Protection of Personal Data

INFORMATION TEXT ON THE PROCESSING OF PERSONAL DATA

Novapera Pazarlama Ve Dış Ticaret A.Ş. with the Information Text Regarding the Processing of Personal Data (“Information Text”). As (“Vitruta” or “Company”), in accordance with the Personal Data Protection Law No. 6698 (“KVKK” or “Law”), as the Data Controller, within the framework of our obligation to inform you within the scope of KVKK, the collection methods and legal reasons for your Personal Data defined below, We would like to inform you about our methods and policy of protecting your data, samples of Personal Data processed, the identity of the data controller, the purposes of processing Personal Data, the transfer of your Personal Data to third parties and/or abroad, and the rights granted to you under KVKK.

Within the scope of KVKK, personal data includes all kinds of information regarding an identified or identifiable natural person (“Personal Data”) and a special type of Personal Data, such as race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, It refers to data regarding appearance and clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data (“Special Qualified Personal Data”). In this context, the definition of Personal Data also includes your Special Personal Data.

1. Identity of the Data Controller

Your personal data is registered with Novapera Pazarlama Ve Dış Ticaret A.Ş., as the data controller, registered with the Istanbul Trade Registry with the registry number 965225, Mersis number 6320479576, and whose corporate headquarters is at Firuzağa Mahallesi Boğazkesen Caddesi No:30 Beyoğlu 34425 Istanbul. may be processed within the scope explained below in accordance with the Personal Data Protection Law.

2. How We Collect Your Personal Data and Legal Reasons

Your personal data is transferred through different channels in order to carry out the Company's activities; It is collected based on legal reasons to ensure compliance with the legislation and Company policies. Your collected personal data may be processed and transferred for the purposes specified in this Information Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law.

Vitruta acts in accordance with all obligations required by the relevant legislation, especially KVKK, in all Personal Data processing activities it carries out, and takes the necessary security measures to safely host your Personal Data and prevent unlawful use of your Personal Data.

In accordance with KVKK, we collect your Personal Data automatically or non-automatically, verbally, in writing or electronically, through the following and other channels that may be added in the future, and process it within the scope of KVKK Article 5.1, Article 5.2, Article 6.2 and Article 6.3:

I. Electronically, through automatic or non-automatic means, through our website www.vitruta.com and other websites that may be established in the future ("Website"), including but not limited to the following pages,

  • Paid or free Membership section on the Website (“Membership Section”),
  • Contact Form section on the Website (“Contact Form Section”),
  • Electronically, automatically or non-automatically, through cookies ("Cookies") that communicate with your devices on the Website (cookies generally collect anonymous data),
  • Correspondence carried out via our e-mail address info@vitruta.com directed on the Website
  • On the product pages of the Website, the "Notify Me When It's In Stock" section, which automatically sends an e-mail to info@vitruta.com in case a product that is out of stock comes back into stock ("Notify Me When It's in Stock")

ii. Electronically, automatically or non-automatically, from accounts operated on behalf of Vitruta through various Social Media channels (Google, YouTube, Facebook, Instagram, WhatsApp, Twitter, Linkedin, Yandex, Pinterest, Snapchat, Twitch, TikTok, Oracle BlueKai, Bip, etc.),

iii. Through our call centers managed by Vitruta,

iv. Through the entire sales and marketing network established and managed by Vitruta,

v. Orally, in writing or electronically, through automatic or non-automatic means within the scope of sales and marketing, through our employees operating on behalf of Vitruta and working in the sales and marketing network,

vi. Through other communication methods, including correspondence carried out through our e-mail addresses, short messages (“SMS”) or multi-media messages (“MMS”) sent for other purposes regarding Vitruta activities, and all kinds of Communication Tools,

vii. Orally, in writing or electronically, through automatic or non-automatic means within the scope of sales, marketing and after-sales services, through all service sales and marketing networks established or operated by third parties that are not owned by Vitruta,

viii. Verbally, in writing or electronically, automatically or non-automatically, through our network of all other after-sales services established or operated by Vitruta or by third parties not within Vitruta,

ix. Through third parties such as group companies to which Vitruta serves or receives services, business partners, manufacturer companies or companies from which it supplies services/products.

x. Orally or electronically, through automatic or non-automatic means, through your website, social media or other channels where you make your Personal Data public.

3. Purposes of Processing Your Personal Data

(a) Within the scope of Articles 5 and 6 of the Law;

As a rule, we process your Personal Data based on your explicit consent. However, in exceptional cases permitted under KVKK, your Personal Data may be processed without your explicit consent. In this context, (i) in order to fulfill our legal obligations (such as tax legislation, legislation on the protection of consumers, obligations arising from the Turkish Code of Obligations, the Turkish Commercial Code and other legislation), your data (within the scope of e-invoice, e-archive or in cases required by consumer legislation) processing and any other processing that can be attributed within the scope of the relevant regulation can be given as examples.) (ii) If you are unable to express your consent due to actual impossibility, (iii) for the purpose of establishing or performing a contract (membership agreements, purchase and sale agreements, sale or supply of products or services). (iv) in order to fulfill our legal obligations such as receiving your questions and complaints regarding the service, responding to you, and using them in case of a possible dispute when necessary, (v) sales and In order to establish or protect a right through the processing carried out within the scope of keeping records as evidence within the scope of after-sales services and any other processing that can be attributed within the scope of the relevant regulation, (vi) cost reduction, efficient use of resources, call center service, provided that your fundamental rights and freedoms are not harmed. In order to protect our legitimate interests such as monitoring the quality, ensuring your security and measuring the quality of the service provided to you, evaluating and resolving your requests in this context; We process your Personal Data. In addition, the processing of personal data you have made public within the limits specified in the KVKK does not require your explicit consent. Examples of this include the processing by us of your Personal Data that you have made public on social media channels, your website and other media, and any other processing that can be attributed within the scope of the relevant regulation. Apart from this, if a transaction requires your explicit consent, your explicit consent will also be obtained.

