CLARIFICATION TEXT ON PROCESSING OF PERSONAL DATA
Dear customer,
As Benov Partners Consulting Trade Corporation ("Company"), we attach great importance to the protection of your personal data. In this context, as the "data controller" ("Data Controller") under the Personal Data Protection Law No. 6698 ("PDPL"), we process your personal data in accordance with PDPL and within the purposes and limits specified below, and we take utmost care to take necessary administrative and technical measures accordingly. We would like to inform you with this Clarification Text on Processing of Personal Data ("Clarification Text") about our personal data processing processes and your rights under PDPL regarding your personal data that we process within the scope of the platform ("Platform") accessed through our website www.fanself.com.
Your Personal Data We Process
The following personal data ("Personal Data") will be processed by the Company within the scope of Platform membership and/or use:
- Identity Information: Name and surname, photo
- Contact Information: Address, phone number, email address
- Marketing Information: Communication preferences
- Transaction Security Information: Platform username and password information, IP address, website entry and exit/visit information, log records
- Customer Transaction Information: Membership information, comment information, campaign information, discount code information
- Order Information: Order, amount, invoice, shipping and delivery information of the Product selected through the Platform
- Financial Information: Encrypted bank and credit card information
- Other Information: Requests and complaints submitted to the Company through the Platform and information shared in this context
Cookies are used limited to ensuring the functionality of the Platform. For detailed information about cookies, you can review the Cookie Policy.
Method of Collecting Your Personal Data
Your Identity and Contact Information are collected from information and documents you provide within membership or order scope, and Transaction Security Information, Order Information, and Other Information are collected through automatic methods within the Platform and processed in electronic environment.
Purposes of Processing Your Personal Data, Legal Grounds and Transfer
If you request to register/create membership on the Platform, upon submitting this request to the Company:
Your Identity Information and Contact Information obtained for realizing membership, verification and recording member information, enabling member login, ensuring accuracy and currency of your membership information, making notifications about your membership, fulfilling membership agreement requirements or enabling distance selling and other purposes related to orders, and Transaction Security Information obtained within Platform membership scope will be processed based on legal grounds that processing of personal data belonging to parties of a contract is necessary provided that it is directly related to establishment or performance of the contract and that data processing is mandatory for legitimate interests of the data controller provided that it does not harm your fundamental rights and freedoms.
To ensure transaction security on the Platform, to increase and maintain customer loyalty, your Identity Information, Contact Information, Customer Transaction Information, Order Information, and Transaction Security Information will be processed based on legal grounds that processing of personal data belonging to parties of a contract is necessary provided that it is directly related to establishment or performance of the contract and that data processing is mandatory for legitimate interests of the data controller provided that it does not harm your fundamental rights and freedoms.
If you submit a request or complaint to the Company through the Platform, your Identity Information, Contact Information, and Other Information will be processed based on legal grounds that data processing is mandatory for the legitimate interests of the data controller provided that it does not harm your fundamental rights and freedoms, for the purposes of examining and resolving your request and complaint and increasing and maintaining customer loyalty.
Your Personal Data processed within these processes is shared with IT service providers (database and server service providers, intermediary software service providers, archiving service providers, Platform service providers) from whom we receive service support regarding the software related to our systems, the execution of the Platform, and the software used, and with audit service providers within the Company's audit processes.
Due to the servers used by various software related to the Platform and service providers (database and server service providers, intermediary software service providers, archiving service providers, Platform service providers) being located abroad, your Personal Data may be transferred abroad based on your explicit consent.
Processing of Your Personal Data in Commercial Electronic Communications
If you have given your consent for Commercial Electronic Communications, your name, surname, phone number, and email address will be processed based on legal grounds that data processing is mandatory for the legitimate interests of the data controller provided that it does not harm your fundamental rights and freedoms, for the purposes of informing you about campaigns, promotions, product and service introductions conducted by the Company, receiving newsletters, presenting customer satisfaction practices, advertisements, notifications, and conducting commercial communication activities within marketing activities.
If you later refuse to receive commercial electronic communication from the Company, records related to this refusal, and information regarding the commercial electronic consent you will give if you wish to receive commercial electronic communication again after the refusal will be processed based on legal grounds that data processing is mandatory for the legitimate interests of the data controller provided that it does not harm your fundamental rights and freedoms.
If you have given your consent for Commercial Electronic Communications, for the Company to send you commercial electronic communication, your name, surname, phone number, and/or email address will be shared with the mobile media company, agency, or marketing company that the Company is receiving support from at that time regarding sending commercial electronic communication, and with IT service providers and consultants from whom support is received; information regarding your phone number and/or email address, and if applicable, the information regarding the refusal of the commercial electronic communication consent you provided to the Company and the consent you provided to receive communication again will be shared with authorized organizations according to the Regulation on Commercial Communication and Commercial Electronic Messages and intermediary service providers for information transfer to this organization, and with IT service providers and consultants from whom support is received as necessary.
