Customer Privacy Notice Pursuant to Personal Data Protection Legislation
Dear Concerned Party,
Bor Şeker A.Ş. (“Bor Şeker” or the “Company”), as the data controller, hereby informs you that the personal data obtained from you within the scope of our activities and the legal relationship established with you will be processed, recorded, stored, and retained in accordance with the purposes specified under the Law No. 6698 on the Protection of Personal Data (“KVKK”), in a limited and proportionate manner, by keeping the data accurate and up-to-date; such data may be shared with authorized institutions entitled to request personal data by law and transferred to third parties in accordance with the conditions prescribed by KVKK.
Definitions Related to KVKK
For the purposes of applying the KVKK;
- Anonymization: The process of rendering personal data in such a way that it cannot be linked to an identified or identifiable natural person even when combined with other data,
- Data Subject: The natural person whose personal data is processed,
- Personal Data: Any information relating to an identified or identifiable natural person,
- Processing of Personal Data: Any operation performed on personal data such as collection, recording, storage, retention, alteration, rearrangement, disclosure, transfer, acquisition, classification, or prevention of use, whether by automatic means or not,
- Board: The Personal Data Protection Board,
- Institution: The Personal Data Protection Authority,
- Data Processor: The real or legal person who processes personal data on behalf of and under the authorization of the data controller,
- Data Recording System: The system where personal data is processed according to certain criteria,
- Data Controller: The real or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system,
- Sensitive Personal Data: Personal data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, attire, membership to associations, foundations or trade unions, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data.
What is Personal Data? Which Personal Data is Processed?
Personal data refers to any information that identifies or can identify you. This includes, but is not limited to, your identity information such as your name, surname, Turkish Identification Number, address, phone number, and bank account details. Data concerning your race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, association or union memberships, health, sexual life, criminal records, biometric and genetic data are considered sensitive personal data. Bor Şeker does not process any sensitive personal data.
Personal data processed by our Company related to individual customers, their authorized representatives, or employees are detailed below:
| Data Category | Personal Data Processed | Processing Purposes | Legal Grounds for Processing |
|---|---|---|---|
| Identity | Name, Surname, Turkish ID No, Signature, Signature Circular | Conducting product sales processes; operational and audit activities; sales management; customer relations management; production and operational processes; contract management; communication activities; complaint/follow-up management | Necessity for the establishment or performance of a contract; explicit consent of the data subject; compliance with legal obligations |
| Contact | Phone number, Email address, Address | Product sales; operational and audit activities; customer relations management; communication activities; complaint/follow-up management | Same as above |
| Financial | Tax certificate, Customer data form, IBAN | Conducting sales processes; operational and audit activities; financial and accounting transactions; contract management | Same as above, including legal obligation and rights protection |
| Customer Transactions | Request details | Sales management; customer relations; contract management; communication; complaint/follow-up | Contract necessity; explicit consent |
How Do We Collect and Process Your Personal Data?
Your personal data is collected and processed through various means, including but not limited to:
- During product sales and related contract signing,
- Through submission and processing of order forms and related communications,
- During logistics and transportation activities,
- When handling and following up on customer requests and demands,
- Throughout payment and accounting procedures,
- By verbal, written, electronic, automated, or manual means.
How is the Security of Your Personal Data Ensured?
Bor Şeker places great importance on maintaining the confidentiality and security of your personal data. Necessary technical and administrative measures are taken to protect personal data against unauthorized access, damage, loss, or disclosure. These include system controls, data access restrictions, secure data transfers, business continuity measures, and other institutional controls.
Do We Transfer Your Personal Data to Third Parties or Abroad?
Your personal data will be securely kept and processed lawfully. Under the conditions allowed by law and KVKK Article 8, your data may be shared with:
- Authorized public institutions and organizations within Turkey,
- Relevant suppliers for planning and tracking production processes, material procurement, and supply activities,
- Logistics companies for communication during delivery processes,
- Legal firms providing consultancy services for litigation and enforcement proceedings,
- Potential buyers in the context of potential investments, mergers, and acquisitions,
Furthermore, when communication is conducted using foreign-based email or online instant messaging services, your name, surname, email address, and customer transaction information may be transferred abroad with your explicit consent pursuant to KVKK Article 9.
Your Rights as a Data Subject and How to Apply
You have the following rights regarding your personal data processed by Bor Şeker:
- To learn whether your personal data is processed or not,
- To request information if your data is processed,
- To know the purpose of processing and whether your data is used accordingly,
- To learn the third parties in Turkey to whom your data is transferred and the categories of data transferred,
- To request correction of incomplete or inaccurate data,
- To request deletion or destruction of data and notification to third parties to whom the data was transferred,
- To object to processing based solely on automatic systems that result in adverse consequences for you,
- To request compensation for damages caused by unlawful processing.
How to Submit Your Requests
You may submit your requests by filling out the application form available on our website and delivering it in writing either by hand, post, cargo, via notary, secure electronic signature, mobile signature, registered electronic mail (KEP), or from your previously registered email address to kvkk@borseker.com.
Bor Şeker will respond to your requests free of charge within the shortest possible time, and no later than 30 days. If the fulfillment of your request incurs costs, you may be charged according to the fee schedule determined by the Board.
Bor Şeker reserves the right to accept or reject your requests with justifications and will notify you in writing or electronically accordingly. If accepted, Bor Şeker is obliged to fulfill your request promptly.
Data Controller Information
This notice has been prepared by and for Bor Şeker A.Ş., established in Turkey, whose contact details are as follows:
| BOR ŞEKER A.Ş. MERSIS No: 0478056194500010 Address: Şeker Mahallesi Bor Cad. Cadde No: 67A/ Bor Niğde Phone: +90 (850) 304 0 267 KEP Address: borseker@hs01.kep.tr |