Protection of Personal Data

Information Notice Pursuant to the Personal Data Protection Law no. 6698

Personal Data Protection

Information Notice Pursuant to the Personal Data Protection Law no. 6698

This Information Notice is intended to inform you about how your personal data are to be collected, processed, used, transferred and destroyed by Suwen Tekstil Sanayi Pazarlama Anonim Şirketi (“Suwen”), in the capacity of a data controller, within the framework of the article 10 ‘Obligation of the Data Controller to Inform the Data Subjects’, and the article 11 ‘Rights of the Data Subjects’ concerning the personal data processing pursuant to the Personal Data Protection Law no. 6698 (the “PDPL”).

Limited to the purposes as listed below, Suwen asks you to provide and processes some of your personal data about your name, surname, address, mobile phone number, e-mail address, date of birth, body size and BIN number (the first eight digits of your credit card number).

We hereby pledge that we will process and store your Personal Data:

•                 acting legally and honestly at all times,
•                 keeping your personal data accurate and updated,
•                 for certain, open and legitimate purposes,
•                 in connection with, limited to and extended by the purpose of processing as described hereunder,
•                 within the scope of the terms and conditions as required by the applicable legislation or necessary for the intended purpose.

Suwen may process your personal data pursuant to the applicable provisions of the PDPL for such purposes and to such extent as described below.

1.               Purpose of Processing

Processing for Reasons of Legal Compliance. The details about your name, surname, address, mobile phone number, e-mail address, body size and BIN number (the first eight digits of your credit card number) are processed for the purposes of:

•                 meeting your demands within the scope of the performance of the sales agreement,
•                 fulfilling our obligations and commitments pursuant to the applicable law and as may arise from the pertinent legislation,
•                 ensuring that you are able to shop on our website and fulfill our obligations arising from the applicable provisions of the distance sales agreement,
•                 contacting you if needed in connection with your shopping procedures,
•                 answering your complaints and requests,
•                 conducting analysis studies so that you are able to make use of our products and services in the best manner possible,
•                 carrying out accounting and financial processes and
•                 collecting statistical information.

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These personal data of yours described here are processed without the need for your explicit consent. Therefore, you are not able to ask us to stop processing your personal data that are processed under this scope within the storage period.

Processing based on Explicit Consent. And the details about your name, surname, mobile phone number, e-mail address and date of birth are processed based on your explicit consent for the purposes of:

•          informing you of new products and promotions,
•          managing interactive customer programs,
•          contacting you for commercial purposes in order to carry out advertising and marketing operations including customer programs allowing you to earn money, bonuses.

Membership with the Website. You can purchase products and services through our website with our without a membership. In case you prefer to be a member of our website, Suwen may use the personal data of the members in order to provide better services to the users, improve the products and services and, facilitate the use of the website. Suwen may keep the records of the actions of a member on the website. 

Participation in the Loyalty Program.  The Suwen Club loyalty program is an additional benefit program that allows the customers to earn heart bonuses from their shopping and use these bonuses in the subsequent shopping transactions. We process the details about your name, surname and mobile phone number based on your explicit consent pursuant to the article 5/1 of the PDPL for your participation in the loyalty program. You give your explicit consent by sharing us with the SMS confirmation code sent to your mobile phone.

The customers, who prefer to participate in the loyalty program, are asked to provide details about the dates of birth of their spouses and children for marketing campaign purposes.  Our customers are not required to provide Suwen with these data in order to make use of the loyalty program. You should get the consent of your spouse and children before you share the details about their dates of birth with Suwen. It will be under your responsibility if you share these data without getting their prior consent.

Suwen also automatically process your personal data.

Suwen has surveillance cameras at its stores as a security measure.

In addition, Suwen may also make use of your personal data for advertising and marketing purposes by means of converting them into statistical details.

