PRIVACY AND SECURITY POLICY

Link: https://www.meleztea.com/pages/privacy-policy

PRIVACY AND SECURITY POLICY

MELEZ TEA (ASLANOBA), primarily in accordance with the Turkish Penal Code No. 5237 and the Law on the Protection of Personal Data No. 6698, and in order to fulfill its legal obligations arising from the relevant legislation and to provide better service to its Members, requests certain personal information (such as name, e-mail address, address, mobile phone number, real-time location information, etc.) from you. By using the MELEZ TEA (ASLANOBA) mobile application and/or website, you accept this Privacy and Security Policy.

These personal data collected on MELEZ TEA (ASLANOBA) servers are used for sending press releases via electronic mail, conducting periodic campaign activities, designing special promotional activities for member profiles, and member “classification” studies aimed at preventing the delivery of unsolicited e-mails. Your personal data may be processed within MELEZ TEA (ASLANOBA), wholly or partially, by automatic or non-automatic means, through processes such as obtaining, recording, storing, preserving, modifying, disclosing, transferring, taking over, reorganizing, etc. MELEZ TEA (ASLANOBA) does not share the information collected through the Membership Agreement with third parties other than its employees and performance assistants, all representatives, service providers and/or subcontractors of MELEZ TEA (ASLANOBA), without the knowledge of the relevant member or without an explicit instruction, does not use it for commercial purposes outside its activities, and does not sell it. MELEZ TEA (ASLANOBA) takes all necessary measures, including administrative, technical and physical measures, to protect your personal information against loss, theft and misuse, as well as unauthorized access, disclosure, alteration and destruction.

Statistical data that do not contain personal information may be shared with performance assistants, all representatives, service providers and/or subcontractors of MELEZ TEA (ASLANOBA) in order to provide users with a more personalized and effective service experience.

If you would like to make inquiries regarding the information registered in the MELEZ TEA (ASLANOBA) database, correct/update your personal information and change your data sharing preferences, you may submit your request via the following channels:
212-229-2969 / info@meleztea.com

The user may not claim that the information contained in the MELEZ TEA (ASLANOBA) mobile application and/or website is incorrect or that they have suffered damage based on such information. The user accepts that when intending to carry out a transaction by referencing the information, they are obliged to obtain final and reliable information from MELEZ TEA (ASLANOBA), and that MELEZ TEA (ASLANOBA) has no liability due to the information published on the mobile application and/or website not being up to date.

In order to identify system-related problems on the site or application and to urgently resolve potential issues, MELEZ TEA (ASLANOBA) may record users’ IP addresses when necessary and use these records for the aforementioned purposes. These IP addresses may also be used by MELEZ TEA (ASLANOBA) to generally identify Members and to collect comprehensive demographic data.

Member information may only be disclosed to official authorities if such information is duly requested by official authorities and in cases where disclosure is required by mandatory provisions of the applicable legislation.

By sending a message to the e-mail address provided below, you as our valued Member may at any time request and obtain information regarding:

a) Whether your personal data is processed,
b) If your personal data has been processed, information regarding such processing,
c) The purpose of processing your personal data and whether they are used in accordance with this purpose,
d) The third parties to whom personal data is transferred domestically or abroad,
e) The correction of personal data if it has been processed incompletely or inaccurately,
f) The deletion, correction, anonymization or destruction of personal data,
g) Notification of the transactions carried out pursuant to items (e) and (f) to third parties to whom personal data has been transferred,
h) Objection to the emergence of a result against the person himself/herself due to the analysis of processed data exclusively through automated systems,
i) Compensation for damages in case of suffering damage due to unlawful processing of personal data,
j) Information regarding the identity of the data controller and its representative, if any, the purposes of processing personal data, the persons to whom and purposes for which personal data may be transferred, and the method and legal basis of data collection.

Our Members may at any time, without any justification, contact us via the communication channels specified above to stop the use/processing of their personal data and/or the commercial electronic communications sent to them. In accordance with the Member’s explicit notification in this regard, personal data processing and/or communications to the specified channels will be stopped within the maximum legal period (legally required/possible processes and communications will continue). Upon request of the Member, information other than those that must be legally retained and/or are legally permissible will be deleted, destroyed or anonymized in the data recording system. Members may also apply to us at any time and obtain information regarding transactions related to the processing of their personal data. Such applications and requests will be fulfilled within the maximum legal periods or may be rejected by explaining the legal justification to the applicant.

Despite MELEZ TEA (ASLANOBA) taking the necessary information security measures, it shall have no liability in the event that confidential information is damaged or obtained by third parties as a result of attacks on the site and system.

The Member also accepts and declares that MELEZ TEA (ASLANOBA) may send all kinds of commercial electronic data, audio and visual content communications, including promotions such as discounts and gifts, via telephone, call center, automatic dialing, e-mail, short message service and similar means.

