are not defined differently within the Policy. For example; family members, former employees.
Data Processor: The natural or legal person processing personal data on behalf of the data controller based on the authorization granted by the data controller. For example; third-party service providers engaged by the Company, etc.
Data Controller: The person who determines the purposes and means of processing personal data and manages the place where data is systematically stored (data filing system). Under this Policy, JETCONNECT PERAKENDE LOJİSTİK ANONİM ŞİRKETİ is the data controller.
Deletion of Data: Refers to the process of encrypting personal data in such a way that access by all relevant users within the Company is prevented, and only the data protection officer possesses this decryption key.
Destruction of Data: Refers to the complete physical or technological eradication of personal data in an irreversible manner.
Visitor: Natural persons who have entered the physical premises owned by the Company for various purposes.
ARTICLE 3 - PURPOSE AND SCOPE OF THE POLICY
The primary purpose of this Policy is to provide explanations regarding personal data processing activities carried out lawfully by the Company and the systems adopted for the protection of personal data, thereby ensuring transparency towards individuals associated with our Company and informing data subjects about the processing of personal data.
The scope of this Policy covers all personal data of persons receiving products and services, our employees, employee candidates, visitors, employees of collaborating institutions, and third parties, processed by automated means or non-automated means provided that it is part of any data filing system.
ARTICLE 4 - MATTERS RELATING TO THE PROTECTION OF PERSONAL DATA
4.1 Protection of Personal Data; In accordance with Article 12 of the Law, our Company takes the necessary technical and administrative measures to ensure the appropriate level of security in order to prevent unlawful processing of the personal data it processes, prevent unlawful access to data, and ensure data preservation, and conducts or has conducted the necessary audits in this regard. In this context, our Company takes administrative and technical measures and conducts or commissions audits to ensure the required security level in compliance with the guidelines published by the Personal Data Protection Board (“Board”).
4.2 Protection of Special Categories of Personal Data; Special importance has been attributed under the Personal Data Protection Law to sensitive personal data due to the risk of causing victimhood or discrimination to individuals if unlawfully processed. Pursuant to Article 6 of the Law, “special categories of” personal data are defined as data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and clothing, membership in associations, foundations, or trade unions, criminal convictions and security measures (special categories of personal data other than health and sexual life), and health, sexual life, biometric, and genetic data (special categories of personal data relating to health and sexual life). Technical and administrative measures taken by the Company for the protection of personal data are implemented with respect to special categories of personal data within the scope of adequate measures stipulated in Decision No. 2018/10 dated 31/01/2018 of the Board, as detailed in the Policy on the Protection of Special Categories of Personal Data, and activities conducted accordingly are monitored and audited through internal audits.
4.3 Audit of Measures Taken Regarding the Protection of Personal Data and Training of Company Personnel; A Personal Data Protection Committee exists within the Company. On behalf of the Company acting as the data controller and pursuant to its duty arising from Article 12 of the Law, the Committee directly performs the necessary audits or has them performed by receiving support from competent institutions when needed, in order to ensure the implementation of the provisions of the Law within its organization. According to the results of these audits, detected violations, adverse events, and non-conformities are reported to the responsible persons within the Committee, who enforce necessary remedial actions. In cases where personal data is transferred to natural or legal persons from whom services are outsourced by the Company, supplementary agreements containing provisions stipulating that the relevant entities to which personal data is lawfully transferred shall take all necessary security measures to protect personal data and ensure compliance with these measures within their organizations are executed. In addition, Jetconnect Perakende Lojistik Anonim Şirketi executes contracts with its personnel concerning compliance with personal data protection measures. The Company ensures that necessary training is provided to its employees to raise awareness regarding the prevention of unlawful processing of personal data, prevention of unlawful access to data, and preservation of data.
ARTICLE 5 - MATTERS RELATING TO THE PROCESSING OF PERSONAL DATA
The Company conducts personal data processing activities in accordance with Article 20 of the Constitution and Article 4 of the Law. Jetconnect Perakende Lojistik Anonim Şirketi retains personal data for the period stipulated in the laws or required by the purpose of processing personal data. In accordance with Article 10 of the Law, the Company informs the data subjects whose personal data is processed, requests consent from data subjects where required, and processes this personal data in accordance with their consent based on the criteria specified below.
