Privacy Notice on the Protection and the Processing of Personal Data
Netmera (hereinafter referred to as “Company” or “We”), has the utmost sensitivity on the lawful processing of its customers personal data.
We have prepared Netmera Privacy Notice on the Protection and the Processing of Personal Data, in order to ensure compliance with national and international legislation in effect, in particular the Law on the Protection of Personal Data (the “Law”) and the European Union General Data Protection Regulation (“GDPR”). For more detailed information about GDPR you may read the GDPR Privacy Notice published on https://netmera.com/gdpr.
The security of our customers’ personal data is at the forefront of our work. Therefore, in order to prevent any unlawful access to personal data or leak and to ensure the secure retention of personal data relating to our customers, such data are only transferred to trusted business partners and on a minimum level, by taking necessary security measures in accordance with the legislation in force.
Transparency is one of the most important subjects of our personal data protection program. In this respect, we have prepared this Notice in order to provide our customers with all possible information while we are processing personal data for the purposes of compliance with our legal obligations and to ensure a better customer experience. Detailed information regarding the types of personal data and the purposes for processing personal data are detailed under the “For Which Purposes Do We Process Your Personal Data?” heading.
Another issue that we also pay close attention to is customers’ right to have control over their personal data. We implement measures to ensure that our customers manage their preferences regarding their own personal data and highly respect our customers preferences. In this regard, you may convey your requests to us by communication channels listed under section “The Exercise of Rights by the Data Subjects”, and detailed explanations regarding the matter are provided within the section named “Rights of the Data Subjects”.
Data security, transparency and individuals’ right to have control over their personal data are fundamentals for us in ensuring compliance with the Law. In this respect, detailed information regarding the processing of your personal data are presented to your attention within this Notice.
1.How Do We Collect Your Personal Data?
We may collect and process your personal data personally, through our representatives, employees or through various channels in accordance with the regulations of our Personal Data Protection, Storage and Destruction Policy, the Law and other relevant legislation; through all kinds of written, verbal, electronic means, image recording, filling out other forms on the website or belonging to our Company, contracts, surveys, interviews, electronic/digital platforms and sites, online channels including social media platforms, e-mail, sales, marketing or support units, events or in other ways.
2.Which Personal Data Do We Collect and Process?
Personal Data Types:
• Identity Information Data that clearly belongs to an identified or identifiable natural person, which is processed partially or fully automatically or non-automatically as part of the data recording system, and contains information about the identity of the person. Name, surname, national ID number, marital status, nationality, parents’ name-surname, date of birth, place of birth, gender and other identity information and driver’s license, identity card, passport and other documents containing this information, tax number, SSI number, signature information, vehicle license plate and other information.
• Contact Information Phone number, address, e-mail address, fax number, IP address, and other information.
• Customer Information Information that clearly belongs to an identified or identifiable natural person, processed partially or completely automatically or non-automatically as part of the data recording system; information obtained and produced about the relevant person because of our commercial activities and the operations carried out by our business units within this framework.
• Financial Information Personal data processed regarding information, documents and records showing all kinds of financial results arising in accordance with the employee-employer or other commercial relationship established by the Company with the Relevant Person and bank account number, branch code, bank card information, IBAN number, credit card information, financial profile, credit rating, asset data, income information and other information.
• Visual and Auditory Information Photographs and camera recordings, audio recordings and all data and other information containing such data.
• Personal Information All kinds of personal data processed for obtaining information that shall be the basis for the protection of the personal rights of natural persons who are in a working relationship with the Personal Data Owner.
• Location Information information that determines the location of the Relevant Person while using the Company vehicles by the Relevant Person within the framework of the activities and operations of the Company or the companies and institutions in cooperation with the Company; GPS location, travel data and other information.
