Explanatory Statement regarding the processing of Personal Data

Data Officer: Loftry Elektronik Ticaret Ve Bilişim Hizmetleri A.Ş.

Ziya Gökalp Mahallesi Süleyman Demirel Blv. The Office Apt. No: 7 E/171 Başakşehir/Istanbul

Loftry E-Commerce and Information Services JSC, has prepared this explanatory statement to provide you with information regarding the processing, transfer and storage of your personal data within the framework of the Personal Data Protection Law No. 6698 and other laws related to this matter.

Employees
Candidates for employment
Trainee students
Students nominated for training
Potential customers
The customer/real person, or the representative of the customer/legal person
Potential business partners of real persons/ authorized representatives of potential business partners of legal persons
Business partners who are real persons/ who are authorized on behalf of business partners who are legal persons.

What personal data about you is subject to processing and what are the purposes of processing your personal data?

Employees

The explanatory data containing details regarding the processing of personal data of our employees has been prepared so that it can only be accessed by employees.

If you are a former employee of Mimari Expert, you have the right to access information related to the processing of your personal data by submitting a personal request to obtain this information in accordance with what is stated in this explanatory statement.

Candidates for employment
Personal identification information
Personal data subject to processing	● Name and surname ● Birth date ● Place of birth ● Gender ● Turkish ID number ● Passport number ● Photo ● Nationality ● Military service performance document/ exemption document ● Civil status ● Driver's license information ● Number of family members ● Number of children ● The signature
Objectives of the processing of personal data	Conducting events legally, managing and following up on legal transactions, providing information to responsible persons, institutions and concerned departments, planning human resources work, managing the processes of selecting candidates for employment/training students and placing them in the appropriate places, managing the process of studying applications for job applicants, managing/overseeing company activities.
Legal justifications for processing personal data	Loftry processes your personal identity data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your personal identification data is collected through: printed and electronic application forms, documents and information sent by the data subject via email, as well as through contracts, recruitment platforms and information systems.
Contact Information
Personal data subject to processing	● E-mail address ● Work phone number ● Mobile phone number ● Residence address – postal address
Objectives of the processing of personal data	Conducting events legally, managing and following up on legal transactions, providing information to responsible persons, institutions and departments concerned, planning human resources work, managing the processes of selecting candidates for employment/ training students and placing them in the appropriate places, managing the process of checking job applications, managing/ overseeing company activities.
Legal justifications for processing personal data	Loftry processes your contact data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	The process of collecting your contact data takes place through printed and electronic application forms, documents and information sent by the person concerned via email, as well as through contracts, recruitment platforms and information systems.
Job information
Personal data subject to processing	● Reference information ● CV ● Job information/ current job title ● Information about the department to which the applicant belongs ● Information about the job title being applied for ● Salary information ● Information about the salary expected by the applicant ● Information related to the workplace ● The start and end dates of work in the previous job ● Salary information at previous work ● Reason for leaving old job ● Information related to the travel ban ● Application letter
Objectives of the processing of personal data	Planning human resources work, managing the process of testing employment candidates/ student trainees, and placing them in appropriate positions, managing the process of examining applications for employment.
Legal justifications for processing personal data	Loftry processes your job data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	The process of collecting your contact data takes place through printed and electronic application forms, documents, and information sent by the person concerned via email, as well as through contracts, recruitment platforms, and information systems.
Information related to professional experiences
Personal data subject to processing	● Information related to training and education ● Professional information ● Educational status ● Certification information ● Training course information ● Training certificates information ● Information about previous work experiences ● Vocational qualification document level 4/5 ● Foreign language test ● Computer usage information ● Information contained in the commercial vehicle driving license ● Information related to competencies.
Objectives of the processing of personal data	Conducting events legally, managing and following up on legal transactions, providing information to responsible persons, institutions, and departments concerned, planning human resources work, managing the processes of selecting candidates for employment/training students, and placing them in the appropriate places, managing the process of checking applications for job applicants, managing/overseeing company activities.
Legal justifications for processing personal data	Loftry processes your job data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	The process of collecting your contact data takes place through printed and electronic application forms, documents and information sent by the person concerned via email, as well as through contracts, recruitment platforms and information systems.
Information related to spatial security
Personal data subject to processing	● CCTV camera recordings.
Objectives of the data processing process	Managing control/ discipline processes, maintaining your physical security, managing/ monitoring work activities, ensuring the protection of movable funds and assets, and creating and following up on visitor restrictions.
Legal justifications for processing personal data	Loftry processes your spatial security data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your spatial security data is collected through electronic devices and CCTV cameras.
Personal data of a special nature
Information of a special nature is information related to a person’s racial and ethnic affiliation, his political opinions, religion, sect or other beliefs, information related to his dress and grooming, information related to his membership in an association, endowment or fund, information related to his health and sexual life, and information related to the legal penalties and trials to which he has been subjected. Information related to security measures, in addition to biological and genetic information.
Health information
Personal data subject to processing	● Information regarding disability status ● Information contained in the mental health document.
Objectives of the data processing process	Manage the processes of selecting employment candidates/ trainee students and placing them in appropriate positions, managing the process of checking job applicants, planning human resources work, and managing occupational safety events.
Legal justifications for processing personal data	Loftry processes your health data within the framework of achieving the mentioned objectives, based on the following legal justifications stipulated in Article 6 of the Personal Data Protection Law: ● Personal data relating to an individual's health and sexual life may be processed by relevant persons or institutions legally obliged to maintain private confidentiality, on the basis of legal justifications, without the need to require the express consent of the person concerned, exclusively for the protection of public health, and for medical purposes. Preventive and medical diagnosis, to manage treatment and health care services, and to develop financing plans for health services. If there is a need to process personal data outside of the mentioned reasons, this will be done after obtaining your express consent.
Personal data collection methods	Your health data is collected from printed application forms, and from information and documents sent by e-mail.
Information related to legal penalties, judicial rulings, and security measures
Processed personal data	● Criminal record registration
Objectives of the data processing process	Managing and following up on legal transactions, managing/ overseeing work activities, managing contracting processes, and planning human resources work.
Legal justifications for processing personal data	Loftry processes your information related to legal penalties, judicial rulings, and security measures within the framework of achieving the mentioned objectives, based on the legal justification stipulated in Article 6 of the Personal Data Protection Law, which states: ● In cases stipulated in the law, personal data may be processed, except for the data mentioned in the first paragraph and related to the individual’s health and sexual life, based on legal justifications without the need to request explicit consent from the person concerned. ● If there is a need to process personal data outside of the reasons mentioned in Article 6 of the Personal Data Protection Law, this will be done after obtaining your express consent.
Personal data collection methods	Your personal data relating to legal sanctions, judicial rulings, and security measures is collected through documents and information you have provided to us.

