DAIKIN ISITMA VE SOĞUTMA SİSTEMLERİ SANAYİ TİCARET ANONİM ŞİRKETİ DISCLOSURE FOR PHYSICAL AND ONLINE APPLICATION, SALES, AND AFTER SALES SUPPORT PROCESSES

  1. Data Controller 

Your personal data is processed by Daıkın Isıtma ve Soğutma Sistemleri Sanayi Ticaret Anonim Şirketi, registered  at the address Gülsuyu Mahallesi Burçak Sok. No: 20 A Maltepe/İstanbul, under the registration no. 801969-0 of  İstanbul Trade Registry Office (“Company”) in its capacity as the data controller, within the scope of the  provisions of the Law no. 6698 on Protection of Personal Data (“LPPD”) and pursuant to this Disclosure for  Physical and Online Application, Sales, and After Sales Support Process (“Disclosure”). 

Our Company respects your confidentiality and your rights regarding protection of your personal data, and  strives to establish and maintain a relationship based on trust with you. In this context, our Company processes  your personal data in compliance with all legal provisions on protection of personal data, particularly the LPPD,  and takes all security measures to ensure safety of your data. This Disclosure explains the scope under which  your personal data, collected if you are a customer, user, and/or real entity  shareholder/employee/representative of our corporate customer, are processed within the framework of  applications, sales and/or after sale support activities regarding products and/or services offered physically (e.g.  our stores, dealers, distributors, contracted chain stores, and authorized service shops as well as other points of  sale) and online (e.g. our mobile applications and websites) by our Company or on behalf and account of our  Company. You can find detailed information on protection of your personal data by our Company in Daikin  Isıtma ve Soğutma Sistemleri Sanayi Ticaret Anonim Şirketi Personal Data Protection and Processing Policy  available at the address, https://airfel.com/tr/tr/sozlesmeler/kisisel-verilerin-korunmasi

  1. Methods for Collection of Your Personal Data 

Your personal data are collected by our Company by fully automated or partially automated means or non automated means as part of a data recording system, from electronic and/or physical media through physical  stores, agents, dealers, distributors, contracted chain stores, and authorized service shops, as well as  construction project companies and similar business partners, websites and mobile applications of our  Company, particularly https://airfel.com/tr/tr , printed forms, customer communication center, live help e mail, SMS, telephone, fax, courier / mail, head office help desks of our Company, request / complaint platforms,  social media platforms, online meeting / communication platforms, internal information systems and  competent public institutions and organizations, as well as integrated systems owned by other relevant 3rd  parties, and other methods (channels) that might be added to these in the future. 

  1. Categories of Your Processed Personal Data and Purposes for Processing of Personal Data and Legal Grounds for Processing 

3.1 In Terms of Physical Application, Sales, and After Sales Support Processes: 

Categories of your personal data collected and processed within the scope of communication, audit, and  reporting management processes, as well as purposes and legal grounds for collection and processing of your  limited personal data in such personal data categories within the scope of application and sales management  for products and/or services offered by our Company and/or on physical environments on behalf and account of  our Company by means of our stores, dealers, distributors, contracted chain stores, as well as other points of  sale and similar business partners; order management; communication management following product dispatch  and shipment; after sale support services management (e.g. product replacement / return, maintenance /  repair, delivery / installation, service, warranty / additional warranty, fault support);  

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project proposal management; solution services management; invoice issuance / modification / cancellation,  payment and collection, as well as other accounting and financial affairs management including mail order and  virtual POS application; operation management; supply chain management; logistics and transport  management; customer relations and satisfaction management including satisfaction surveys; remote product  monitoring and control management; request / complaint / recommendation management; storage and archive  management; audit and internal audit management; legal and advisory affairs management, including  fulfillment of legal obligations and performance of dispute procedures, to which the Company is a party and/or  with which the Company is associated (e.g. lawsuit, enforcement, mediation); information security  management; quality standards management including product / service / process improvement; compulsory  communication management and compliance with policies and procedures of our shareholder are explained in  detail below. 

