Privacy and Protection of Personal Data

Note: This is an unofficial translation provided for information only. The binding text is the Turkish original, available on the Turkish version of this page.

Generally

ASR International Trade Dış Ticaret LTD. ŞTİ. (Clef Trade) collects access data through cookies on the website www.cleftrade.com (the “Website”). This Cookie Policy has been prepared to inform visitors to our Website about the cookies used by Clef Trade and the purposes for which those cookies are used.

The Cookie Policy may be amended where deemed necessary in line with applicable legislation and Clef Trade practice. The current version of the text can always be found on our Website. For detailed information on the processing of your personal data, please review the Clarification Text on the Protection of Personal Data.

2. Types of Cookies and Their Purposes

Cookies are text files placed on visitors’ computers by the websites they visit. They are widely used on almost all websites so that sites work effectively and in line with visitors’ preferences, and to provide information to website administrators.

Clef Trade monitors your browsing information on the site in order to offer you special promotions, campaigns and marketing offers, to improve the content of the website or mobile application for you, and to determine your preferences. We use cookies to identify our visitors’ preferences, to detect requests for a particular page, to improve the user experience of our Website, to keep our services secure, and to carry out online behavioural advertising for our users.

Our Website uses cookies from Google Analytics, an analytics service provided by Google Inc. (“Google”), and from Yandex.Metrica, an analytics service owned by YANDEX LLC (“Yandex”). These services use cookies — text files saved on your computer that allow your use of the website to be analysed. The information generated by the cookies about your use of the website is transmitted to a Google server in the USA and stored there, and to a Yandex server in Russia and stored there. On the instructions of the operator of this website, this information is used to evaluate your use of the website and to prepare reports in order to provide related services. If you do not want these cookies to be stored, you can adjust your browser accordingly.

3 - How can you prevent the use of cookies?

The use of cookies allows the Website to serve you better, but you can prevent their use if you wish. Please note, however, that in this case the site may not function fully and you may not be able to benefit from all of its features.

To prevent the use of cookies you need to change the settings of your internet browser. These steps vary depending on the device and browser you are using. Below is information on the steps to follow in different browsers:

Internet Explorer

1. Open the desktop and tap or click the Internet Explorer icon on the taskbar.
2. Tap or click the Tools button, then Internet options.
3. Tap or click the Privacy tab, then move the slider up under Settings and tap or click OK to block all cookies.

Microsoft Edge

1. Click the three-dot menu in the upper right corner of your Microsoft Edge browser and go to Settings.
2. Select “Choose what to clear” in the window that appears, then select the items you want to clear.
3. There are several items here; select the ones you want and start the clearing process.

Google Chrome

1. Open Chrome on your computer.
2. Click More, then Settings, in the top right.
3. Click Advanced at the bottom.
4. Under “Privacy and security”, click Content settings.
5. Click Cookies.
6. Under “All cookies and site data”, search for the Website’s name.
7. Click the Remove icon to the right of the site.

Mozilla Firefox

1. Click the Firefox menu button and select Options.
2. Select the Privacy & Security panel and go to the History section.
3. Set Firefox to use custom settings for history.
4. Click the “Show cookies…” button. The Cookies window will appear.
5. In the Search field, type the name of the site whose cookies you want to delete. Matching cookies will be displayed. Select the cookie or cookies you want to delete and click “Remove selected”.
6. Close the Cookies window with the Close button, then close the about:preferences page.

Safari

1. Select Safari > Preferences.
2. Click Privacy.
3. Click Manage Website Data.
4. Select one or more websites, then click Remove or Remove All.

Further information on how to do this in other major browsers can be found in your browser’s settings.

3. Cookie Management

Many internet browsers are set to accept cookies automatically by default. If you do not want these tools to be used, you can disable them in your browser settings. We would point out, however, that in this case you may not be able to use all functions of our Website to their full extent.