Students nominated for training
Personal identification information
Personal data subject to processing	● Name and surname ● Birth date ● Gender ● Turkish ID number ● Photo ● Nationality ● Military service performance document/ exemption document ● Place of birth ● Civil status ● Driver's license information ● The signature
Objectives of the processing of personal data	Managing the processes of selecting candidates for employment/ training students and placing them in appropriate positions, managing the process of checking job applicants’ applications, conducting communication events, and planning human resources work.
Legal justifications for processing personal data	Loftry processes your job data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your spatial security data is collected through electronic devices and CCTV cameras.
Contact Information
Personal data subject to processing	● E-mail address ● Work phone number ● Mobile phone number ● Residence address – postal address
Objectives of the processing of personal data	Managing the processes of selecting candidates for employment/ training students and placing them in appropriate positions, managing the process of checking job applicants’ applications, conducting communication events, and planning human resources work.
Legal justifications for processing personal data	Loftry processes your job data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your contact data is collected from printed and electronic application forms, the information and documents you have provided to us, private job insurance offices, job opportunity platforms, and emails.
Job information
Personal data subject to processing	● Reference information ● CV ● Job title/ job description for which you are applying ● Information about the salary expected by the applicant ● Travel ban information
Objectives of the processing of personal data	Managing the processes of selecting candidates for employment/ training students and placing them in appropriate positions, managing the process of checking job applicants’ applications, conducting communication events, and planning human resources work.
Legal justifications for processing personal data	Loftry processes your job data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your contact data is collected from printed and electronic application forms, the information and documents you have provided to us, from private job insurance offices, from job opportunity platforms, and from emails.
Professional experience information
Personal data subject to processing	● Education and training information ● Professional information ● Educational Status ● Certification information ● Foreign language test ● Computer usage information ● Efficiency information
Objectives of the processing of personal data	Conducting events legally, managing and following up on legal transactions, providing information to responsible persons, institutions and departments concerned, planning human resources work, managing the processes of selecting candidates for employment/ training students, and placing them in the appropriate places, managing the process of checking job applicants’ applications, managing/ overseeing company activities.
Legal justifications for processing personal data	Loftry processes your job data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your professional experience data is collected through: printed and electronic application forms, documents and information sent by the person concerned via email, and through contracts, recruitment platforms and information systems.
Information related to spatial security
Personal data subject to processing	● CCTV camera recordings
Objectives of the data processing process	Managing control/ discipline processes, maintaining your physical security, managing/monitoring work activities, ensuring the protection of movable funds and assets, creating and following up on visitor restrictions.
Legal justifications for processing personal data	Loftry processes your spatial security data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your spatial security data is collected through electronic devices and CCTV cameras.
Personal data of a special nature
Information of a special nature is information relating to a person's racial and ethnic affiliation, his political opinions, religion, sect or other beliefs, information relating to his dress and grooming, information relating to his membership in an association, endowment or fund, information relating to his health and sexual life, and information relating to the legal sanctions and trials to which he has been subjected. and information related to security measures, in addition to biological and genetic information. Personal data of a special nature requires greater protection and preservation compared to other types of data, and the Data Protection Law has required the organization of a special statement to inform of the processing of this data.
Health information
Personal data subject to processing	● Information regarding disability status ● Information contained in the mental health document
Objectives of the data processing process	Manage the processes of selecting employment candidates/ trainee students and placing them in appropriate positions, managing the process of checking job applicants, planning human resources work, and managing occupational safety events.
Legal justifications for processing personal data	Loftry processes your health data within the framework of achieving the mentioned objectives, based on the following legal justifications stipulated in Article 6 of the Personal Data Protection Law: ● Personal data relating to an individual's health and sexual life may be processed by relevant persons or institutions legally obliged to maintain private confidentiality, on the basis of legal justifications, without the need to require the express consent of the person concerned, exclusively for the protection of public health, and for medical purposes. Preventive and medical diagnosis, in order to manage treatment and health care services, and in order to develop financing plans for health services. ● If there is a need to process personal data outside of the mentioned reasons, this will be done after obtaining your express consent.
Personal data collection methods	Your health data is collected from printed application forms, and from information and documents sent by e-mail.
Information related to legal penalties, judicial rulings, and security measures
Personal data	● Criminal record registration
Objectives of the data processed	Managing and following up on legal transactions, managing/ overseeing work activities, managing contracting processes, and planning human resources work.
Legal justifications for processing personal data	Loftry processes your information related to legal penalties, judicial rulings, and security measures within the framework of achieving the mentioned objectives, based on the legal justification stipulated in Article 6 of the Personal Data Protection Law, which states: ● In cases stipulated in the law, personal data may be processed, except for the data mentioned in the first paragraph and related to the individual’s health and sexual life, based on legal justifications without the need to request explicit consent from the person concerned. ● If there is a need to process personal data outside of the reasons mentioned in Article 6 of the Personal Data Protection Law, this will be done after obtaining your express consent.
Personal data collection methods	Your personal data relating to legal sanctions, judicial rulings, and security measures is collected through the documents and information you provide to us.