• Family Members and Relatives Identity information and contact information, as defined above, about the Relevant Person’s family members, (e.g. spouse, mother, father, child), relatives and other persons who can be reached in case of emergency, within the framework of the activities and operations of the Company or the companies and institutions in cooperation with the Company or in order to protect the legal and other interests of the Company and the Relevant Person.
• Special Quality Personal Information Data specified under Article 6 of the Law (health data, biometric data)
• Request/Complaint Management Information Personal data related to the receipt and evaluation of the request or complaint addressed to our Company.
Processing Personal Data Our Company processes Personal Data for specific, explicit, and legitimate purposes. In this context, Personal Data may be processed.
3.Why Do We Process Your Personal Data and What Is the Legal Basis for This Use (purpose of the processing)?
We process your personal data for the following purposes:
Obtaining information about the actions you take during your visit in order to personalize your website experience, such as saving your preferences and settings, personalizing your website experience, and collecting statistics to help us improve and further develop our websites, products and services, such as recording information needed to provide access to you, such as passwords, IP addresses and browser settings, for the operation of a website when you use the online service or access one of our websites and to comply with security and legal requirements related to the operation of our site,
Ensuring website security, website usage analysis, meeting the requests submitted via the contact form on the website, ensuring the membership of customers via the website and sending a welcome e-mail based on these memberships, calling our Company’s call center, providing call center and remote support services,
When you communicate with us online or offline in connection with a request for information to order a product or service, request support, or participate in a forum or other social networking tool, to fulfill your request, provide you with access to products or services, improve your user experience, provide support and contact you,
Conducting advertising / campaign / promotion processes, conducting marketing analysis studies, conducting activities for customer satisfaction, conducting marketing processes of products / services and ensuring the delivery of commercial messages in this context,
Providing products and services, Customizing the products and services offered in accordance with the demands, Updating and developing products and services due to customer needs / legal and technical developments, Carrying out company / product / service loyalty processes, Carrying out goods / service purchasing processes, Carrying out goods / service sales and after-sales support services and return processes, Carrying out goods / service production and operation processes, Carrying out marketing processes, Sending e-bulletins and information letters to customers within the scope of marketing, Participating in trainings, seminars or organizations organized by our Company, Carrying out customer relationship management processes,
Providing information to authorized persons, institutions and organizations in the context of fulfilling legal obligations and requests of administrative authorities, protecting the rights of the Company and its employees and defending these rights before authorized institutions and courts.
In our relationships with customers or potential customers, solution partners and suppliers, they provide us with business contact information (such as name, business contact information, employee position or title, contractors, consultants, and authorized users) for purposes such as contract management, order management, delivery of products and services, provision of support, invoicing, payment, service, or relationship management.
To ensure the physical security and supervision of locations and to ensure workplace health and safety, we record people who visit our locations (name, identity and work related contact information) and use video surveillance technology for the safety and security of people and their belongings, as well as legal regulations.
Your personal data may be processed within the scope of the execution of our company’s human resources policies, conducting employee candidate / intern / student selection and placement processes, conducting the application processes of employee candidates, fulfilling the obligations arising from the employment contract and legislation for employees, conducting the processes of fringe benefits and benefits for employees, Defining employee user account, Tracking pool vehicles, Defining work computer/phone and e-mail address, Issuing company ID and meal card, Planning human resources processes, Conducting occupational health / safety activities, Conducting performance evaluation processes, Foreign personnel work and residence permit procedures, Conducting talent / career development activities.
Also, your personal data may be processed for Execution of emergency management processes, ex-carrying of information security processes, Execution of audit / ethical activities, Execution of risk management processes, Execution of training activities, Execution of access authorizations, Execution of strategic planning activities, Execution of activities in accordance with the legislation, Fulfillment of legal and contractual obligations, Follow-up and execution of finance, legal and accounting affairs, Ensuring physical space security, Execution of assignment processes, Execution / supervision of business activities, Receiving and evaluating suggestions for improving business processes, Organization and event management, execution of contract processes, execution of sponsorship activities, execution of supply chain management processes, execution of remuneration policy, execution of investor relations, Carrying out management activities Carrying out internal audit / investigation / intelligence activities, Following up requests / complaints, Providing information to authorized persons, institutions and organizations, Carrying out social responsibility and civil society activities.