Clarification Text on the Processing of Personal Data

The protection of personal data is among the top priorities of ASR INTERNATIONAL TRADE DIŞ TİCARET LTD. ŞTİ. (“Clef Trade”). Accordingly, in order to fulfil the disclosure obligation arising from Article 10 of the Law on the Protection of Personal Data No. 6698 (the “KVKK” or “Law”) and the Communiqué on the Procedures and Principles to be Complied With in Fulfilling the Obligation of Clarification (the “Communiqué”), Clef Trade provides the following explanations for the attention of our customers, our suppliers and all interested parties who use our website www.cleftrade.com, our micro sites and our applications.

1. Which Personal Data Do We Process?

“Contact Us” Application

In order for you to contact us via the Website, the following data is processed:

• Identity Data: your name and surname.
• Contact Data: contact details such as your e-mail address, telephone number and address information.
• Other Data: data relating to your message and the information you provide in the message content.
• Internet Traffic Data: device identification information, connection status, network access, storage information and battery information; cookies, IP addresses, router headers, data identifying your web browser and its version; web beacons and tags; browsing and click information (log records) for the site and the application; and your location information.

2. Purposes of Processing Your Personal Data

Your personal data is processed within the framework of the services offered by Clef Trade and its field of activity; lawfully and in accordance with the rules of good faith; accurately and, where necessary, kept up to date; for the specific, explicit and legitimate purposes set out in this Clarification Text and within the scope of Clef Trade’s personal data processing purposes; in a manner connected with, limited to and proportionate to the purposes for which they are processed; and retained for the period required for those purposes or stipulated in the relevant legislation.

Clef Trade may record, store, update, disclose, transfer to third parties, classify and process your personal data in the cases and to the extent permitted by legislation. In this context, your personal data is processed for the following limited purposes:

• recording the information necessary for communication with Website visitors and/or customers;
• providing the features of the services requested by customers;
• evaluating customer complaints and suggestions regarding our products and services;
• conducting communication activities;
• receiving and evaluating suggestions for the improvement of business processes;
• carrying out after-sales support services for goods and services;
• managing customer relationship management processes;
• following up requests and complaints;
• preparing all records and documents that will form the basis of transactions in electronic (internet, mobile and similar) environments;
• fulfilling our obligations arising from the KVKK and other applicable legislation, and exercising our rights arising from that legislation.

3. How and On What Legal Bases Do We Collect Your Personal Data?

We collect your Identity Data, Contact Data and Other Data by fully or partly automated means and/or by non-automated means — through registration on the website, through data transmitted to us by you or on your behalf, and verbally, in person or electronically — on the legal bases set out below.

This data is collected automatically when you contact us through the website, on the legal bases that processing the personal data of the parties to a contract is necessary provided that it is directly related to the establishment or performance of that contract under Article 5 of the KVKK; that data processing is mandatory for the establishment, exercise or protection of a right; and that it is necessary for the data controller to fulfil its legal obligations.

There are cookies on our website in order to provide a better service to our visitors and customers. You can find detailed information about cookies in our Cookie Policy.

In addition, if you receive a newsletter or promotional e-mail from Clef Trade, your personal data is also processed using tags, personalised links and similar technologies in order to determine whether the e-mail was opened and which links you clicked.

Because we are obliged to retain your Internet Traffic Data within the framework of Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications and the related legislation, we collect and store the IP number of the computer from which you access our website, your browsing and click information within the application (log records) and the location information from which you open the application, on the legal basis that this is necessary for the data controller to fulfil its legal obligation.

On the basis of your explicit consent and the applicable legal grounds, we also collect and store your personal data for the purposes of providing personalised advertising, campaigns and other benefits; customer segmentation based on the data obtained; survey and telesales applications; developing and improving customer data quality; loyalty transactions for customer management; cross-selling; designing and managing win-back actions for lost customers; and executing advertising, campaign and promotional processes and the marketing processes for products and services.