Potential Customers
Personal identification information
Data subject to processing	● Name and surname ● Title ● Turkish ID number ● Passport information ● Nationality ● The signature
Objectives of the processing of personal data	Managing events legally, managing and following up on legal transactions, providing information to responsible persons, institutions and departments concerned, managing communication processes, managing/ monitoring work events, managing the processes of producing goods and services, and managing contracting processes.
Legal justifications for processing personal data	Loftry processes your job data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your personal data is collected through printed and electronic personal application forms, documents you submit, and emails.
Contact Information
Data subject to processing	● E-mail address ● Work phone number ● Mobile phone number ● Residence address – postal address ● Country of residence
Objectives of the processing of personal data	Managing events legally, managing and following up on legal transactions, providing information to responsible persons, institutions and departments concerned, managing communication processes, managing/ monitoring work events, managing the processes of producing goods and services, and managing contracting processes.
Legal justifications for processing personal data	Loftry processes your job data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your contact data is collected through printed and electronic personal application forms, documents you submit, and emails.
Audio and video recording information
Personal data subject to processing	● Audio recordings
Objectives of the processing of personal data	Managing events legally, managing and following up on legal transactions, providing information to responsible persons, institutions, and departments concerned, managing communication processes, managing/ monitoring work events, managing the processes of producing goods and services, and managing contracting processes.
Legal justifications for processing personal data	Loftry processes your video and audio recording data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Information regarding your audio and video recordings is collected from calls you make with customer service personnel and through digital recording devices.
Information related to customer transactions
Personal data subject to processing	● Order information ● Product/ service information of interest to the customer.
Objectives of the processing of personal data	● Managing events legally, managing and following up on legal transactions, providing information to responsible persons, institutions, and departments concerned, managing communication processes, managing/ monitoring work activities, managing the production of goods and services, and managing contracting processes.
Legal justifications for processing personal data	Loftry processes your transaction data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your personal data is collected through printed and electronic personal application forms, the information you provide, and emails.