For Which Purposes and on Which Legal Basis Will Personal Data Be Processed and Transferred?

All personal data may be processed for the following purposes:

a) Verifying the identity information of the purchaser shopping through e-commerce channels; fulfilling all contractual obligations, especially distance sales contracts and obligations arising from the Law on the Protection of Consumers; providing necessary information and performing obligations,
b) Providing information to all public officials, especially upon request from Legal and Criminal Courts, in matters related to public security and as required by legislation,
c) Informing about special and general campaigns (promotions, advertisements, discounts, etc.) and using for all kinds of marketing activities,
d) Recognizing customers shopping via the mobile application and/or website and carrying out marketing activities accordingly,
e) Using in various marketing and advertising activities and conducting marketing activities, surveys and market analyses electronically and/or physically through contracted organizations,
f) Evaluating and reporting customer complaints and suggestions regarding our services and sharing data with contracted business partners for this purpose and within the scope of marketing activities,
g) Fulfilling our legal obligations and exercising our rights arising from applicable legislation,
h) Transferring data to third parties and third companies (contracted business partners) from whom we receive services for the fulfillment of legal obligations,
i) Storing in data systems for the fulfillment of contractual obligations (such as product delivery, etc.),
j) Storing your contact information in data systems for the purpose of reminding you of your rights.

For How Long Will Personal Data Be Processed?

As MELEZ TEA (ASLANOBA), when determining the retention periods of personal data, we take into consideration the applicable legislation and the purposes for which the relevant data are processed. In accordance with the KVKK, personal data processed for the purposes specified in this Information Notice will be deleted, destroyed or anonymized when the purpose requiring processing ceases to exist and/or when all limitation periods required by legislation expire, pursuant to Article 7/1 of the KVKK.

How Is Personal Data Security Ensured?

All MELEZ TEA (ASLANOBA) e-commerce channels, the information of customers who register and/or update their information on the MELEZ TEA (ASLANOBA) mobile application and/or website are stored in reporting systems encrypted with cryptographic software, requiring at least two-factor authentication in case of remote access. Customers may only change their own information, and only authorized persons may access the system.

Technical Measures Taken to Ensure Lawful Processing of Personal Data and Prevent Unlawful Access

Technical measures appropriate to technological developments are taken, and these measures are periodically updated and renewed. There are software and hardware systems including virus protection systems, backup systems, system recovery and protection software, and firewalls. Employees are informed that they may not disclose personal data they learn in violation of the Law and may not use them for purposes other than processing, and that this obligation continues even after leaving their duties, and necessary undertakings are obtained from employees accordingly. Systems appropriate to technological developments are used to store personal data in secure environments.

Administrative Measures Taken to Ensure Lawful Processing of Personal Data and Prevent Unlawful Access

Administrative measures taken include:

• Training and raising awareness of company employees regarding the KVKK,

• Ensuring that provisions are added to contracts executed with parties to whom personal data are transferred, stating that the receiving party will fulfill data security obligations,

• Identifying requirements for compliance with the KVKK and preparing internal policies for their implementation.

Measures to Be Taken in Case of Unlawful Disclosure of Personal Data

In the event that processed personal data are obtained by others through unlawful means despite the necessary security measures taken, our Company will notify the relevant data subject and the Personal Data Protection Board as soon as possible, including detailed information regarding the manner and consequences of the breach.

What Are Your Rights Under the Law on the Protection of Personal Data?

Pursuant to Article 11 of the Law, personal data subjects have the right to:

• Learn whether personal data are processed,

• Request information if personal data have been processed,

• Learn the purpose of processing and whether they are used in accordance with this purpose,

• Know the third parties to whom personal data are transferred domestically or abroad,

• Request correction if personal data are incomplete or inaccurately processed,

• Request deletion, anonymization or destruction of personal data,

• Request notification of these transactions to third parties,

• Object to results arising against the person due to analysis exclusively through automated systems,

• Request compensation in case of damage due to unlawful processing.

These rights may be exercised via the communication channels (e-mail, call center, etc.) on the website.

Non-Personal Information

Non-personal information refers to data that cannot personally identify the member, such as usage times, location from which the Site is accessed, pages viewed, etc. MELEZ TEA (ASLANOBA) has the right to use such information for any purpose and may collect, share, transfer and disclose it to third parties without obtaining consent.

Deletion, Destruction and Anonymization of Personal Data

Pursuant to Article 7 of the KVKK, if the reasons requiring processing cease to exist, personal data shall be deleted, destroyed or anonymized by our Company ex officio or upon the request of the data subject.

These procedures shall be carried out in accordance with the KVKK and the Regulation on the Deletion, Destruction or Anonymization of Personal Data published in the Official Gazette dated 28.10.2017 and numbered 30224.

Within 3 (three) months following the date on which the obligation to delete, destroy or anonymize arises, personal data shall be deleted, destroyed or anonymized.