5.1. Processing in Compliance with the Law and Good Faith Principles; The Company acts in accordance with the principles set forth by legal regulations, public trust, and good faith in the processing of personal data. In accordance with the principle of acting in good faith, the Company takes into account the rights of data subjects while striving to achieve its data processing objectives.
5.2. Ensuring Personal Data is Accurate and Up-to-Date Where Necessary; Keeping personal data accurate and up-to-date is essential for the Company to protect the fundamental rights and freedoms of the data subject. The Company fulfills its duty of utmost care in ensuring that personal data is accurate and, when necessary, kept up-to-date. For this reason, all communication channels are kept open by the Company to keep data subjects' information accurate and up-to-date, and necessary measures are taken in this regard.
5.3. Processing for Specified, Explicit, and Legitimate Purposes; Jetconnect Perakende Lojistik Anonim Şirketi clearly and definitively determines its legitimate and lawful personal data processing purposes. The Company processes personal data only to the extent connected with the activities it carries out and necessary for its operational activities and commercial services.
5.4. Being Relevant, Limited, and Proportionate to the Purposes for which They are Processed; The Company processes personal data strictly within the purposes relevant and necessary for conducting its business. Therefore, the Company processes personal data in a manner suitable for realizing the specified purposes and refrains from processing personal data that is not relevant to or needed for achieving the purpose.
5.5. Retention for the Period Prescribed in the Relevant Legislation or Necessary for the Purpose of Processing; The Company retains personal data only for the period specified in the relevant legislation or required for the purpose for which they are processed pursuant to company policies. In this context, the Company first determines whether a retention period is prescribed for the storage of personal data in the relevant legislation; if a period is stipulated, it complies with that period; if no period is specified, it retains personal data for the duration required for the purpose of processing as defined in the Company's data retention policy. The Company relies on retention periods in its personal data inventory, and upon the expiration of the periods specified therein, personal data is deleted, destroyed, or anonymized in accordance with statutory obligations under the Law depending on data nature and intended use.
ARTICLE 6 - PROCESSING OF PERSONAL DATA
The explicit consent of the data subject whose personal data is processed is only one of the legal grounds enabling lawful processing of personal data. Aside from explicit consent, personal data may also be processed if one of the conditions stipulated by the law exists. The basis of personal data processing activity may be only one of the conditions listed below, or more than one condition may concurrently constitute the basis of the same processing activity. Where processed data constitutes special categories of personal data, the conditions set forth under section 6.2 of this Policy (Processing of Special Categories of Personal Data) shall apply.
6.1. Conditions for Processing Personal Data
a) Existence of Explicit Consent of the Data Subject: One of the conditions for processing personal data is the explicit consent of the data subject. The explicit consent of the data subject must relate to a specific subject, be based on information, and be expressed with free will. Where any of the conditions for processing personal data listed below exist, personal data may be processed without requiring the explicit consent of the data subject.
b) Explicitly Stipulated in the Laws: This data processing condition is met if personal data of the data subject is expressly provided for by law, in other words, if there is an explicit provision in the relevant law regarding the processing of personal data.
c) Impossibility of Obtaining Explicit Consent Due to Actual Impossibility: Personal data of the data subject may be processed if it is mandatory to process personal data to protect the life or physical integrity of a person who is unable to express their consent due to actual impossibility or whose consent is not granted legal validity, or of another person.
d) Direct Relevance to the Conclusion or Execution of a Contract: This condition shall be deemed fulfilled if processing of personal data is necessary, provided that it is directly related to the conclusion or performance of a contract to which the data subject is a party.
e) Fulfillment of Legal Obligations by Jetconnect Perakende Lojistik Anonim Şirketi: Personal data of the data subject may be processed if processing is mandatory for our Company to fulfill its legal obligations.
f) Personal Data Made Public by the Data Subject: If the data subject has made their personal data public, the personal data concerned may be processed limited to the purpose of making it public.
g) Data Processing is Mandatory for the Establishment or Protection of a Right: Personal data of the data subject may be processed if data processing is mandatory for the establishment, exercise, or defense of a right.
h) Data Processing is Mandatory for the Legitimate Interests of Jetconnect Perakende Lojistik Anonim Şirketi: Personal data of the data subject may be processed if processing is mandatory for the legitimate interests pursued by our Company, provided that it does not harm the fundamental rights and freedoms of the data subject.