Clients who are real persons/ authorized persons on behalf of clients who are legal persons
Personal identification data
Personal data subject to processing	● Name and surname ● Title ● Civil status ● Photo of personal ID ● Passport copy ● The signature ● Turkish ID number ● Name of father and mother ● Date of birth ● Place of birth ● ID serial number ● Nationality ● Circulate signature ● Tax ID number
Objectives of the processing of personal data	Managing events legally, managing legal transactions and following them up, providing information to responsible persons, institutions and departments concerned, managing communication processes, managing work activities/ controlling them, managing the processes of producing goods and services and managing contracting processes, managing work related to managing relationships with customers, carrying out work for its purpose. Achieving customer satisfaction, managing communication work, managing production processes for services and products, managing logistical events, managing support work in the after-sales phase of the service/product, managing strategic planning events, managing financial and accounting work, managing product/service marketing events, and managing events. Setting prices, managing storage, and archiving operations.
Legal justifications for processing personal data	Loftry processes your identity data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● When the processing is necessary for the data subject to fulfill his or her legal obligations. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your personal identification data is collected from electronic and printed forms, company correspondence, customer service communications, e-mails sent by the person concerned, telephone calls, minutes, contracts, and face-to-face meetings.
Contact Information
Personal data subject to processing	● E-mail address ● Work phone number ● Mobile phone number ● Residence address – postal address ● Country of residence information ● Workplace address
Objectives of the processing of personal data	Managing events legally, managing legal transactions and following them up, providing information to responsible persons, institutions and departments concerned, managing communication processes, managing work activities/ controlling them, managing the processes of producing goods and services and managing contracting processes, managing work related to managing relationships with customers, carrying out work for its purpose. Achieving customer satisfaction, managing communication work, managing production processes for services and products, managing logistical events, managing support work in the after-sales phase of the service/product, managing strategic planning events, managing financial and accounting work, managing product/service marketing events, and managing events. Setting prices, managing storage, and archiving operations.
Legal justifications for processing personal data	Loftry processes your identity data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● When the processing is necessary for the data subject to fulfill his or her legal obligations. If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your contact data is collected from electronic and printed forms, company correspondence, customer service communications, e-mails sent by the person concerned, telephone calls, minutes, contracts, and face-to-face meetings.
Customer transaction information
Personal data subject to processing	● Order information ● Information about the product/service of interest to the customer ● Title Deed website transactions: (Tapu Web), (appointment, sale, etc.)
Objectives of the processing of personal data	Managing events legally, managing legal transactions and following them up, providing information to responsible persons, institutions, and departments concerned, managing communication operations, managing work activities/ controlling them, managing production operations of goods and services, managing contracting operations, managing work related to managing relationships with customers, carrying out work for the purpose. Including achieving customer satisfaction, managing communication work, managing production processes for services and products, managing logistical activities, managing support work in the after-sales phase of the service/ product, managing strategic planning events, managing financial and accounting work, and managing product/service marketing activities.
Legal justifications for processing personal data	Loftry processes your transaction data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your personal information relating to customer transactions is collected from printed order forms, contracts, and information provided by the person concerned.
Information related to legal transactions
Personal data subject to processing	● Correspondence information with judicial authorities. ● Correspondence information with administrative authorities. ● Information related to notification/notification. ● Contract information. ● Lawsuit file information.
Objectives of the processing of personal data	Conducting events legally, managing and following up on legal transactions, providing information to responsible persons, institutions, and departments concerned, and managing the contracting process.
Legal justifications for data processing	Loftry processes your legal transaction data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● When the processing is necessary to establish, exercise, or protect a right. ● When the processing is necessary for the data subject to fulfill his or her legal obligations.
Personal data collection methods	Your information relating to legal transactions is collected from printed application forms and information sent by e-mail by the data subject.
Spatial security information
Personal data subject to processing	● CCTV camera recordings information
Objectives of the data processing process	Maintaining spatial security, conducting events in accordance with the law, conducting and following up on legal transactions, and providing information to responsible persons and concerned institutions.
Legal justifications for processing personal data	Loftry processes your spatial security data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If the processing is necessary for the data controller to fulfill his legal obligations. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your information relating to location security is collected from printed application forms, email, and closed circuit camera systems.
Financial information
Personal data subject to processing	● Bank account information ● IBAN bank account identifier number
Objectives of the data processing process	Managing events legally, managing legal transactions and following them up, providing information to responsible persons, institutions, and departments concerned, managing communication operations, managing work activities/ controlling them, managing production operations of goods and services, managing contracting operations, managing work related to managing relationships with customers, carrying out work for the purpose. Including achieving customer satisfaction, managing communication work, managing production processes for services and products, managing logistical activities, managing support work in the after-sales phase of the service/product, managing strategic planning events, managing financial and accounting work, managing product/service marketing activities, and managing pricing events.
Legal justifications for processing personal data	Loftry processes your financial data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● When the processing is necessary for the data subject to fulfill his legal obligations. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your financial information is collected through information provided by the data subject, emails, contracts, telephone calls, and information systems.
Video and audio recording information
Personal data subject to processing	● Image ● Video recordings ● Audio recordings
Objectives of the process	Managing/ controlling work events, managing customer relations work, managing events related to customer satisfaction.
Legal justifications for processing personal data	Loftry processes your video and audio recording data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned. ● In the event of the express consent of the person concerned.
Personal data collection methods	Your video and audio recording information is collected from calls you have with customer service agents, digital recording devices, image capture devices, and video recordings.

