Data Protection


STATEMENT ON THE PROTECTION AND PROCESSING OF CUSTOMERS’ PERSONAL DATA

Maintaining the security of your personal data is a priority for us and we are committed to respecting your privacy rights. We are also dedicated to being transparent about what data we collect about you, how we handle and use it. Your personal data is considered sensitive by us and consequently we have a particular sensitivity to the protection of your personal data. Therefore, keeping in mind these considerations, we, TØMPSEN E-TİCARET (shall hereinafter be referred to as (“TØMPSEN”, “we” or “us”), have prepared this Disclosure Statement on the Protection and Processing of Customers’ Data (“Disclosure Statement”) pursuant to article 10 of the Law No 6698 on the Protection of Personal Data (the “Law”) and the Communiqué on Procedures and Principles for Compliance with the Disclosure Obligations (the “Communiqué”) in our capacity as the Data Controller within the meaning of the Law referred to above to provide you with information about how we use your data, what personal data we collect, how we ensure your privacy is maintained and your legal rights relating to your personal data.

 

We reserve the right to update this “Disclosure Statement on the Protection of Personal Data”, at any time, within the framework of the amendments that may be introduced by the relevant legislation and to make amendments to this disclosure statement from time to time in the event of a change in the purpose of collecting and/ or transferring personal data as well as in line with any future change regarding the method of collecting personal data. While processing your personal data as a customer we also comply with the requirements for “the Privacy and Cookie Policy” posted on our Site. For more detailed information on this subject please refer to our main page.

Following are some definitions of the terms used in this disclosure statement within the framework of the Law on the Protection of Personal Data:

Personal Data: shall mean any information relating to an identified or identifiable natural person;

Processing of Personal Data: shall mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

Data Subject: shall mean a natural person/data owner (Customer) whose personal data is processed

Data Controller: shall mean the natural or legal person (i.e. TØMPSEN), public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of personal data and that is responsible for the establishment and management of the data filing system;

Personal Data filing system (“filing system’’): shall mean any structured set of personal data which is accessible according to specific criteria, whether centralized, decentralized or dispersed on a functional or geographical basis;

Law: shall mean Law no 6698 on the Protection of Personal Data;

Explicit Consent: shall mean a consent that is related to a specific issue, based on information and expressed with free will;

Your personal data processed within the scope of this Disclosure Statement shall include the following:

Personal Identity Information: Name – surname, Personal identification number, Tax identification number;

Contact Details: Phone number, Business address, Home address, E-mail address;

Finance: Bank information, Credit card data (if any);

Other Data: Customer transaction data, Legal action data, Internet activity log records on website, Personal identifiable information collected during e-commerce transactions.

(1) Processing of your personal data

We will collect and process your personal data in accordance with the purposes specified below according to the methods specified in this Disclosure Statement to allow us to perform the required operations to meet and comply with our legal obligations under the applicable legislation. Your personal data will be processed in accordance with the data processing requirements set forth in the Law No 6502 on Consumer Protection and other relevant applicant legislation and articles 5 and 6 of the Law taking and implementing the technical and administrative to ensure the data security provided that will not be used outside the purposes and scope specified in this Disclosure Statement.

Your personal data will be stored for a period of time until it is required for the due purposes for which it was collected and upon expiration of this period it will be automatically deleted, erased or rendered permanently anonymous provided that the statutory data retention period is not exceeded.

In addition to all the foregoing, pursuant to article 4 of the Law no 6698 on the Protection of Personal Data (“LPPD”) TØMPSEN has an obligation to keep your personal data accurate and up-to-date. In this respect, you as a customer of TØMPSEN, please provide us with your accurate and up-to-date personal data so as to enable TØMPSEN to meet and comply with its obligations arising under the applicable legislation. In this context, we kindly ask you to inform us within the shortest possible time in case of any change in your personal data for any reason whatsoever by sending an email to us at hello@tompsen.com by typing the phrase “Updating My Personal Data” in the subject section of the email to update your personal data. We would like to emphasize that it is important to understand that your personal data has not yet been updated until you receive a response email from us confirming that your personal data has been updated. In such a case, we kindly ask you to send us emails repeatedly until you receive a response from us.