6.2. Processing of Special Categories of Personal Data
Special categories of personal data are processed by our Company in accordance with the principles set forth in this Policy, by taking all necessary administrative and technical measures including methods determined by the Board, and in the presence of the following conditions:
a) Special categories of personal data other than health and sexual life may be processed without seeking the explicit consent of the data subject if explicitly provided for by law, in other words, if there is an explicit provision in the relevant law regarding the processing of personal data. Otherwise, explicit consent of the data subject shall be obtained.
b) Special categories of personal data relating to health and sexual life may be processed without seeking explicit consent by persons under the obligation of confidentiality or authorized public institutions and organizations for the purposes of protection of public health, preventive medicine, medical diagnosis, treatment, and nursing care services, planning and management of healthcare services and financing. Otherwise, explicit consent of the data subject shall be obtained.
ARTICLE 7 - PURPOSES OF PROCESSING PERSONAL DATA
The Company processes personal data strictly limited to the purposes within the conditions for processing personal data specified in paragraph 2 of Article 5 and paragraph 3 of Article 6 of the Personal Data Protection Law. Detailed information regarding this matter can be accessed from the ANNEX-1 (“ANNEX-1 - Personal Data Processed by the Company and Its Purposes”) document of this Policy. In addition, the general purposes regarding processed personal data are also stated in the Data Controllers Registry in which registration has been completed.
ARTICLE 8 - OBLIGATION TO INFORM AND ENLIGHTEN THE DATA SUBJECT
In accordance with Article 10 of the Personal Data Protection Law, the Company informs data subjects during the collection of personal data. In this context, depending on the status of the data subject and the data processing procedure, the Company informs data subjects regarding the identity of the data controller and its representative (if any), the purpose for which personal data will be processed, to whom and for what purposes the processed personal data may be transferred, the method and legal basis of collecting personal data, and the rights of data subjects whose personal data is processed. In this regard, initial privacy notices and full disclosure texts have been placed in conspicuous locations within the Company premises and common areas. Along with this Policy, process- and person-based disclosure texts, a cookie policy, and an application form are also published on the Company website.
ARTICLE 9 - TRANSFER OF PERSONAL DATA
In line with lawful personal data processing purposes and by taking necessary security measures, the Company may transfer personal data of the data subject to third parties. In this scope, personal data is transferred if;
a) There is an explicit provision in the laws regarding personal data transfer,
b) Transfer of personal data belonging to contract parties is necessary, provided that it is directly related to the conclusion or performance of a contract,
c) Personal data transfer is mandatory for the Company to fulfill its legal obligation,
d) Personal data transfer is mandatory for the establishment, exercise, or defense of a right,
e) Personal data transfer is mandatory for the legitimate interests of the Company, provided that it does not harm the fundamental rights and freedoms of the data subject,
f) For special categories of personal data other than health and sexual life; if circumstances provided for in the laws exist,
g) For personal data relating to health and sexual life; if there is a necessity to share it with authorized persons, institutions, and organizations for the protection of public health, preventive medicine, medical diagnosis, treatment, and nursing care services, planning and management of healthcare services and financing,
transferred.
ARTICLE 10 - THIRD PARTIES TO WHOM PERSONAL DATA IS TRANSFERRED BY JETCONNECT PERAKENDE LOJİSTİK ANONİM ŞİRKETİ AND PURPOSES OF TRANSFER
In line with lawful personal data processing purposes and by taking necessary security precautions, the Company may transfer personal data and special categories of personal data of the data subject to third parties. In this regard, our Company acts in accordance with the provisions set forth in Articles 8 and 9 of the Law. Detailed information regarding this matter can be accessed from the ANNEX-2 (“ANNEX-2 - Third Parties to Whom Personal Data is Transferred by Our Company and Purposes of Transfer”) document of this Policy.
ARTICLE 11 - JETCONNECT PERAKENDE LOJİSTİK ANONİM ŞİRKETİ PERSONAL DATA INVENTORY AND CLASSIFICATION OF PERSONAL DATA
Identity Data; Data group containing information regarding personal identity.
Contact Data; Data group that can be used to reach the individual.
Visual and Audio Data; Data group containing visual and audio records belonging to the individual.