The potential business partner who is a real person/ the person authorized on behalf of the potential business partner who is a legal person
Personal identification information
Personal data subject to processing	● Name and surname ● The signature
Objectives of the processing of personal data	Conducting events in accordance with the law, managing and following up on legal transactions, sending information to responsible persons and concerned departments, managing storage and archiving work, managing contracting processes, and managing the process of setting prices and wages.
Legal justifications for processing personal data	Loftry processes your identity data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your identity data is collected through printed and electronic application forms, from e-mail, from information provided by the data subject, and from the contract.
Contact Information
Personal data subject to processing	● E-mail address ● Work phone number ● Mobile phone number
Objectives of the processing of personal data	Conducting activities in accordance with the law, managing and following up on legal transactions, sending information to responsible persons and concerned departments, managing serial supply operations and contracting operations, managing the process of setting prices and wages.
Legal justifications for processing personal data	Loftry processes your contact data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your contact data is collected through printed and electronic application forms, email, information provided by the data subject, and the contract.
Job information
Personal data subject to processing	● Job information/ job title ● Workplace information ● Information about the professional chamber in which the person is registered and the registration number in the chamber
Objectives of the processing of personal data	Managing communication events, managing/ overseeing work events
Legal justifications for processing personal data	Loftry processes your job data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your job information is collected from printed application forms and information provided by the person concerned.
Financial information
Personal data subject to processing	● Information on bills, securities, checks, and current accounts ● Bank account information.
Objectives of the processing of personal data	Conducting work activities in accordance with the law, managing and following up on legal transactions, providing information to responsible persons and relevant institutions, managing product/ service sales operations, contracting operations management, and managing the process of setting prices and wages.
Legal justifications for processing personal data	Loftry processes your financial data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms.
Personal data collection methods	Your financial data will be collected from printed and electronic application forms, from e-mail, from information provided by the person concerned, and from the contract.