Important Note: We would like to remind that private personal data (e.g. religion and blood type information)  pertaining to corporate customers and employees in signatory circulars and other documents, which might be  requested in contract negotiation, execution, and performance processes, should not be submitted or  submitted by obfuscation to our Company and, accordingly, our Company does not intend to process private  personal data in terms of the processes within the scope of this Disclosure. 

Personal Data Category 

Purposes for Processing of Personal Data and Legal Grounds for Processing

 

Identity Data

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of express stipulation in the legislation pursuant to clause (a), the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Conducting Finance and Accounting Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Receiving and Evaluating Recommendations Aimed at Improvement of Business Processes 

Conducting Business Continuity Activities 

Conducting Logistics Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Customer Satisfaction Activities 

Conducting Risk Management Processes 

Conducting Retention and Archiving Activities 

Conducting Contractual Processes

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Follow-up of Requests / Complaints 

Ensuring Security of Data Controller Operations 

Providing Information to Competent Individuals, Institutions, and  Organizations

Contact Data 

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of express stipulation in the legislation pursuant to clause (a), the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Conducting Finance and Accounting Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Receiving and Evaluating Recommendations Aimed at Improvement of Business Processes 

Conducting Business Continuity Activities 

Conducting Logistics Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Customer Satisfaction Activities 

Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Ensuring Security of Data Controller Operations 

Providing Information to Competent Individuals, Institutions, and  Organizations

Request / Complain /  

Recommendation Data

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes:

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Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Receiving and Evaluating Recommendations Aimed at Improvement of Business Processes 

Conducting Logistics Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Customer Satisfaction Activities 

Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Providing Information to Competent Individuals, Institutions, and  Organizations

Audio-Visual Data 

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Conducting Business Continuity Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Providing Information to Competent Individuals, Institutions, and  Organizations

Financial Data 

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of express stipulation in the legislation pursuant to clause (a), the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), 

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the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Conducting Finance and Accounting Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting / Auditing Business Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Good / Service Manufacturing and Operation Processes Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Providing Information to Competent Individuals, Institutions, and  Organizations

Customer Transaction Data (Processed if you buy products and/or services directly from our Company or if you utilize products and/or services of our Company.) 

 

 

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Conducting Finance and Accounting Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Receiving and Evaluating Recommendations Aimed at Improvement of Business Processes 

Conducting Business Continuity Activities 

Conducting Logistics Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Customer Satisfaction Activities 

Conducting Retention and Archiving Activities 

Conducting Contractual Processes

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Follow-up of Requests / Complaints 

Ensuring Security of Data Controller Operations 

Providing Information to Competent Individuals, Institutions, and  Organizations

Professional Experience Data 

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Conducting Logistics Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Providing Information to Competent Individuals, Institutions, and  Organizations

Legal Action Data

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting / Auditing Business Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes

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Conducting Good / Service Manufacturing and Operation Processes Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Providing Information to Competent Individuals, Institutions, and Organizations

Risk Data 

(Processed only if you are a real  person shareholder of our  

corporate customer.)

In case obtained specific to financial adequacy control management process in accordance with paragraph 2 of article 6 of the LPPD, processing is performed within the scope of the condition of explicit consent for personal data processing (legal ground) and for the following purposes: 

Conducting Audit / Ethics Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting / Auditing Business Activities 