Location Data; This data category refers to data types such as location coordinates/information of the individual's presence.
Personnel/HR Data; This data category refers to data types such as payroll records, asset declaration records, and résumé information of individuals.
Financial Data; Data group containing financial information of the individual.
Professional Experience; Data group containing information about the person's profession, professional experience, and educational background.
Customer Transaction Data; This data category refers to data types such as call center records, receipts, voucher/acknowledgement documents, negotiable instruments details, and invoice information.
Marketing Data; This data category refers to the data group used for marketing and sales purposes containing digital footprints generated as a result of processing individual data. It refers to website browsing data, marketing cookies, and shopping history.
Legal Transaction Data; This data category refers to data types such as information in correspondence with judicial authorities and legal case file details.
Transaction Security Data; Data group containing transaction security data such as IP address, log records, and cookies belonging to the individual.
Physical Space Security Data; Data group containing physical space security data such as security camera recordings and entrance-exit logs belonging to the person.
Risk Management; This data category refers to data types processed for managing technical and administrative risks.
Criminal Conviction Data; Data group regarding public and criminal sanctions imposed on the person in the past.
Health Data; Data group regarding health data of the individual.
Other; Refers to Military Status Information data which is not categorized in the Data Controllers Registry.
ARTICLE 12 - RETENTION PERIODS OF PERSONAL DATA
In cases stipulated in relevant laws and regulations, the Company retains personal data for the duration specified in such legislation. If no duration is prescribed in the legislation regarding how long personal data should be retained, personal data is retained for the period requiring its retention in accordance with company practices and commercial customs, depending on the activity conducted by the Company while processing that data.
Pursuant to Article 138 of the Turkish Penal Code, Article 7 of the Personal Data Protection Law, and the “Regulation on the Deletion, Destruction, and Anonymization of Personal Data” enacted by the Personal Data Protection Authority, personal data processed in accordance with the provisions of relevant laws shall be deleted, destroyed, or anonymized based on Company policies or upon request of the data subject when the grounds requiring their processing cease to exist. The Company has formulated a policy on this matter pursuant to the provisions of the Regulation and acts in accordance with this policy.
ARTICLE 13 - RIGHTS OF THE DATA SUBJECT; EXERCISE OF THESE RIGHTS
In accordance with Article 10 of the Personal Data Protection Law, the Company notifies the data subject of their rights, provides guidance to the data subject whose personal data is processed on how to exercise these rights set out in Article 11, and operates the necessary channels, internal workflows, administrative and technical arrangements in accordance with Article 13 of the Personal Data Protection Law for the evaluation of data subjects' rights and the provision of requisite disclosures to them.
13.1. Rights of Data Subjects Whose Personal Data is Processed: Data subjects whose personal data is processed possess the following rights:
13.1.1. To learn whether personal data is processed,
13.1.2. To request information if personal data has been processed,
13.1.3. To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
13.1.4. To know third parties to whom personal data is transferred domestically or abroad,
13.1.5. To request correction of personal data if incomplete or inaccurately processed and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
13.1.6. To request deletion or destruction of personal data in the event that reasons requiring processing cease to exist, despite having been processed in accordance with the Personal Data Protection Law and provisions of other relevant laws, and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
13.1.7. To object to the occurrence of a result against the person themselves by analyzing processed data exclusively through automated systems,
13.1.8. To claim compensation for damages in case of suffering damage due to unlawful processing of personal data.
13.2. Circumstances Where the Data Subject Cannot Assert Their Rights
13.2.1. Pursuant to Article 28 of the Personal Data Protection Law, data subjects whose personal data is processed cannot assert the rights listed in 13.1 in the following cases, as they are excluded from the scope of the Personal Data Protection Law:
13.2.1.1. Processing of personal data for research, planning, and statistics purposes by rendering them anonymous through official statistics,
13.2.1.2. Processing of personal data for artistic, historical, literary, or scientific purposes or within the scope of freedom of expression, provided that it does not violate national defense, national security, public security, public order, economic security, right to privacy, or personal rights, and does not constitute a crime,
13.2.1.3. Processing of personal data within the scope of preventive, protective, and intelligence activities carried out by public institutions and organizations mandated and authorized by law to ensure national defense, national security, public security, public order, or economic security,
13.2.1.4. Processing of personal data by judicial authorities or execution authorities in relation to investigation, prosecution, adjudication, or execution procedures.