 

(2) To whom and for what purposes your personal data may be transferred

Your personal data that we have collected and processed in accordance with the methods, principles and purposes set forth in this Disclosure Statement may be transferred to the directors and officers, cargo companies, courier companies, suppliers in accordance with the nature of the services provided. However, your personal data may be shared with or transferred to courts and other competent public authorities and governmental bodies due to and only limited to our legal obligations.

Cross-Border Transfer of Personal Data

Personal data collected by TØMPSEN may not be transferred to persons resident abroad.

All necessary technical and legal measures are taken and implemented to prevent right violations during the transfer of data to third parties. However, TØMPSEN is not responsible and may not be held liable for any right violations and/or data security breaches that may occur due to data protection policies of the data- acquiring third party as well as that may occur in the risk area under its responsibility.

(3) Collection of your Personal Data

Your personal data may be collected by us, by filling out the form on the website within the scope of your purchase. We will collect your personal data and process it in accordance with the terms and conditions and purposes set forth in articles 5 and 6 of the Law and in line with legal reasons and purposes specified in this Disclosure Statement.

The legal reasons for processing your personal data are the following: being necessary for TØMPSEN to fulfil its legal obligations as a data controller, being necessary for the establishment and execution of the agreement and without prejudice to your fundamental rights and freedoms, being compulsory for TØMPSEN’s statutory interests

(4) The Purposes for which your personal data is processed

The purposes for which your personal data is processed include but not limited to ensuring the performance of the contracts drawn up and concluded between you and TØMPSEN at the time when you purchase a product or a service from TØMPSEN or participate in campaigns conducted by us and/or for any other reason whatsoever, to provide you with our products/ services, or respond any queries you may have, to get to know our customers within the limits of the personal data that you have consented for us to process and your personal data may also be used within the scope of the activities aimed at improving the quality of the services that we provide you with such as ensuring the availability of the right product, maintaining the business relationship, providing you with information about current products.

However, in any case we process all of your personal data you may provide us in accordance with the terms and conditions set forth in the relevant distance selling contract and as provided for in the relevant applicable legislation, in accordance with the legislation and/or the consent you have given for the collection of your data.

(5) Your Rights

You have the following rights under article 11 of the Law on the Protection of Personal Data;

• to learn whether or not the personal data relating to you are processed,

• if processed, to request information with regard to processing,

• to learn purposes of the processing and whether they are used for such purpose or not,

• to request the restriction of processing under certain circumstances,

• to know the third persons within or outside the country to whom the personal data are transferred,

• to request correction and update of the personal data if the data is processed incompletely or inaccurately,

• to request deletion or destruction of the personal data when purposes of processing cease to exist,

• to request notifying third parties to whom the personal data are transferred, about deletion, destruction and correction,

• to object to negative consequences about you that are concluded as a result of analysis of the processed personal data by solely automatic means, and

• to claim compensation for the damage arising from the unlawful processing of your personal data.

We would like to inform you that in your capacity as a data subject, you are entitled to convey us your request regarding exercising any of your rights either by downloading the application form created by TØMPSEN from our website or receiving the same by hand and either by personally delivering the application form with wet-ink signature or sending it by mail to our registered office located at ’’Maslak Mah. Sanatkarlar Sk. Eclipse Maslak No: 2 E İç Kapı No: 9 Sarıyer/ İstanbul’’ or to our electronic mail address at hello@tompsen.com through the applicants’ e-mail address registered in our system. Your requests filed with TØMPSEN will be reviewed, concluded and responded, free of charge, within 30 days at the latest depending on the nature of the request. As regards to your requests with respect to your rights as a data subject, in accordance with the Communiqué on the Procedures and Principles regarding the Application to the Data Controller, in cases where a response, in writing will be sent to you, you will not be charged any fees up to the first 10 (ten) pages, however, you may be charged a processing fee of 1 TL for each page exceeding the limit of 10 (ten) pages. On the other hand, in cases where the response to your application will be provided in a recording medium such as CD or flash disk, the process fee to be charged by TØMPSEN, in its capacity as the Data Controller, may not exceed the cost recording medium.

Respectfully submitted for your information