The business partner is a real person/ the person authorized on behalf of the business partner is a legal person
Personal Information
Personal data subject to processing	● Name and surname ● The signature
Objectives of the processing of personal data	Managing events in accordance with the law, managing/monitoring work events, managing logistical activities, managing operations to provide support in the after-sale of goods/ services, managing organization and discipline operations, managing communication events, managing sales operations of goods/ services.
Legal justifications for processing personal data	Loftry processes your identity data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● When the processing is necessary for the data subject to fulfill his or her legal obligations. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your identity data is collected through face-to-face interviews, and telephone calls with the customer service team, and from printed and electronic order forms, e-mail, information provided by the data subject, and the contract.
Contact Information
Personal data subject to processing	● E-mail address ● Work phone number ● Mobile phone number
Objectives of the processing of personal data	Managing events in accordance with the law, managing/monitoring work events, managing logistical activities, managing support processes in the after-sale of goods/ services, managing organization and discipline processes, managing communication activities, managing contracting processes.
Legal justifications for processing personal data	Loftry processes your contact data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your contact data is collected through printed and electronic application forms, from e-mail, the information provided by the data subject, and the contract.
Job information
Personal data subject to processing	● Job information/ job title ● Workplace information ● Information about the professional chamber in which the person is registered and the registration number in the chamber
Objectives of the processing of personal data	Managing communication events, managing and controlling work events.
Legal justifications for processing personal data	Loftry processes your job data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms. ● If the data processing is necessary for the legitimate benefit of the person responsible for it, provided that this does not prejudice the fundamental rights and freedoms of the person concerned.
Personal data collection methods	Your job information is collected from printed application forms and from the information provided by the person concerned.
Financial information
Personal data subject to processing	● Information on bills, securities, checks, and current accounts. ● Bank account information.
Objectives of the processing of personal data	Organization and discipline management, communication events management, financial and accounting business management.
Legal justifications for processing personal data	Loftry processes your financial data within the framework of achieving the mentioned objectives based on the following legal justifications stipulated in Article Five of the Personal Data Protection Law: ● In the event that it is necessary to process the personal data of both parties to a contract, provided that this is directly related to the conclusion of the contract and the fulfillment of its terms.
Personal data collection methods	Your financial data is collected from printed and electronic application forms, from e-mail, the information provided by the data subject, and the contract.

To whom in Turkey can your personal data be transferred and what are the purposes of the transfer?

Under the Personal Protection Law and applicable laws:

Personal data will be shared with persons who have express authorization under applicable laws. Your personal data will also be shared with authorized persons and government institutions by a decision issued by a court or administrative authority that has been granted the authority to make this decision.
Pursuant to the service contract concluded between us and with regard to securing services and products from providers, we may share personal data on a limited basis with providers contracting with us for the purpose of managing emergency and urgent cases, conducting control/ discipline activities, managing occupational security/ safety activities, and managing work activities in a proper manner. In compliance with the law, managing logistics work, managing work activities/controlling them, managing contracting operations, managing financial and accounting work, following up on requests/ complaints, managing serial supply operations, managing and following up on legal transactions, purchasing and selling goods/services, maintaining spatial security, following up on the security of assets and transferred funds, managing emergency operations and urgent cases, conducting internal control/investigations/intelligence activities, and providing information to responsible persons and concerned institutions.
Data may also be partially shared with owners of ownership stakes in our company for the purpose of conducting internal control/ investigations/ intelligence activities, conducting oversight/ discipline activities, developing human resources plans, conducting risk management activities, managing contracting processes, following up on requests/ complaints, and accounting management and financial work, management of work activities/ control, management and follow-up of legal transactions, management of goods/ services sales activities, management of goods/ services production operations, management of performance monitoring operations, management of strategic planning operations, and management of company management activities.
Personal data may be shared on a limited basis with real persons and legal persons for the purpose of conducting activities in accordance with the law, managing and following up on legal transactions, managing/ monitoring work activities, managing the contracting process, and organizing events aimed at achieving customer satisfaction.
Personal data may be shared on a limited basis with customers to manage/ monitor events, manage the contracting process, manage product/service sales, and manage the production of goods/ services.
Personal data may be shared on a limited basis with Imtilak Group companies for the purpose of planning human resources work, managing the work of selecting candidates for employment/ training students and placing them in the appropriate place, managing/ monitoring work activities, managing activities that ensure business continuity, managing the contracting process, and managing the study process. Applications for job applicants, managing the process of selling goods/ services, managing production operations of goods and services, managing customer relationships, organizing events directed to gaining customer satisfaction, following up on requests/ complaints, managing financial and accounting work, maintaining spatial security, and managing security/occupational safety activities.
Private data may be shared on a limited basis with our business partners for the purpose of conducting emergency management and urgent situations, conducting internal control/ investigations/ intelligence work, managing activities that ensure business continuity, planning human resources work, selecting employment candidates/ training students, and placing them in the appropriate place, managing the process of examining job applicants, managing goods/ services production activities and operations, managing contracting processes, and maintaining employee rights and benefits.

Do we transfer your personal data outside Turkey?

