KVKK

Clarification Text on Personal Data Processing and Cookie Policy 

 

At Kahramanmaraş Kağıt San. ve Tic. A.Ş. (“KMK PAPER”), we value the protection of our valued customers’ personal data and would like to inform you within the framework of the Personal Data Protection Act No. 6698 (“KVKK”).

 

  1. What is personal data?

 

Within the scope of the KVKK, personal data means any information relating to an identified or identifiable natural person (“Personal Data”), and Sensitive Personal Data, which is a special type of data, refers to your data concerning race, ethnic origin, political opinions, beliefs, religion, sect or other convictions, clothing, association, foundation or trade union membership, health, sex life, criminal convictions and security measures, as well as your biometric and genetic data (“Sensitive Personal Data”). The explanations for your personal data in the context of this Clarification Text also refer to your sensitive personal data.

 

  1. By what methods and for what legal reasons do we collect your personal data?

 

In all personal data processing activities we carry out, we act in accordance with all obligations and principles required by relevant legislation, in particular the KVKK, and we take the necessary security measures for the safe processing of your personal data. More detailed information can be found on our “Personal Data Protection Policy” page.

 

In accordance with the KVKK, we collect your personal data automatically or non-automatically, orally, in writing or electronically through the following channels and other channels that may be added in the future, and process such data within the framework of Article 5.1, Article 5.2, Article 6.2 and Article 6.3 of the KVKK, depending on the purpose of the processing:

 

Our other websites managed by KMK PAPER or KMK PAPER Group Companies (“Websites”), including our websites on which personal data is processed and which are associated with KMK PAPER’s affiliates listed in Annex 1 (“KMK PAPER Affiliates”), and other respective documents, and updated from time to time as part of this Clarification Text, through our mobile and other applications and any other online media (“Media Tools”) owned by a KMK PAPER Group Company or KMK PAPER communicating with your devices on the Websites, or through third-party cookies (“Cookies”) as indicated below,

 

  • Through any websites established or operated by KMK PAPER and managed under the name of KMK PAPER affiliates for the purpose of measuring performance and communicating with the visitor,

 

  • Through accounts operated on behalf of KMK PAPER or KMK PAPER affiliates on various social media channels (“Social Media”),

 

  • Through correspondence via our email addresses (“Email”), other methods of communication, including short messages (“SMS”) or multimedia messages (“MMS”) sent to KMK PAPER or KMK PAPER affiliates for other purposes, and all types of means of communication (“Means of Communication”),

 

  • Through our call centers (“Call Center”) managed by KMK PAPER or the companies from which KMK PAPER receives services,

 

  • Through third parties such as group companies, business partners, manufacturers or companies from which KMK PAPER provides or receives products/services.

 

  1. What personal data do we process?

 

The following examples relate to your personal data that we process:

 

Personal data that you provide to us: First and last name, date of birth, Turkish ID number, telephone number, email address, address, as well as photographs, video recordings submitted as part of surveys, and any other personal data that you provide to us in any way through the above channels.

 

Other information, including personal data, collected by automatic means: Your personal data collected automatically through automatic search engines, video and audio recording devices, cookies or other means.

 

Other information, including personal data, obtained from other sources: Your personal data, such as updated shipping and address information shared with us by social media tools, our business partners, suppliers, and other third parties based on your previously provided consent; account information, purchase and page view data; information such as searched terms and search results, paid listings (e.g. sponsored links).

 

  1. For what purposes do we process your personal data?

 

As a rule, we process your personal data on the basis of your express consent. However, in exceptional cases permitted under the KVKK, your personal data may be processed without your express consent (Art. 5.2 and Art. 6.3 of the KVKK). In this context, we process your personal data (i) to comply with our legal obligations, (ii) if you are unable to give your consent due to impossibility of doing so, (iii) to contact you via the contact details you have provided to us through the Websites, in the context of the sale of goods and services offered by KEY, POS usage, return transactions, shipping services, formation of a sales contract, sale, delivery, supply of products or services, to receive your questions and complaints, to respond to you, to use them in a possible dispute when necessary, such as the establishment or performance of a contract or to fulfill our legal obligations or to establish or protect a right, (iv) to protect our legitimate interests, e.g. cost reduction, efficient use of resources, monitoring the quality of service of the call center, etc., provided that this does not affect your fundamental rights and freedoms. In addition, we may process your personal data that you have disclosed through means such as social media channels to the extent permitted under the KVKK without seeking your consent again.

 

If we obtain your explicit consent (Art. 5.1 and Art. 6.2 of the KVKK), we may process your personal data that we have collected via the above-cited channels and using the above-cited methods: (i) in order to provide you with opportunities for special products and services such as internet advertising, targeting, re-targeting, cross-selling, campaigns, opportunities and product/service advertisements, to use Cookies for this purpose, to make commercial offers by taking into account your preferences and recent purchases (ii) to determine how you are informed about our Websites, to create non-anonymous traffic statistics through unique user registration, to make your visit to the Websites more enjoyable and increase the use and functionality of the Websites, to recognize you during your visit to the Websites and providing content and personalized browsing opportunities tailored to your expectations and interests, to use Cookies for this purpose, to conduct other marketing and CRM (Customer Relationship Management) activities, to use Cookies for this purpose (iv) to create new product and service models, to use Cookies for this purpose (v) to send electronic commercial messages (such as campaigns, newsletters, customer satisfaction surveys, product and service advertisements) (vi) to send gifts and promotions and other magazines/periodicals (vii) for purposes of corporate communication and to hold other events and send out invitations in this context. In addition, your Sensitive Personal Data may also be processed with your explicit consent for the purposes specified in Article 5.2 of the KVKK and for the purposes specified in articles (i) to (vii) herein.