13.2.2. Pursuant to Article 28 of the Personal Data Protection Law, data subjects whose personal data is processed cannot assert the rights listed in 13.1 in the following cases, as they are excluded from the scope of the Personal Data Protection Law:
13.2.2.1. Where personal data processing is necessary for crime prevention or criminal investigation,
13.2.2.2. Processing of personal data made public by the data subject themselves,
13.2.2.3. Where personal data processing is necessary for regulatory, supervisory, or disciplinary proceedings carried out by public institutions and organizations or professional organizations having public institution status based on statutory authority,
13.2.2.4. Where personal data processing is necessary for protecting the economic and financial interests of the State regarding budgetary, tax, and financial matters.
13.3. Exercise of Rights by the Data Subject: Data subjects whose personal data is processed may convey their requests regarding the rights specified in this Policy to the Company free of charge by filling out and signing the application form along with information and documents identifying their identity through the methods specified below or other methods determined by the Personal Data Protection Board. Regulations in this regard have been established in the JETCONNECT PERAKENDE LOJİSTİK ANONİM ŞİRKETİ Personal Data Application and Response Procedure and within the disclosure notices.
The data subject may exercise their rights by;
13.3.1. Filling out the form available at https://www.jetbee.com.tr/kvkk-politikasi and delivering a wet-signed physical copy in person or sending it via registered mail with return receipt to the address “Devrim Mh. Nevruz Bulvarı No:23E Nusaybin/Mardin”, or by applying in person,
13.3.2. Filling out the form and signing it with a “secure electronic signature” within the scope of the Electronic Signature Law No. 5070 and sending the form with secure electronic signature via registered electronic mail (KEP) to [email protected], or applying to [email protected] using secure electronic signature, mobile signature, or the email address previously notified to the Company by the data subject and registered in the Company's system, or via software or an application developed for application purposes.
In order for the above-mentioned application to be accepted as a valid application, pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller, the application must include;
13.3.3. Name, surname, and signature if the application is in writing,
13.3.4. Turkish ID number for citizens of the Republic of Turkey, nationality, passport number or identification number (if any) for foreigners,
13.3.5. Residential or workplace address for notification,
13.3.6. Email address, telephone, and fax number for notification (if any),
13.3.7. Subject of the request,
It is mandatory to specify these details. Otherwise, the application will not be evaluated as a valid application. For applications made without filling out the application form, the matters listed herein must be submitted to the Company completely.
In order for third parties to submit an application on behalf of data subjects whose personal data is processed, a special power of attorney issued by a notary public on behalf of the applicant must be present.
Data Controller: JETCONNECT PERAKENDE LOJİSTİK ANONİM ŞİRKETİ
Address: Devrim Mh. Nevruz Bulvarı No:23E Nusaybin/Mardin
Below is a table presenting definitions, personal data processing purposes, and transfer purposes to assist in reviewing the policy.
ANNEX-1 PERSONAL DATA PROCESSED BY JETCONNECT PERAKENDE LOJİSTİK ANONİM ŞİRKETİ AND PURPOSES OF PROCESSING
Data Subject; Employee
Processed Personal Data Category; Identity, Contact, Professional Experience, Legal Transaction, Finance, Personnel/HR, Visual and Audio Records, Military Status Data, Criminal Record, Health Information
Purposes of Processing Personal Data; In accordance with Labor Law No. 4857 and relevant regulations subordinate to these laws; Execution of Employee Satisfaction and Loyalty Processes, Fulfillment of Obligations Arising from Employment Contracts and Legislation for Employees, Management of Fringe Benefits and Entitlements for Employees, Execution of Activities in Compliance with Legislation, Execution of Activities in Compliance with Legislation, Execution of Financial and Accounting Affairs, Execution of Assignment/Deployment Processes, Tracking and Execution of Legal Affairs, Execution of Internal Audit / Investigation / Intelligence Activities, Execution of Communication Activities, Execution / Auditing of Business Activities, Execution of Contract Processes, Planning of Human Resources Processes, Providing Information to Authorized Persons, Institutions, and Organizations, Execution of Training Activities, with the purpose(s) of tracking the suitability of Company employees for their assignments, personal data belonging to employees are processed.