4.To Whom, Why and Where Do We Transfer Your Personal Data?
Personal Data held by our Company may be transferred to the following real or legal Third Parties in or outside the country in accordance with the regulations of the Law on the transfer of data, with your explicit consent or by complying with the exceptions in the law (performance of the contract, legitimate interest, etc.) and the obligations required by the Law.
Consultants / Service Providers : Accounting Firm, Agencies, BES Firm, Life Insurance Firm, Legal Consultants, Health Insurance Firm, Payroll Company, Financial Consultancy Firm, etc,
Suppliers: Personal Data may be transferred to the companies/persons from whom services are received as specified in this article within the scope of the products, services, services received and the commercial, legal, contractual relationship established with these persons, limited to the data and purposes that will need to be processed.
Employees: In order to properly fulfill the duties undertaken by our Company and employees within this scope and to ensure communications, Personal Data belonging to other employees and other persons who are required to be in contact with employees in order to fulfill their duties may be shared with employees.
Event Sponsors: Personal Data may be transferred to sponsors to be used for the purpose of fulfilling sponsorship activities and obligations and limited to what is necessary to achieve this purpose.
Natural Persons or Private Law Legal Entities: Personal Data may be transferred to private law persons legally authorized to request information and/or documents from our Company, limited to their requests and legally required to be transmitted.
Business Partners and Cooperating Companies: Your data may be transferred to business partners that we have authorized, companies operating on behalf and account of our Company, in order to establish a business partnership with our representatives and / or to fulfill the purpose of the cooperation, in accordance with this purpose and limited to this purpose.
Shareholders/Affiliates: Personal Data may be shared with shareholders limited to the purposes of monitoring activities, determining and developing commercial strategies, auditing and informing shareholders.
Customers: Personal Data of employees may be shared with customers in order to provide products and services received by customers within the framework of the relationship between us and customers.
Judicial Authorities and Public Authorities: Personal Data may be transferred to legally authorized public institutions and organizations, limited to their requests and legally required to be transmitted.
Audit Firms
R&D Management Company
Banks and Financial Institutions Your personal data shall be processed by taking all necessary information security measures, provided that they are not used outside the purposes and scope notified to you, and shall be stored and processed for the legal retention period or, if no such period is stipulated, for the period required by the purpose of processing. When this period expires, your personal data will be removed from our Company’s data streams by deletion, destruction or anonymization methods.
5.How long will you retain my data?
Our Company stores Personal Data in accordance with the periods stipulated in the laws and other legislation. If there is no time regulation in the laws and other legislation regarding how long Personal Data should be stored, Personal Data is processed for the period until the realization of the purpose of processing the Personal Data of the activity carried out when our Company processes that Personal Data, and then it is deleted, destroyed or anonymized.
6.Principles relating to personal data privacy
Our company acts in accordance with the principles stated below in all data processing activities. “lawfulness, fairness and transparency”, “purpose limitation”, “data minimisation”, “accuracy”, “storage limitation”, “integrity and confidentiality” and “accountability”.
7.Use of cookies
Netmera collects information using “cookie” technology, JavaScript tags and other technologies when End Users access the Websites. Netmera uses both session cookies (which expire once End Users close their browser) and persistent cookies (which stay on End Users’ computer until deleted by them) to help us collect information and to enhance End Users’ experience using the Websites. If End Users do not want us to place a cookie on their hard drive, they may turn that feature off on their computer.
For further information regarding cookies, please refer to the Entire Cookie Privacy Notice located at https://netmera.com/cookie-policy-eu/.