 

In this context, you can help us provide you with better service by giving your consent to each of the types of processing for which your explicit consent is required in this Clarification Text with respect to the documents and areas where your explicit consent is required.

 

  1. How long will your personal data be processed?

 

Your personal data will be processed in accordance with the legislation on the protection of personal data, in particular the KVKK, and the time limits prescribed by other laws, as long as the legitimate purposes mentioned above do not disappear.

 

  1. Transfer of your personal data to third parties and/or abroad

 

Your personal data may only be transferred to third parties from whom we receive support in areas such as storage, archiving, information technology support (server, hosting, program, cloud computing), security, call center in the country and abroad, especially in EU countries, USA, England, OECD countries, India, China and Russia as well as KEY affiliates, business partners, suppliers, banks, financial institutions; consultancy firms from which we receive support in areas such as law, tax, and other related parties and authorized institutions and organizations where transfer is necessary for the specified purposes, in the presence of processing purposes that do not require your express consent.

 

Apart from the above, provided your explicit consent is obtained, it may be transferred to KEY affiliates located in the country and countries mentioned above, and to third parties providing us with marketing and sales support who may process personal data based on your explicit consent above. In addition, in case of sale of any part of KEY or its assets (including but not limited to the brand, domain name and other elements of the commercial enterprise), your personal data may be transferred to third parties in the country and abroad including the individuals or legal entities acquiring the business, their shareholders, business partners or intermediaries, consultants, based on your explicit consent, to the extent necessary for the transfer, they may be processed by these third parties as part of the transaction process to an extent limited to the necessary evaluation, and in the event of a transfer, the recipient may continue to process the assets and your personal data which is associated with these assets with itself as data controller.

 

  1. Under your Personal Data Rights originating from the KVKK and under our support as Data Controller

 

you may apply to KEY as per Article 11 of the KVKK to do the following:

 

To find out whether your personal data is being processed,

 

  • To request information about the processing of your personal data,

 

  • To know the purposes for which your personal data is processed and whether your data is used in accordance with the intended purpose,

 

  • To know the third parties to whom your personal data is communicated in the country or abroad,

 

  • To request the rectification of your personal data in case of incomplete or inaccurate processing,

 

  • To request the erasure or destruction of your personal data if the reasons that make the processing of your personal data necessary no longer exist, according to the principles of purpose, duration and lawfulness,

 

  • To request the communication of these operations to third parties to whom personal data is communicated in case of rectification, erasure or destruction of your personal data,

 

  • To object to a result against you, in case of analysis of your processed personal data exclusively by automated systems,

 

  • To request compensation for the damage in the event that your personal data is processed unlawfully and you suffer damages as a result.

 

 

 

In this regard, you may send your requests regarding these rights to the email address provided below by completing the above Request Form. Upon your request, you must send your Request Form with a secure electronic signature to our email address with the Kep extension to be provided to you or to our mailing address below with documents proving your identity and a handwritten signature or via a notary public. KEY will process your request as soon as possible, but no later than within 30 (thirty) days of receipt of the appropriate documentation, free of charge.

 

If any costs are incurred as a result of fulfilling your requests, we may only charge you the fees provided for in the tariff established by the Personal Data Protection Committee.

 

Postal address :

 

Email address :  [email protected]

 

You can always follow the changes in the legislation on personal data and our practice on the relevant page of our website.

 

Cookie Policy

 

  1. What is a cookie?

 

Cookies are small text files from KEY or third parties that are stored on your devices with network access through browsers when you visit websites over the Internet. Cookies are used on the Websites as defined in the Clarification Text.

 

  1. Why do we use cookies?

Depending on your device, we use cookies, in particular for the following purposes:

  • To make your visit to the Websites more enjoyable and to improve the use and functionality of the Websites,
  • To recognize you on your next visit to the Websites and to offer you content tailored to your expectations and interests and personalized browsing,
  • To make commercial offers for your specific products and services, such as internet advertising, targeting, re-targeting, cross-selling, campaigns, opportunities and product/service ads,

 

  • To compile traffic statistics,
  • To determine how you are informed about the Websites.
  1. How can you edit cookie settings in your internet browser?

Although the default settings of internet browsers are generally programmed to accept Cookies, you can easily change this by modifying your browser settings.

However, if you choose to disable Cookies in your browser, you may not be able to take advantage of all the functional features offered on our Websites.

For more information on cookie settings, please see the links below:

  • http://www.aboutcookies.org/
  • Internet Explorer™: http://windows.microsoft.com/en-us/windows7/how-to-manage-cookies-in-int…
  • Safari™: http://support.apple.com/kb/HT1677?viewlocale=en_US
  • Chrome™: https://support.google.com/chrome/answer/95647?hl=en
  • Firefox™: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-…
  • Opera™: http://help.opera.com/Windows/10.20/en/cookies.html

As a reminder, by disabling Cookies through your internet browser, you are disabling all Cookies, including those necessary for the proper functioning of our websites.

  1. Do we accept third-party cookies?

 

The following third-party website cookies may be stored on your device to personalize and enhance the content presented to you during your visit to our Websites, including advertising:

  • Social network content: We may publish content from social networks on our support pages. Thus, when you access such content on our support pages, a Cookie from the relevant social network may be stored on your device. For more detailed information, we recommend that you read the cookie policies of these social networks.
  • Flash cookies: These are files stored by the Flash software. This tool is often installed as an extension of internet browsers to display dynamic objects such as animated graphics or video directories. Therefore, using this application can install Flash cookies. For more information, we recommend that you read the cookie policy at www.adobe.com.