Your Personal Data processed within this process is also shared with IT service providers (database and server service providers, monitoring/targeting technology support providers, marketing/advertising/analysis activity support providers, intermediary software service providers, archiving service providers) and audit service providers within the Company's audit processes.
Due to the servers used by various software related to the Platform and service providers (database and server service providers, monitoring/targeting technology support providers, marketing/advertising/analysis activity support providers, intermediary software service providers, archiving service providers) being located abroad, your personal data may be transferred abroad based on your explicit consent.
Processing of Your Personal Data in Legal Processes and Internal Activities
Your Personal Data will be processed for the purposes of using all rights of response, objection, and litigation against official institutions and organizations such as courts, enforcement offices, arbitration boards, the Personal Data Protection Authority, and the Ministry of Commerce in the event of a possible complaint or arising disputes, conducting negotiation and agreement processes related to disputes, being used as evidence in all these processes, providing necessary information if authorized public institutions and organizations request information from us, and providing necessary information to you if you request information from us or apply within the scope of your legal rights, based on legal grounds that data processing is mandatory for the establishment, use, or protection of a right and that it is necessary for the legitimate interests of the data controller provided that it does not harm your fundamental rights and freedoms.
Your Personal Data will also be processed based on legal grounds that data processing is mandatory for the legitimate interests of the data controller provided that it does not harm your fundamental rights and freedoms, to fulfill the legal obligations of the data controller within the scope of internal audit, internal control, compliance, and reporting activities.
Your Personal Data will be shared with relevant public/private institutions and organizations as necessary to fulfill our obligations arising from the legislation, including providing information to authorized and competent public institutions and organizations. Additionally, in the event of a possible complaint or arising disputes, your Personal Data will be shared with relevant public/private institutions and organizations and judicial authorities for the purposes of using our legal rights such as response, objection, and litigation rights, and conducting negotiation and agreement processes related to disputes, including mediation processes, as necessary.
Except for the cases specified in this article, if it is necessary to share your Personal Data with a third party, we will fulfill our obligation to inform you regarding that transfer specifically.
Processing of Personal Data in Case the Platform User/Member is a Legal Entity
If the Platform user/member is a legal entity, the name-surname, phone number, and email address information of the real person representative of the legal entity user will be collected through the information and documents sent from the legal entity user to the Company, and will be processed automatically based on the method and medium through which these information and documents are sent (for physical documents) and through automatic methods (for information and documents sent via electronic channels), and will be recorded in the Company's systems through automatic methods. This information will be processed based on legal grounds that data processing is mandatory for the legitimate interests of the data controller provided that it does not harm the fundamental rights and freedoms of the representative in order to establish contact with the Platform user/member.
The processed information will be transferred abroad based on your explicit consent due to the servers used by various software related to the data controller's systems and service providers (database and server service providers, intermediary software service providers, archiving service providers, Platform service providers) being located abroad.
Your Rights as Data Subject Under PDPL
Within the framework of PDPL and other applicable legislation, you have the right to:
- Learn whether your Personal Data is being processed,
- Request information if your Personal Data has been processed,
- Learn the purpose of processing Personal Data and whether they are used in accordance with the purpose,
- Know third parties to whom your Personal Data is transferred domestically or abroad,
- Request correction if Personal Data is processed incompletely or inaccurately and request notification of such transaction to third parties to whom Personal Data has been transferred,
- Request deletion or destruction of Personal Data if reasons requiring processing have disappeared despite being processed in accordance with PDPL and relevant legislation, and request notification of such transaction to third parties to whom Personal Data has been transferred,
- Object to occurrence of any result against you through analysis of processed data exclusively through automated systems,
- Request compensation for damages if you suffer damage due to unlawful processing of Personal Data.
Ways to Apply to the Company Regarding Your Rights
You can submit your applications regarding your rights specified above in accordance with the Communiqué on Application Procedures and Principles to Data Controller (in writing or through registered electronic mail (REM) address, secure electronic signature, mobile signature or via your email address previously notified to our Company and registered in our systems, together with information/documents that verify your identity to enable our Company to determine that you are the actual rights holder but do not contain any special categories of personal data (such as religion information or blood type information)) to Hasanpaşa Mah. Kahkeşan Sk. Gülizar Mahmut No: 24 İç Kapı No: 1 Kadıköy / Istanbul by physical mail and to [email protected] by electronic mail. Your applications will be concluded free of charge as soon as possible and within 30 (thirty) days at the latest depending on the nature of your request; however, if the transaction requires additional cost, you may be charged according to the tariff to be determined by the Personal Data Protection Board.
In case of any changes in data processing processes regulated under this Clarification Text, changes will be reflected in the Clarification Text as soon as possible, and you can always review the current version of the text through the Platform.