If you apply to our Company requesting the deletion or destruction of your personal data:

a) If all processing conditions have ceased, the relevant personal data will be deleted, destroyed or anonymized and the request will be finalized within thirty days.
b) If the data have been transferred to third parties, this will be notified to such parties and necessary actions will be ensured.
c) If processing conditions have not ceased, the request may be rejected with justification pursuant to Article 13/3 of the KVKK, and the response will be provided within thirty days.

Cookies

Cookies are small text files that record your preferences on your computer when you visit the mobile application and/or website. Cookies are used to provide you with the highest quality service, such as remembering products in your shopping cart, recognizing you when you revisit the site, and displaying advertisements and announcements that may interest you on frequently visited pages. Cookies enhance site functionality and help us analyze site usage more accurately. They do not contain personal or private information and do not harm your computer. You may control or delete cookies as you wish. MELEZ TEA (ASLANOBA) may use cookies to identify you and retain your settings after login. You may always change your browser settings to be notified when such files are sent. MELEZ TEA (ASLANOBA) may provide links to other sites within the application or website.

Payment Security

Collected financial information is used to invoice purchased products. By making an online purchase via the mobile application and/or website, you accept that your financial information may be shared with necessary third parties (banks, credit card companies, etc.) to complete the transaction. Shared information includes credit card number, expiration date, CVC2 and all required financial information.

In secure transactions, no individual or entity other than you and the issuing bank can access your information. Credit card transactions are transmitted directly to the bank POS system, and the transaction result is notified to the member. Credit card information is not transmitted via e-mail or similar methods and is never stored by MELEZ TEA (ASLANOBA). It is not possible for us to access credit card information transmitted as a result of online transactions.

Application Procedures to the Data Controller Within the Scope of Personal Data

The relevant person may submit an application regarding their processed personal data in Turkish, in writing or by other methods determined by the Personal Data Protection Authority (e-mail or software/application developed for application purposes).

Applications must include:

1. Name, surname and signature if written,

2. Turkish ID number for Turkish citizens; nationality, passport number or ID number for foreigners,

3. Address for notification,

4. E-mail address, phone and fax number, if any,

5. Subject of the request.

Applications will be reviewed in accordance with law and good faith principles and responded to within thirty days.

No fee will be charged unless the response incurs additional cost. If a cost arises, the tariff determined by the Personal Data Protection Authority will apply.

Data Controller Information

…………………………

…………………………

For all your questions:

Title	:
Address	:
Phone	:	…………
Fax	:	…………
E-Mail	:

 

[EHB1] Written as an example. Must be changed according to the current situation.
[EHB2] Additions may be made if different software and hardware exist.
[EHB3] Article 7 of the Law regulates deletion, destruction or anonymization of personal data; violation is punishable under Turkish Penal Code Article 138.
[EHB4] A separate “Cookie Policy Information Text” may be provided via link.
[EHB5] This section must be completed in full.

Camera Systems Information Notice

As Aslanoba Yatırım Gıda San. ve Tic. A.Ş. (“Melez Tea”), image recording is carried out through camera systems in our workplaces for the purpose of ensuring security. This notice has been prepared to inform you within the scope of the Law on the Protection of Personal Data No. 6698 (“KVKK”).

Data Controller

Pursuant to KVKK, your personal data is processed by Aslanoba Yatırım Gıda San. ve Tic. A.Ş. in its capacity as the data controller.
Contact: info@meleztea.com

Processed Personal Data

Image recordings obtained through camera systems

Purposes of Processing Personal Data

Image recordings are processed for the following purposes:

Ensuring the security of our workplaces, guests, and employees
Ensuring physical space security
Being used as evidence in possible legal disputes

Legal Basis for Processing Personal Data

Your personal data is processed within the scope of the legitimate interests of the data controller pursuant to Article 5, paragraph 2, subparagraph (f) of KVKK.

Methods of Collecting Personal Data

The Company collects personal data electronically through CCTV systems, by automatic means, in line with the legal grounds specified in Article 5 of the Law.

Retention Period

Camera recordings are stored for 30 (thirty) days and are automatically deleted at the end of this period.

Transfer of Personal Data

Image recordings may be transferred only to legally authorized public institutions and organizations and judicial authorities, upon request and within the scope of legal obligations.

Principles Regarding the Use of Camera Systems

Camera systems are used only in common areas
There are no cameras in toilets, changing rooms, or similar private areas
No audio recording is carried out through camera systems

Your Rights Under KVKK

Pursuant to Article 11 of KVKK, you have the right to:

Learn whether your personal data is processed
Request information regarding such processing
Learn whether personal data is used in accordance with its purpose
Request correction if personal data is processed incompletely or incorrectly
Request deletion or destruction of personal data
Object to processing activities

You may submit your requests within this scope by contacting us via info@meleztea.com

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