Data Subject; Employee Candidate
Processed Personal Data Category; Identity, Contact, Professional Experience, Visual and Audio Records
Purposes of Processing Personal Data; To serve as a basis for evaluating employee candidates for appropriate positions in recruitment processes; our Company processes identity details, contact details, professional experience details, and financial details of employee candidates for the purpose of carrying out preparatory employment procedures.
Data Subject; Intern
Processed Personal Data Category; Identity, Contact, Professional Experience, Finance
Purposes of Processing Personal Data; Our Company organizes programs and events for interns voluntarily participating in our work. The data in question is processed for the purpose of issuing an Internship Certificate of Participation to interns at the end of the program.
Data Subject; Visitor
Processed Personal Data Category; Identity, Physical Space Security, Identity Transaction Security
Purposes of Processing Personal Data; To ensure the security of the company building and track entry and exit of visitors to the company building, in line with our company's legitimate interests, visitor images are recorded through camera footage within our company; and pursuant to Law No. 5651 on Regulating Broadcasting on the Internet and Fighting Against Crimes Committed Through Internet Broadcasting, for recording by whom and for what purpose the internet service provided is used, conducting e-commerce activities on our corporate website and mobile applications, and confirming user details, our website visitors' identity information, IP address details, and website access logs are processed.
Data Subject; Person Receiving Products and Services
Processed Personal Data Category; Identity, Contact, Transaction Security, Finance, Visual and Audio Records, Marketing Data, Legal Transaction Data, Customer Transaction Data
Purposes of Processing Personal Data; Within the framework of contractual relations, customer details registered on websites managed by our company are processed for direct marketing, digital marketing, remarketing, targeting, profiling, and analysis in order to promote and market applications, goods, products, and services in line with customer preferences and needs.
Data Subject; Person Receiving Products and Services
Processed Personal Data Category; Identity, Contact, Transaction Security, Finance, Visual and Audio Records, Marketing Data, Legal Transaction Data, Customer Transaction Data
Purposes of Processing Personal Data; Within the framework of contractual relations, customer details registered on websites managed by our company are processed for direct marketing, digital marketing, remarketing, targeting, profiling, and analysis in order to promote and market applications, goods, products, and services in line with customer preferences and needs.
ANNEX-2 THIRD PARTIES TO WHOM PERSONAL DATA IS TRANSFERRED BY JETCONNECT PERAKENDE LOJİSTİK ANONİM ŞİRKETİ AND PURPOSES OF TRANSFER
Parties to Whom Data May Be Transferred: Business Partner
Relevant Persons: Person Receiving Products and Services
Purpose of Data Transfer: Transfers are carried out on a limited basis to our business partners providing research, promotion, and consultancy services who act as data processors on behalf of JETCONNECT PERAKENDE LOJİSTİK ANONİM ŞİRKETİ in order to ensure that persons receiving products and services access products and services at more affordable prices, provide and present various advantages, and provide access to affordable products, advertising, promotion, sales, marketing, information, promotional discounts, campaign notifications, membership transactions, and services within this scope personally to persons receiving products and services.
Parties to Whom Data May Be Transferred: Suppliers
Relevant Persons: Person Receiving Products and Services
Purpose of Data Transfer: Transfers are carried out on a limited basis to ensure that the services outsourced by the Company from the supplier and necessary for performing Company activities are provided to the Company.
Parties to Whom Data May Be Transferred: Authorized Public Institutions and Organizations
Relevant Persons: Person Receiving Products and Services
Purpose of Data Transfer: Transfers are carried out strictly limited to the purpose in cases where requested by public institutions and organizations and where they provide a legal basis.
Parties to Whom Data May Be Transferred: Commercial Electronic Message Intermediary Service Provider
Relevant Persons: Person Receiving Products and Services
Purpose of Data Transfer: Transfers are carried out on a limited basis for conducting electronic communications and sending other communication messages in order to execute services provided to persons receiving products and services and fulfill our statutory obligations.
Parties to Whom Data May Be Transferred: Banks and Payment Intermediary Institutions
Relevant Persons: Person Receiving Products and Services
Purpose of Data Transfer: Transfers are carried out on a limited basis for payment activities in the event that persons receiving products and services wish to make payments via our Website.
Share
Link copied