- We are committed to safeguarding the privacy of our website visitors and individual customers.
- This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
- In this policy, “we”, “us” and “our” refer to Alster Pazarlama İthalat ve İhracat A.S. For more information about us, see Section 14.
- The personal data that we collect
- In this Section 2 we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
- We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, telephone number, and postal address. The source of the contact data is you.
- We may process information relating to our customer relationships (“customer relationship data”). The customer relationship data may include your name, the name of your business or employer, your job title or role, your contact details, your classification / categorisation within our customer relationship management system and information contained in or relating to communications between us and you, or between us and your employer. The source of the customer relationship data is you and/or your employer.
- We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content.
- We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
- Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Purposes of processing and legal bases
- In this Section 3, we have set out the purposes for which we may process personal data and the legal bases of the processing.
- Operations – We may process your personal data for the purposes of operating our website, the processing and fulfilment of orders, providing our services, supplying our goods, generating invoices, bills and other payment-related documentation, and credit control. The legal basis for this processing is our legitimate interests, namely the proper administration of our website, services and business.
- Relationships and communications – We may process contact data, customer relationship data and communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, and individual customers, the maintenance of our relationships, enabling the use of our services, and the proper administration of our website, services and business.
- Direct marketing – We may process contact data and customer relationship data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users.
- Record keeping – We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases, client account opening, other administrative tasks and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to properly and efficiently run our business in accordance with this policy.
- Security – We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.
- Legal claims – We may process your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
- Legal compliance and vital interests – We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
- Providing your personal data to others
- Your personal data held in our website database will be stored on the servers of our hosting services providers.
- We may disclose contact data along with any other personal data contained in enquiries made through our website or services to one or more of those selected third party suppliers of goods and/or services for the purpose of delivering and fulfilling our goods and/or services. Each such third party will act as a data controller in relation to the personal data that we supply to it.
- In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- International transfers of your personal data
- In this Section, we provide information about the circumstances in which your personal data may be transferred to a third country under UK and EU data protection law.
- We may transfer your personal data from the European Economic Area (EEA) to Turkey and process that personal data in Turkey for the purposes set out in this policy, and may permit our suppliers and subcontractors to do so, during any period with respect to which Turkey is not treated as a third country under EU data protection law or benefits from an adequacy decision under EU data protection law.
- We have offices and facilities in Turkey. Some of our suppliers, subcontractors, and the hosting facilities for our website are also situated in Turkey. Transfers to Turkey will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the competent data protection authorities, a copy of which can be obtained from https://kvkk.gov.tr.
- Retaining and deleting personal data
- This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
- Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
- We will retain your personal data as follows:
(a) contact data will be retained for a minimum period of 5 years following the date of the most recent contact between you and us, and for a maximum period of 10 years following that date;
(b) customer relationship data will be retained for a minimum period of 5 years following the date of the most recent contact between you and us, and for a maximum period of 10 years following that date;
(c) communication data will be retained for a minimum period of 5 years following the date of the most recent contact between you and us, and for a maximum period of 10 years following that date;
(d) usage data will be retained for 10 years following the date of collection.
- Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
- Security of personal data
- We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
- We will store your personal data on secure servers and personal computers.
- Your rights
- In this Section, we have listed the rights that you have under data protection law.
- Your principal rights under data protection law are:
(a) the right to access – you can ask for copies of your personal data;
(b) the right to rectification – you can ask us to rectify inaccurate personal data and to complete incomplete personal data;
(c) the right to erasure – you can ask us to erase your personal data;
(d) the right to restrict processing – you can ask us to restrict the processing of your personal data;
(e) the right to object to processing – you can object to the processing of your personal data;
(f) the right to data portability – you can ask that we transfer your personal data to another organisation or to you;
(g) the right to complain to a supervisory authority – you can complain about our processing of your personal data; and
(h) the right to withdraw consent – to the extent that the legal basis of our processing of your personal data is consent, you can withdraw that consent.
- These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects by visitinghttps://edpb.europa.eu/our-work-tools/general-guidance/gdpr-guidelines-recommendations-best-practices_en and https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
- You may exercise any of your rights in relation to your personal data by written notice to us, using the contact details set out below.
- Updating information
- Please let us know if the personal information that we hold about you needs to be corrected or updated.
- About cookies
- A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
- Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
- Cookies may not contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.
- Cookies that we use
- Managing cookies
- Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647 (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- Blocking all cookies will have a negative impact upon the usability of many websites.
- We may update this policy from time to time by publishing a new version on our website.
- You should check this page occasionally to ensure you are happy with any changes to this policy.
- Our details
- This website is owned and operated by Alster Pazarlama İthalat ve İhracat A.S.
- We are registered in Turkey under registration number 301272-5, and our registered office is at Hasanpasa Mah. Nabizade Sok. No 82/A Kadikoy 34722 Istanbul, Turkey.
- Our principal place of business is at Hasanpasa Mah. Nabizade Sok. No 82/A Kadikoy 34722 Istanbul, Turkey.
- You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form; or
(c) by email, using firstname.lastname@example.org.