Conducting Good / Service Sale Processes 

Conducting Risk Management Processes 

Conducting Retention and Archiving Activities


3.2 In Terms of Online Application, Sales, and After Sales Support Processes: 

Categories of your personal data collected and processed within the scope of communication, audit, and  reporting management processes, as well as purposes and legal grounds for collection and processing of your  limited personal data in such personal data categories within the scope of application and sales management  for products and/or services offered by our Company and/or on behalf and account of our Company; after sale  support services management (e.g. product replacement / return, maintenance / repair, delivery / installation,  service, warranty / additional warranty, fault support); order management; communication management  following product dispatch and shipment; invoice issuance / modification / cancellation, payment and  collection, as well as other accounting and financial affairs management; operation management; supply chain  management; project proposal management; solution services management; logistics and transport  management; mobile application management (e.g. Daikin Online Controller, Airfel Scala, I Touch Manager, I  Tablet Controller, Onecta Wifi, Daikin App, and Nethome Plus); remote product monitoring and control  management; product selection method (e.g. Web Express and Daikin Applied Tools); customer relations and  satisfaction management including satisfaction surveys; request / complaint / recommendation management;  storage and archive management; audit and internal audit management; legal and advisory affairs  management, including fulfillment of legal obligations and performance of dispute procedures, to which the  Company is a party and/or with which the Company is associated (e.g. lawsuit, enforcement, mediation);  information security management; quality standards management including product / service / process  improvement; compulsory communication management and compliance with global policies and procedures of  our shareholder are explained in detail below. 

Personal Data Category 

Purposes for Processing of Personal Data and Legal Grounds for Processing

 


Identity Data 

Your personal data in this category are processed within the scope of  

personal data processing conditions (legal grounds) of express stipulation in  

the legislation pursuant to clause (a), the need to process personal data of  

contractual parties, provided that it is directly related to drawing up or  

executing an agreement pursuant to clause (c), the need for the data  

controller to fulfill a legal obligation pursuant to clause (ç), the need to  

process data for the establishment, exercise or protection of any right  pursuant to clause (e),  

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and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Conducting Finance and Accounting Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Conducting Business Continuity Activities 

Receiving and Evaluating Recommendations Aimed at Improvement of Business Processes 

Conducting Logistics Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Customer Satisfaction Activities 

Conducting Risk Management Processes 

Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Ensuring Security of Data Controller Operations 

Providing Information to Competent Individuals, Institutions, and  Organizations

Contact Data

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of express stipulation in the legislation pursuant to clause (a), the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Conducting Finance and Accounting Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Conducting Business Continuity Activities

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Receiving and Evaluating Recommendations Aimed at Improvement of Business Processes 

Conducting Logistics Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Customer Satisfaction Activities 

Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Ensuring Security of Data Controller Operations 

Providing Information to Competent Individuals, Institutions, and  Organizations

Request / Complain /  

Recommendation Data

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Receiving and Evaluating Recommendations Aimed at Improvement of Business Processes 

Conducting Logistics Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Customer Satisfaction Activities 

Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Providing Information to Competent Individuals, Institutions, and  Organizations

Audio-Visual Data 

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e),

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and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Conducting Business Continuity Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Providing Information to Competent Individuals, Institutions, and  Organizations

Financial Data 

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of express stipulation in the legislation pursuant to clause (a), the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Conducting Finance and Accounting Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting / Auditing Business Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Good / Service Manufacturing and Operation Processes Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Providing Information to Competent Individuals, Institutions, and  Organizations

Customer Transaction Data (Processed if you buy products and/or services directly from our Company or if you utilize products 

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for 

 

the data controller to fulfill a legal obligation pursuant to clause (ç), 

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and/or services of our Company.) 

the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Conducting Finance and Accounting Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Receiving and Evaluating Recommendations Aimed at Improvement of  Business Processes 

Conducting Business Continuity Activities 

Conducting Logistics Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Customer Satisfaction Activities 

Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Ensuring Security of Data Controller Operations 

Providing Information to Competent Individuals, Institutions, and  Organizations

Location Data 

In case provision through the mobile application specific to the mobile application management in accordance with paragraph 1 of article 5 of the LPPD, your personal data in this category are processed within the scope of the condition of explicit consent for personal data processing (legal ground) and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Retention and Archiving Activities 

