KVKK

I. Privacy Notice

1. Introduction

This privacy notice has been prepared by Estora İlaç ve Ecza Depoculuk A.Ş in order to ensure that the personal data of the natural persons who are our guests, and of the personnel, employees or representatives of our corporate guests, is processed in accordance with the Constitution of the Republic of Türkiye, the international conventions on human rights to which our country is a party, and the relevant legislation, above all Personal Data Protection Law No. 6698 (“KVKK”), and to ensure that the relevant persons whose data is processed can exercise their rights effectively. All personal data shared with our companies may be processed lawfully, in a manner connected with and proportionate to our activity and service purposes.

2. Definitions

The concepts of personal data, special categories of personal data and data processing used in this privacy notice are used on the basis of the definitions in the KVKK. Under the KVKK, “personal data” means any information relating to an identified or identifiable natural person; “processing of personal data” means any operation performed on data, such as obtaining, recording, storing, retaining, altering, reorganising, disclosing, transferring, sharing, acquiring, making available, classifying or preventing the use of personal data, wholly or partly by automated means or by non-automated means provided that it forms part of a data filing system; and “special categories of personal data” means data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership of an association, foundation or trade union, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data.

3. Principles for Processing Personal Data

Pursuant to Article 4 of the KVKK, the personal data of the data subject will be processed by the Companies acting as data controller, within the scope of the purposes set out below, in accordance with the rules of lawfulness and fairness; accuracy and, where necessary, being up to date; being processed for specific, explicit and legitimate purposes; being connected with, limited to and proportionate to the purposes for which they are processed; and being retained for the period stipulated in the relevant legislation or required for the purpose of processing.

4. Purposes of Processing Personal Data

Your personal data;

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  Fulfilling the obligations arising from the contractual relationship between the Companies and the customer/visitor, and fulfilling other legal, administrative or contractual obligations;

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  Evaluating complaints, requests and wishes for the sake of customer/visitor satisfaction;

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  Developing services and campaigns tailored to customers/visitors in order to improve the customer/visitor service experience;

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  Determining the type of communication activities to be carried out towards customers/visitors;

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  Resolving disputes that may arise in the future between the Companies and the customer/visitor;

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  Enabling the Companies to exercise and protect the rights granted to them on legal grounds;

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  Fulfilling the statutory obligations of the Companies;

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  Assessing customer/visitor satisfaction

will be processed for these purposes, in accordance with the conditions for processing personal data set out in Articles 5 and 6 of the KVKK.

5. Transfer of Your Personal Data

Our companies act in accordance with the arrangements provided for in the KVKK regarding the transfer of personal data. Save for the exceptional cases set out in the legislation, personal data and special categories of data are not transferred by us to other natural or legal persons without the explicit consent of the data subject. In the exceptional cases provided for by the KVKK and other legislation, the utmost care is taken to comply with the forms and limitations stipulated in the legislation when transferring personal data to authorised administrative or judicial institutions or private organisations.

Your personal data,

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  To authorised official institutions and organisations and to private persons authorised by law, for the purpose of fulfilling a statutory obligation,

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  To the transport companies with which we have agreements, for the organisation of airport transfers in line with the requests of our corporate or individual customers/visitors,

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  To the relevant judicial authorities, for the purpose of conducting or following up judicial proceedings,

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  To its affiliates, subsidiaries, group partners and overseas stakeholders,

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  Anonymously, with the data management platforms with which it has a contractual relationship,

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  In cases such as merger, demerger or acquisition, to the airline companies arising as a result of those situations and to our business partners operating in the same sector,

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  To companies and online service providers operating in the sectors of information technologies; education; electricity and electronics; finance; food; construction; culture, arts and design; media, communication and publishing; automotive; health and social services; textiles, ready-to-wear and leather; trade and retail; tourism, aviation, accommodation, food and beverage services; transport, logistics, communications and telecommunications

may be transferred within the framework of the procedures and principles set out in the relevant legislation and in accordance with the conditions and purposes for transferring personal data specified in Articles 8 and 9 of the KVKK.

6. Method of Collecting Personal Data / Special Categories of Personal Data and the Legal Grounds

Your personal data varies depending on the service provided by our companies or on the commercial activity, and is collected by automated or non-automated means; directly by our companies and by the call centres from which we receive services, through the website, the call centre, mobile applications and social media channels, verbally, in writing or electronically. The contracts you have concluded with our companies and the personal data you provide at every stage of this process will be processed and kept up to date for as long as you benefit from the products and services offered by our companies and, following the termination of those contracts, for the periods stipulated in the relevant legislation or for which the Companies have a legally legitimate interest in retaining the information.

The legal grounds for the processing of your personal data by the Companies are the explicit consent given by the Customer in the Explicit Consent Statement pursuant to the first paragraph of Article 5 of the KVKK, and the cases constituting an exception to explicit consent specified in subparagraphs (a), (c), (ç), (e) and (f) of the second paragraph of Article 5 and in the third paragraph of Article 6 of the KVKK. Your personal data is collected by our companies on the stated legal grounds, in accordance with all legislation in force, and for the purposes set out in Articles 4 and 5 of this Privacy Notice.

7. Rights of the Data Subject Set Out in Article 11

By applying to the Companies acting as data controller, data subjects have the right to: learn whether their personal data is being processed and, if it has been processed, to request information about it; learn the purpose of processing their personal data and whether it is used in accordance with that purpose; be informed about the third parties in Türkiye or abroad to whom their personal data is transferred; request the correction of their personal data if it has been processed incompletely or incorrectly; request the erasure or destruction of their personal data within the framework of the conditions set out in Article 7 of KVKK No. 6698; request that the operations carried out pursuant to subparagraphs (d) and (e) of Article 11 of the KVKK be notified to the third parties to whom their personal data has been transferred; object to a result arising against the person themselves through the analysis of the processed data exclusively by automated systems; and request compensation for the damage suffered as a result of the unlawful processing of personal data.

Explicit Consent

I have read and understood the matters set out in the privacy notice above, prepared in accordance with Personal Data Protection Law No. 6698. I freely and explicitly consent to the processing of my personal data collected by the methods stated in the privacy notice within the scope of the purposes and principles stated in that notice; to its transfer, including transfer abroad, within the scope of the stated purposes; and to the retention and processing of that data, following the termination of the contractual relationship, for the periods stipulated in the relevant legislation or for which the Companies have a legally legitimate interest in retaining the data.