(b) Your Personal Data collected through the above channels and by the methods mentioned above may also be processed for the following purposes, provided that your explicit consent is obtained:

I. Processing for the purpose of presenting you special advertisements, campaigns, advantages and other benefits for sales, tele-sales and marketing activities and carrying out other marketing and customer relationship management activities.

ii. Processing to provide personalized content during your visit to the Websites,

iii. Processing for the purpose of offering you opportunities for special products and services such as internet advertising, targeting, re-targeting, cross-selling, campaigns, opportunities and product/service advertisements,

iv. Processing for the purpose of creating new product and service models,

v. Processing for the purpose of sending electronic commercial messages (such as campaigns, newsletters, customer satisfaction surveys, product and service advertisements),

vi. Processing for the purpose of sending gifts, promotions and other magazines/periodicals,

vii. Processing for the purpose of arranging corporate communication and other events and invitations within this scope and providing information about them, application for meeting participation, entry and all related transactions and completion of other necessary meeting notification procedures, processing for participation in Congress/Symposium, scientific and educational meetings.

viii. Processing of your Special Personal Data for the purpose of protecting our legitimate interests, without harming your fundamental rights and freedoms, if you are unable to express your consent due to actual impossibility, for the establishment or execution of a contract, to fulfill our legal obligations, to establish, exercise or protect a right.

4. Processing Period of Your Personal Data

The Personal Data you have shared with Vitruta through the channels mentioned in this Information Text will be processed in accordance with the legislation on the protection of Personal Data, especially KVKK, and the periods required by other legislation, as long as the above legitimate purposes are not eliminated.

5. Transfer of Your Personal Data to Third Parties and/or Abroad

Vitruta may transfer your Personal Data collected through the channels and methods mentioned in this Information Text to third parties or abroad within the scope of KVKK and other legislation and for the purposes mentioned in this Information Text.

If your Personal Data has processing purposes that do not require your explicit consent, storage, archiving, information technology support (server, hosting, program, cloud computing) at home and abroad, especially in EU countries, America, England, OECD countries, India, China and Russia, Third parties from whom we receive support in areas such as security, call center, Group Companies, business partners, supplier companies, banks, financial institutions, law, tax, etc. with whom we cooperate and/or receive services. It can be transferred to consultancy firms from which support is received in similar fields and to other related parties and authorized institutions and organizations where transfer is necessary for specified purposes.

Apart from this, only on condition that your explicit consent is obtained, Group Companies located domestically and in the countries mentioned above may transfer personal data to third parties who provide marketing and sales support and may process personal data based on your explicit consent specified above. In addition, in case a part or assets of Vitruta (including but not limited to brand, domain name and other commercial enterprise elements) are sold based on your explicit consent, your Personal Data may be transferred to the real or legal persons who acquire it, including their stakeholders, business partners, agents and consultants. It may be transferred to third parties at home and abroad to the extent required by the transfer, it may be processed to a limited extent by these third parties after the necessary evaluation is made during the transaction process, and in case of transfer, the transferee may continue to process your Personal Data, which are the assets and the values ​​​​attached to these assets, as the data controller.

6. Access to Your Personal Data and Your Rights Under KVKK

By applying to Vitruta in accordance with Article 11 of KVKK;

(a) Learning whether your Personal Data is being processed or not,

(b) Request information regarding your Personal Data if it has been processed,

(c) Learning the purpose of processing your Personal Data and whether they are used for their intended purpose,

(d) Knowing the third parties to whom your Personal Data is transferred domestically or abroad,

(e) Request correction of your Personal Data if it is incomplete or incorrectly processed,

(f) To request the deletion or destruction of your Personal Data in case the reasons requiring processing of your Personal Data disappear, in order to be evaluated within the principles of purpose, duration and legitimacy,

(g) In case your Personal Data is corrected, deleted or destroyed, request that these transactions be notified to third parties to whom the Personal Data is transferred,

(h) Object to a result that is unfavorable to you if your processed Personal Data is analyzed exclusively through automatic systems,

(i) If your Personal Data is processed unlawfully and you suffer damage as a result, you have the right to request compensation for the damage.

In this context, you can make your applications regarding your above rights in a way that meets the conditions determined by the Personal Data Protection Authority, by sending an e-mail to the e-mail address given below from the e-mail address you have previously notified us and registered in our system, or to our kep address with a secure electronic signature, or again below. You can deliver it by hand or via a notary with a signed petition to our mailing address, which may change from time to time, and send it by other methods determined by the Personal Data Protection Authority, which may be added to these in the future. Vitruta will finalize the request free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. If an additional cost arises for Vitruta to finalize the requests, Vitruta may request the fees in the tariff determined by the Personal Data Protection Board.

Postal address: Firuzağa Mahallesi Boğazkesen Caddesi No:30 Beyoğlu 34425 Istanbul

E-mail address: info@vitruta.com

Cap address: novapera@hs01.kep.tr