1.               Legal Basis for Processing 

Reasons for Legal Compliance. Data processing during your physical shopping at our stores or at the website based on a distance sales agreement takes place for the legal reasons pursuant to the applicable provisions of the Turkish Code of Obligations, Consumer Legislation, Turkish Commercial Code and tax legislation and for such reasons because it is necessary for Suwen to do so in the capacity of a data controller as required by the applicable laws or in connection with the conclusion or performance of the agreement respectively in accordance with the applicable provisions of the articles 5/2 (a), (c), (.) of the Personal Data Protection Law no. 6698 (the “Law no.6698”). Suwen process the details about your name, surname, contact info, the subjects of a complaint and legal action in order to manage and respond to customer complaints from you, establish, protect and exercise its rights in case of a legal dispute pursuant to the applicable provisions of the article 5/2 (e) of the PDPL. The records from surveillance cameras at the stores are processed in order to Suwen to protect its legitimate interests pursuant to the applicable provision of the article 5/2 (f) of the PDPL. This processing does not require your consent. Accordingly, we hereby inform you that you do not have the right to ask us to delete or destroy your personal data until the end of the retention period as required by the respective business and applicable laws.

Explicit Consent. The personal data of a user, who is a member of the website, disclosed by them within the framework of this membership are processed based on the explicit consent of this member pursuant to the applicable provisions of the article 5/1 of the PDPL. The fact that you are a member of our website does not necessarily mean that your personal data may be used to make a commercial contact with you for advertising and marketing purposes unless you give your explicit consent in this respect.

The processing of your personal data for the purposes of contacting you to inform you about new products and promotion and conduct marketing operations including such programs allowing you to earn money, bonuses and, carrying out marketing operations is based on your explicit consent pursuant to the applicable provisions of the article 5/1 of the PDPL.

You have the right to withdraw you explicit consent granted pursuant to the applicable provisions of the PDPL.

Your personal data will not be made use of to contact you and carry out marketing operations if and when you have withdrawn your explicit consent.

3. How to Collect and Store Data

Your personal data are collected when you enter these data on the website and/or during the procedures and transactions you carry out at our retail stores. These data are processed by the Suwen Operations Team and stored by the ERP System that is owned by Suwen. Your personal data are kept at the application Customer Relationship Management (CRM) on the program Microsoft Dynamics.

4. Transfer of the Personal Data

Transfer Not Based On Explicit Consent.  Based on the reason of legal compliance, Suwen may transfer or disclose your personal data without the need for your consent in order to comply with the obligations as may arise from the applicable law and regulations, and fulfil its responsibilities and liabilities pursuant to the respective service and purchase agreement if it is necessary to establish, exercise or protect one of its rights thereunder:

(1)           to the stores of Suwen, the Social Security Institution, the respective tax offices, courier companies, and the related units within the company for the purposes of delivering such products and rendering such services as requested, and carrying out the payment transactions and procedures related thereto,

(2)           to such third parties as required by the pertinent transactions and procedures and/or from whom it receives services such as banks, auditing companies, lawyers, law offices, certified public accountants and suppliers as limited to the services rendered and in proportion to this end for the purposes of fulfilling the respective obligations only and

(3)           to the police departments, public authorities, related ministries and directorates as well as such public departments and legal entities including the Social Security Institution in charge pursuant to the applicable labor code and social security regulations, the Turkish Statistical Institute, and other public offices and institutions authorized under the applicable laws and regulations.

In addition, in case the company is partially or wholly taken over, then these data may be transferred to such real persons and legal entities that take over the company.

The data transfer within the borders of Turkey will take place based on the applicable provisions of the PDPL 8/2(a) and only if it is necessary to do so in order to establish an agreement pursuant to the paragraph (c) thereof, fulfill a legal obligation pursuant to the paragraph (ç) thereof, and establish, exercise or protect a right pursuant to the paragraph (e) thereof.

You will be allowed at any time to get and review such information about those third parties and/or third parties to whom your personal data are disclosed/transferred.

Transfer Based On Explicit Consent. The personal data about the identifies and contact info of the customers may be transferred based on an explicit consent to the suppliers that offer advertising and marketing services for the business operations of Suwen pursuant to the applicable provisions of the article 8/1 of the PDPL. A data subject may at any time withdraw their explicit data granted for the transfer of their personal data to third parties for marketing purposes.

