KVKK Clarification Text

This Clarification Text contains the statements of Safir Optik Sanayi Ve Dış Ticaret Limited Şirket (“Safir Optik” or the “Company”) regarding the processing of personal data, prepared to inform and enlighten you in accordance with Article 10 of the Law No. 6698 on the Protection of Personal Data (“KVKK”).

1 - Method and Legal Basis for Collecting Your Personal Data

Your personal data is collected electronically or physically. Your personal data collected on the legal grounds specified in this Clarification Text may be processed and shared within the framework of the personal data processing conditions specified in Articles 5 and 6 of the Law.

2 - Data Controller and Representative

In accordance with the KVKK, Safir Optik, acting as the data controller, may process, record, store, classify and update your personal data for the purposes explained below, in accordance with the law and the principles of good faith, and may disclose/transfer such data to third parties where permitted by legislation and/or limited to the purposes for which they are processed.

3 - Purpose of Processing Personal Data

Your personal data is processed in accordance with the fundamental principles stipulated in the Law, for purposes including carrying out the Company’s operational and commercial activities, business relations and human resources processes, responding to requests from relevant persons, providing products and services appropriately, continuing marketing and technical processes, and conducting activities to ensure the Company’s commercial security, and is securely stored for a reasonable period based on the processing activity. (In this context, our Company, Safir Optik, acts in compliance with all obligations stipulated by the relevant legislation.)

4 - Transfer of Your Personal Data

Your processed personal data may be transferred, within the scope of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK, to our business partners, shareholders, authorized public institutions and organizations, private individuals, companies from which support services are obtained for the purpose of carrying out our activities, and independent audit companies within the framework of legal obligations and legal limitations, for purposes including planning and carrying out the activities necessary to customize and recommend and promote the products and services offered by the Company to relevant persons according to their preferences, usage habits and needs; conducting the necessary activities by business units to enable relevant persons to benefit from the products and services offered by the Company and carrying out the related business processes; conducting the necessary activities by relevant business units and carrying out related business processes for the performance of the Company’s commercial activities; planning and executing the Company’s commercial and/or business strategies; and ensuring the legal, technical and commercial/business security of relevant persons who have business relationships with the Company.

5 - Rights of the Relevant Person Pursuant to Article 11 of the KVKK (Rights of Data Subjects and Exercise of These Rights)

Data subjects may submit their requests (applications) concerning their rights, together with documents enabling the identification of the relevant data subject, by delivering a wet-signed copy in person, through a notary public, or by registered mail with return receipt requested to the address Fatih Mh. Yamaç Sk. No:7/3 Sancaktepe - İstanbul. For a third party to submit an application on behalf of a personal data subject, a special power of attorney issued through a notary public by the data subject in favor of the person making the application must be provided. Depending on the nature of the request, the Company shall conclude the request as soon as possible and, in any event, within thirty (30) days free of charge. However, if the process requires an additional cost, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board.

Pursuant to Article 11 of the KVKK, the rights of data subjects are as follows:

• To learn whether their personal data has been processed,
• To request information if their personal data has been processed,
• To learn the purpose of processing their personal data and whether such data is used in accordance with its purpose,
• To know the third parties to whom personal data is transferred domestically or abroad,
• To request correction of personal data if it has been processed incompletely or incorrectly,
• To request the deletion or destruction of personal data within the conditions stipulated in the relevant article,
• To request notification of the transactions carried out pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,
• To object to the occurrence of a result against the person by means of analyzing the processed data exclusively through automated systems,
• To demand compensation for damages in the event of suffering damage due to the unlawful processing of personal data.