PRIVACY NOTICE ON THE PROTECTION OF PERSONAL DATA
This Privacy Notice has been prepared under Turkish Law No. 6698 on the Protection of Personal Data (“KVKK”) by KFD Yatırım Danışmanlık İnşaat Otomotiv İthalat İhracat ve Dış Ticaret Ltd. Şti. (“KFD” or the “Company”), acting as data controller, to inform visitors about personal data processed during their use of the www.kfd.com.tr website.
This English translation is provided for convenience. In the event of any discrepancy, the Turkish text of this Notice prevails.
1. Personal Data Processed
Depending on how you use the website and the features you enable, the following personal data may be processed:
Contact data: If you use the contact form, your full name, e-mail address and the content of the message you submit.
Newsletter data: If you request a newsletter subscription, your e-mail address and preferred site language.
Transaction security and technical data: IP address, request time, browser and device information, requested page or resource, and security and error logs. Digest values derived from the IP address and e-mail address may be processed for a limited period to prevent form abuse and repeated submissions within a short period.
Cookie and preference data: Information relating to the storage of your cookie and similar-technology choices in your browser.
Analytics data: If you enable analytics technologies, visited pages, session and interaction information, and browser, device and similar technical usage data.
Map-service technical data: If you enable Google Maps, technical data such as your IP address and browser and device information may be processed by the relevant service provider to display the map.
The Company does not request that you submit special categories of personal data through the contact form.
2. Purposes of Processing Personal Data
Your personal data is processed for the purposes of:
- receiving and responding to contact requests;
- providing information or a proposal concerning our services where requested;
- evaluating messages, requests, complaints and suggestions;
- creating and managing newsletter subscriptions;
- ensuring website security;
- preventing spam, automated submissions and other attempted abuse;
- detecting and resolving technical problems;
- measuring and analysing website use in accordance with your preferences;
- providing the map service in accordance with your preference; and
- complying with legal obligations arising from applicable legislation.
3. Collection Methods and Legal Grounds
Your personal data is obtained directly from you through website forms or, during your visit, by wholly or partly automated means through server logs, browser technologies, cookies and similar technologies.
The legal grounds for the processing activities are as follows:
Contact form: Where your request directly relates to establishing or performing a contract, Article 5(2)(c) of the KVKK; for other general communications, questions, complaints and similar requests, the Company's legitimate interests under Article 5(2)(f), provided that your fundamental rights and freedoms are not prejudiced.
Newsletter subscription: Where applicable, your explicit consent to receive newsletters and similar commercial or informational electronic communications and the electronic-communications permission you grant under applicable commercial electronic communications legislation.
Form and website security: The Company's legitimate interests under Article 5(2)(f) in ensuring information security and preventing spam, automated submissions and abuse, provided that your fundamental rights and freedoms are not prejudiced.
Server and technical security logs: The Company's legitimate interests under Article 5(2)(f) in ensuring website security, detecting technical problems and investigating security incidents.
Storage of cookie preferences: The Company's legitimate interests under Article 5(2)(f) in applying your preferences and maintaining the website's essential functions.
Google Analytics: Your explicit consent under Article 5(1) of the KVKK when you enable the analytics preference.
Google Maps: Your explicit consent under Article 5(1) of the KVKK when you enable the map service.
Statutory obligations and requests from competent authorities: Processing expressly provided for by law under Article 5(2)(a) and/or necessary for compliance with the data controller's legal obligations under Article 5(2)(ç) of the KVKK.
You may withdraw your consent at any time in relation to processing based on explicit consent. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
4. Cookies and Similar Technologies
Technologies necessary for the operation of the website are managed separately from analytics and third-party technologies used in accordance with your preferences.
Your cookie choice is stored in your browser's local storage and is used to allow the website to remember your selection.
Analytics services such as Google Analytics are not activated unless you expressly enable the analytics option.
Google Maps content is also activated in accordance with your preference. Once the map is enabled, your browser may communicate directly with Google's systems and Google may use cookies or similar technologies.
The current names, providers, purposes and storage periods of the cookies and similar technologies used are displayed in the Cookie Preferences panel. You may change your choices at any time through the same panel.
5. Transfers of Personal Data
Limited to the processing purposes and to the extent necessary, your personal data may be transferred to:
technical service providers for website hosting, database, security, maintenance and technical infrastructure services;
Google to provide Google Analytics or Google Maps only where you enable the relevant service in accordance with your preferences; and
competent public authorities and institutions where they are legally authorised and the applicable conditions are met, for compliance with the relevant legal obligations.
Such transfers may take place only to the extent described above.
Information submitted through the contact form and newsletter subscription is not additionally transferred to a third-party form-collection service.
6. Cross-Border Transfers of Personal Data
Some personal data may be transferred abroad because the website uses service providers located abroad or capable of processing data abroad.
If Google Analytics or Google Maps is enabled, the relevant technical and usage data may be processed by Google abroad.
Where the website's hosting or database infrastructure is located abroad, personal data held in that infrastructure may also constitute a cross-border transfer.
Cross-border transfers are carried out only where a transfer mechanism satisfying the requirements of Article 9 of the KVKK has been established.
7. Retention of Personal Data
Personal data is retained for the period necessary for the purpose for which it is processed and for any retention period prescribed by applicable legislation. When the reason for processing ceases to exist, it is erased, destroyed or anonymised in accordance with Article 7 of the KVKK and the relevant secondary legislation.
Digest values created to prevent form abuse are retained only for the period necessary to apply the submission limit and are disabled or deleted at the end of that period.
Storage periods relating to cookies and similar technologies are stated in the Cookie Preferences panel.
8. Your Rights under the KVKK
Under Article 11 of the KVKK, you have the right to learn whether your personal data is processed; request information if it has been processed; learn the purpose of processing and whether it is used in accordance with that purpose; know the third parties to whom it is transferred; request rectification of incomplete or inaccurate data; request erasure or destruction where the applicable conditions are met; request notification of these actions to recipients; object to an adverse result arising from analysis carried out exclusively by automated systems; and claim compensation for damage caused by unlawful processing.
You may submit requests concerning these rights, together with information and documents sufficient to verify your identity, in writing to the Company address below or to info@kfd.com.tr using one of the electronic methods prescribed by Article 13 of the KVKK and the Communiqué on the Procedures and Principles of Application to the Data Controller.
Requests are answered as soon as possible according to their nature and no later than 30 days. Applications are free of charge; where processing the request entails an additional cost, fees in the tariff determined by the Turkish Personal Data Protection Board may apply.
Data Controller
KFD Yatırım Danışmanlık İnşaat Otomotiv İthalat İhracat ve Dış Ticaret Ltd. Şti.
E-mail: info@kfd.com.tr
Address: Kızılırmak, Ufuk Univ. Cd No:10, 06510 Çankaya/Ankara, Türkiye