We may share your personal data with service providers located abroad to manage archiving and storage activities, manage the information security process, manage communication operations, manage/ monitor work activities, manage archiving and storage operations, manage occupational security/ safety activities, and managing control/ discipline processes, planning human resources work, managing the processes of selecting candidates for employment/ training students, and placing them in the right place, managing the process of studying applications for job applicants, managing the business of selling goods/services, managing the process of producing goods/ services, and managing operations, contracting and managing the processes of setting prices and wages.
Data may be shared in public circles available to everyone to introduce the company on a broader scale, and to manage communication events, and your personal data may be shared through social media accounts, such as Facebook, Instagram, Twitter, YouTube, and others. These are platforms whose infrastructure centers are located outside Turkey, and you can view information related to your personal data that is subject to processing through social media accounts through the confidentiality policy pages on the social media platforms.
When obtaining your personal data from messaging applications WhatsApp, Telegram, etc., and through our e-mail accounts with the Microsoft Exchange service provider, whose servers are located outside Turkey, it is possible that this personal data will be transferred for the purpose of managing/monitoring activities and conducting oversight and disciplinary activities, and Planning human resources work, and managing storage and archiving operations, on a limited basis to the WhatsApp platform WhatsApp LLC, Meta Platforms Inc and other service providers based outside Turkey, based on the legal justification: “explicit consent” stipulated in the first paragraph of Article Nine. of the Personal Data Protection Law, and to obtain detailed information on this subject, you can visit the confidentiality principles and conditions page on the aforementioned platforms.

How long do we store your personal data?

If there is a specific period stipulated by the laws for personal data according to its type, it must be stored in accordance with what the law stipulates. However, in the event that there is no legal text specifying the duration of storage, personal data is stored for a period that varies according to the purpose of processing it, provided that this period is specific and reasonable.

Your rights relating to your personal data

Your rights regarding personal data are as follows:

To be informed whether your personal data is being processed or not.
The right to request information about processing once it occurs.
To know the purpose of processing your personal data and ensure that it is used in accordance with this purpose.
To know the third parties to whom your personal data has been transferred, whether inside or outside Turkey.
Request to correct errors in the event that data is processed incorrectly or incompletely.
Request the erasure or destruction of your personal data in accordance with the conditions related to this matter stipulated in the Personal Data Protection Law and applicable laws.
In the event that you request the deletion or destruction of your personal data as a result of incorrect or incomplete processing, you have the right to demand knowledge of the third parties to whom we have transferred your personal data.
Any person has the right to object to the results of processing personal data that are not in his favor, exclusively if the data is processed and analyzed through the established mechanisms and systems.
Demanding the removal of the damage resulting from the processing of personal data in violation of the Personal Data Protection Law.

How can you use your rights?

If you wish, you can submit requests related to personal data by filling out the “Loftry Personal Request Form”

Then submitting it to the group through one of the following means:

Send the request via your email address, which you have previously notified the group and is registered in its system, to the email address [email protected]
Apply in person using a valid ID card/ passport.
Send the application with a live signature and a copy of the ID card/passport attached to the address: “Mall of Istanbul, Office Block, Kat: 11, No: 91 Başakşehir/Istanbul.”
Sending via registered email through a secure electronic signature or through a mobile phone signature to the registered email address of the Imtilak Group [email protected]

According to the notification regarding the principles and basis for submitting applications to the evidence officer: The application submitted by the concerned person must include the name, surname, signature if the application is in writing, the Turkish ID number (passport number if the applicant is a foreigner), and the residential or workplace address for reception. Reports, an email to receive electronic notices if any, telephone number, fax number, and information related to the subject of the request.

The concerned person must include in his request to use his above-mentioned rights a clear explanation of the right to be used, and information that defines the subject of the request in a clear and understandable manner. Information and documents related to the request must also be attached.

The application must be submitted personally by the person concerned, and if a person applies on behalf of the person concerned, the authorization of the person concerned must be documented for the person applying through a legal authorization document (agency), and the application must include identity information, address, It must be accompanied by documents proving the identity of the applicant.

Applications submitted by a person other than the relevant person will not be evaluated if he or she does not have legal authorization.

How long does it take to respond to your requests regarding your personal data?

Your requests related to your personal data will be answered within a maximum period of 30 days from the date it reaches the relevant department after completing its evaluation. In the event that your request receives a negative evaluation, the rejection document will be sent, along with justifications for the rejection, to the mail address and e-mail address mentioned in the request, or through the means by which the request was sent, if possible.

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