4. Security of Your Personal Data

All personal data and information shared with Clef Trade is stored as e-mail correspondence while we are in contact with you. In this context, Clef Trade uses the technologies necessary to prevent unauthorised access to and use of personal data, stores personal data in computer systems with limited access, uses Secure Sockets Layer (SSL) and similar encryption methods, maintains the organisation necessary to protect the confidentiality and integrity of personal data, and takes all necessary technical and administrative measures in this regard.

5. Transfer of Your Personal Data

Personal data is shared with courts and other public institutions because of, and limited to, our legal obligations. Your personal data may be shared with the relevant judicial and administrative authorities — in particular the General Directorate of Security and the public prosecutor’s office — as well as with authorised regulatory and supervisory public institutions and organisations, in the event of any dispute, the investigation or prosecution of a crime, or any audit or request.

The personal data you provide by completing the contact form is shared, within the limits stipulated by legislation and in order to carry out our commercial activities, provide the services we undertake and control the quality of those services, with the domestic and foreign institutions and organisations we cooperate with, with various business partners and with authorised manufacturers, for the following purposes:

• integration of commercial electronic message sending and the Message Management System (“İYS”);
• managing the website;
• storing requests and customer contact information;
• resolving complaints;
• carrying out order shipments;
• providing better service and customer satisfaction.

Because the servers of some of the business partners to whom personal data is transferred for the purposes stated above are located abroad, transfers of personal data to those business partners are based on your explicit consent. If you do not consent to the transfer of your data abroad, we will not be able to receive your requests through the contact form. In that case you may also contact us in writing at “Mimar Sinan Mah., Çolpan Sk. Uzunlar Apt. B Blok No:4 Kat:2 Daire 6, Çekmeköy/İstanbul”.

6. Your Rights Regarding Your Personal Data

In accordance with the Law, we would remind you that you have the right, in respect of your personal data:

• to learn whether it has been processed;
• to request information if it has been processed;
• to learn the purpose of processing and whether the data is used in accordance with that purpose;
• to learn the third parties in Türkiye or abroad to whom it has been transferred;
• to request correction if it has been processed incompletely or incorrectly;
• to request its deletion or destruction within the framework of the conditions stipulated in Article 7 of the Law;
• to request that the transactions carried out be notified to the third parties to whom the data has been transferred;
• to object to a result being reached against you through analysis exclusively by automated systems;
• to claim compensation for damage suffered as a result of processing in breach of the Law.

You may submit requests regarding the rights listed above to Clef Trade in writing. Clef Trade concludes your request free of charge within 30 (thirty) days at the latest. If, however, the transaction incurs an additional cost, Clef Trade will charge the fee in the tariff determined by the Personal Data Protection Board.

In order to exercise the rights stated, you must submit your request in accordance with Article 13 of the Law in writing to Clef Trade’s address at “Mimar Sinan Mah., Çolpan Sk. Uzunlar Apt. B Blok No:4 Kat:2 Daire 6, Çekmeköy/İstanbul”, including your name and surname and your signature; your Turkish ID number if you are a citizen of the Republic of Türkiye, or your nationality, passport number or identity number if you are not; and the subject of your request together with the information and documents necessary to establish your identity. You may also contact us at info@cleftrade.com.

7. Notification of Changes

We are aware of your rights under the KVKK and of Clef Trade’s obligations. We would like to inform you that we process your personal data with this awareness and to the extent required by legislation, that we may update this information on our page from time to time in the event of legal changes, and that you can follow those updates on this page at any time.

8. Keeping Personal Data Up to Date

In accordance with Article 4 of the KVKK, Clef Trade has an obligation to keep your personal data accurate and up to date. In this context, in order for Clef Trade to fulfil its obligations arising from current legislation, accurate and up-to-date data must be shared with Clef Trade. In the event of any change in your personal data, we ask you to update it by contacting us through the communication channels mentioned above.