8.Use of Digital Platforms
Your personal data may be processed while your use of Digital Platforms to manage and operate the Website, to perform activities for optimizing and improving the user experience related to the Website and Application, to detect in what ways the Website is being used, to support and enhance the use of location based tools, to manage your online accounts and to inform you about the services offered near you.
In case you desire to benefit from the offered product and services, your personal data will be processed only to make you get such product and services.
9.What are Your Rights as Data Subjects?
In accordance with Article 11 of the Law, data subjects are entitled to the following rights:
- Learn whether data relating to him/her are being processed;
- Request further information if personal data relating to him/her have been processed;
- Learn the purpose for the processing of personal data and whether data are being processed in compliance with such purpose;
- Learn the third-party recipients to whom the data are disclosed within the country or abroad,
- Request rectification of the processed personal data which is incomplete or inaccurate and request such process to be notified to third persons to whom personal data is transferred;
- Request deletion or destruction of personal data in the event that the data is no longer necessary in relation to the purpose for which the personal data was collected, despite being processed in line with the Law and other applicable laws and request such process to be notified to third persons to whom personal data is transferred;
- Object to negative consequences about him/her that are concluded as a result of analysis of the processed personal data by solely automatic means;
- Demand compensation for the damages he/she has suffered as a result of an unlawful processing operation.
10.The exercise of rights by the data subjects
You can easily use your rights mentioned above and easily communicate the related requests to us via contact information below.
Data subjects’ requests concerning the above-listed rights shall be concluded by us within thirty days at the latest, in accordance with the limitations provided by the Law.
In principle, data subject requests shall be concluded free of charge. However, Netmera reserves its right to demand a fee from the tariff specified by the Board, in case the request requires additional costs.
Our Company may request certain information from the data subject in order to determine that the applicant is in fact the Data Subject, and additional questions can be directed to the applicant to clarify matters regarding the applications.
Netmera
BUDOTEK Dudullu OSB Mah. DES 2. Caddesi No:8 D:8, 34776 Ümraniye/İstanbul
Turkey
Website: https://netmera.com
Email: privacy@netmera.com
Phone number: +908507578321
11.Data security
We take all appropriate technical and organizational measures to safeguard your personal data and to mitigate risks arising in connection with unauthorized access, accidental data loss, deliberate erasure of or damage to personal data.
In this respect our Company;
- Ensures data security by utilizing protection systems, firewalls and other software and hardware containing intrusion prevention systems against virus and other malicious software,
- Access to personal data within our Company is carried out in a controlled process in accordance with the nature of the data and on a strict need-to-know basis,
- Ensures the conduct of necessary audits to implement the provisions of the GDPR, in accordance with Article 32 of the GDPR,
- Ensures the lawfulness of the data processing activities by way of internal policies and procedures,
- Applies stricter measures for access to special categories of personal data,
- In case of external access to personal data due to procurement of outsourced services, our Company obliges the relevant third party to undertake to comply with the provisions of the GDPR,
- It takes necessary actions to inform all employees, especially those who have access to personal data, about their duties and responsibilities within the scope of the GDPR.
12.Definitions
- Explicit consent: Consent that is provided for a specific subject, upon being informed and freely given.
- Anonymization: Rendering personal data by no means identified or identifiable with a natural person even by linking with other data.
- Related person/Data subject: Refers to the natural person whose personal data are processed.
- Personal data: Refers to any information relating to an identified or identifiable natural person.
- Special Categories of Personal data: Refers to data that has been subjected to a more stringent protection regime under the Law which may cause the Data Subject to be victimized or discriminated against in cases of disclosure or loss.
- Processing of personal data: Refers to any operation that is performed upon personal data such as collection, recording, storage, preservation, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization or blocking its use by wholly or partly automatic means or otherwise than by automatic means which form part of a filing system.
- Data recording system: Refers to the registration system in which personal data is configured and processed according to certain criteria.
- Data controller: The natural or legal person determining the purposes and means of the processing of personal data and who is responsible for the establishment and management od a data recording system.