In addition to servers which located in Turkey, Suwen may transfer your personal data to a foreign country or to a third party located in a foreign country.

5. Protection and Deletion of the Personal Data

Suwen is required and obliged to any type of physical, technical and administrative measures intended to provide a sufficient level of security to prevent your personal data from being illegally processed and accessed, and ensure that your personal data are protected, and Suwen takes such measures at the highest level possible.

Your personal data will be deleted, destroyed or anonymized by Suwen at the end of a period of ten (10) years following the most recent purchase agreement entered into between you and Suwen.

In case of a membership on our website, your personal data you give us during the membership will be kept and maintained for a period of two (2) years in addition to the term of your membership to make a commercial contact with you unless you withdraw your explicit consent to that end.

If you are not a member of our website, the period during which your personal data are processed for marketing purposes is limited to a period of two (2) years following the most recent date on which you purchase a product and/or service from Suwen. At the end of this period of two (2) years, Suwen will not make use of your personal data in order to contact you for marketing purposes.

The records from the surveillance cameras located at the stores of Suwen are kept and maintained for a period of three (3) months of the recording date and, then destroyed at the end of this period.

Your personal data will be deleted, destroyed or anonymized at the first destruction period following the storage periods as described hereunder.

6. Your Rights in the capacity of Data Subject

As a data subject, you are entitled pursuant to the applicable laws and regulations to (a) ask for information about whether your personal data are processed and, how these data are processed (article 11/(a), (b)); (b) learn about the intended purpose of the processing and whether these data are used for this purpose (article 7, m. 11/e); (c) learn about those third parties to whom your personal data are transferred (article 11/ç); (d) ask for the correction thereof (article 11/d); (e) ask for the deletion of your personal data if the reason of the processing is no longer valid (article 7, article 11/e); (f) request that those third parties, to whom your personal data are transferred, are informed about the this correction and deletion (article 11/f); (g) object the results of the analysis carried out on your personal data (article 11/g); (h) request for the limitation on the processing (article 7); (i) ask for the indemnification of any loss you may suffer due to an illegal processing of your personal data (article 11/ğ).

Your rights as described hereinabove are limited by the applicable laws and regulations, and will be fulfilled by us only under certain conditions. (please see, in particular, the articles 10 and 13 of the PDPL).

You may send these requests listed above to the e-mail address provided for this purpose kvkk@bilgi.suwen.com.tr. Suwen shall fulfill your request as soon as possible and not later than 30 (thirty) days once it has received the respective documents. Pursuant to the Communique on Procedures and Principles on Applications to Data Controllers issued by the Personal Data Protection Board, any written answer to the requests submitted by you in the capacity of a data subject will be free of charge up to ten pages thereof. A transaction fee of 1 Turkish Lira for each page exceeding this limit of ten pages will be charged. In case of a response on a recording medium such as CD, flash memory etc. the price as may be charged by our company as a data controller will not exceed the cost of the said recording medium.

Data Controller:  Suwen Tekstil Sanayi Pazarlama Anonim Şirketi    

Mersis No:03300499555036

Address:  Fatih Sultan Mehmet Mah. Balkan Cd. No:39/41, 34771 Ümraniye/İstanbul

Phone: +90-216- 344 4285

E-Mail:  kvkk@bilgi.suwen.com.tr  

You may use the contact info detailed above to contact us for these purposes.

Upon your request, Suwen may at any time update your personal data and the information notice.  For the most recent version of the information notice please visit:https://www.suwen.com.tr/kvkk.

Right to Submit Complaints to the Personal Data Protection Board

To exercise to submit a complaint to this Board (pursuant to the articles 13, 14 and 15 of the PDPL) please use the following contact info:

Board: Personal Data Protection Board

Address: Nasuh Akar Mah. Ziyabey Cad. 1407. Sok. No: 4 06520 Balgat-Çankaya/ Ankara,

Phone: +90 312 216 5000

Website: http://www.kvkk.gov.tr/.

To review our Confidentiality and Cookies Policy please visit: https://www.suwen.com.tr/suwen-cerez-politikasi

TERMS OF USE FOR THE SUWEN CLUB LOYALTY PROGRAM