Follow-up of Requests / Complaints 

Providing Information to Competent Individuals, Institutions, and  Organizations

Professional Experience Data 

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of the need to process personal data of contractual parties, provided that it is directly related to 

drawing up or 

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executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting Communication Activities 

Conducting / Auditing Business Activities 

Conducting Logistics Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Good / Service Manufacturing and Operation Processes Conducting Customer Relations Management Processes Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Providing Information to Competent Individuals, Institutions, and  Organizations

Legal Action Data 

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of the need to process personal data of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting / Auditing Business Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Good / Service Manufacturing and Operation Processes Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Providing Information to Competent Individuals, Institutions, and Organizations

Process Security Information 

Your personal data in this category are processed within the scope of personal data processing conditions (legal grounds) of the need to process 

personal data

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of contractual parties, provided that it is directly related to drawing up or executing an agreement pursuant to clause (c), the need for the data controller to fulfill a legal obligation pursuant to clause (ç), the need to process data for the establishment, exercise or protection of any right pursuant to clause (e), and the need to process data for legitimate interests of the data controller, provided that fundamental rights and freedoms of the relevant person are not impaired pursuant to clause (f) of paragraph 2 of article 5 of the LPPD, and for the following purposes: 

Conducting Information Security Processes 

Conducting Audit / Ethics Activities 

Conducting Activities in Compliance with the Legislation Follow-up and Conduct of Legal Affairs 

Conducting Internal Audit / Investigation / Intelligence Activities Conducting / Auditing Business Activities 

Conducting Good / Service After Sale Support Services Conducting Good / Service Sale Processes 

Conducting Customer Relations Management Processes Conducting Retention and Archiving Activities 

Conducting Contractual Processes 

Follow-up of Requests / Complaints 

Ensuring Security of Data Controller Operations 

Providing Information to Competent Individuals, Institutions, and Organizations

Important Reminder: We would like to remind that private personal data (e.g. religion and blood type  information) pertaining to corporate customers and employees in signatory circulars and other documents,  which might be requested in contract negotiation, execution, and performance processes, should be submitted  by obfuscation to our Company and, in this scope, our Company does not intend to process private personal  data in terms of the processes within the scope of this Disclosure. 

  1. Transfer of Your Personal Data to Local and/or Foreign Third Parties 

Within our company, only our employees with limited access authorization in terms of the purposes detailed  above can access your personal data to perform their duties, and your personal data are not transferred to local  and/or foreign third parties in the absence of circumstances for transfer, as regulated in article(s) 8 and/or 9 of  the LPPD. However, your personal data, processed within the scope of each personal data category mentioned  above, can be transferred to the following recipient groups in compliance with articles 8 and/or 9 of the LPPD  and also in the presence of abovementioned personal data processing conditions (legal grounds) for the  relevant data category in terms of transfer purposes: 

  • Your personal data, limited to identity, contact, request / complaint / recommendation, visual and audio,  financial, customer transaction, location, professional experience, transaction security, risk and legal action  personal data categories, to our suppliers including our shareholder acting in the capacity of local and/or  foreign service provider for the purposes determined under the relevant category for each data category  mentioned above, and particularly for the purpose of providing products and/or services for maintenance  of company activities (e.g. CPA, tax and legal consultants, audit firms, companies that offer logistics  services, companies that offer services in terms of call center records, as well as information technologies  and data hosting service providers), 

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  • Your personal data, limited to identity, financial, and customer transaction personal data categories, to  local and/or foreign banks and payment institutions and payment systems institutions, for the purposes  determined under the relevant category for each data category mentioned above, and particularly for the  purposes of planning and/or performance of payment transactions concerning products / services,  
  • Your personal data, limited to identity, contact, request / complaint / recommendation, customer  transaction, professional experience, and legal action personal data categories, to our local and/or foreign  distributors, dealers, authorized service shops, and point of sales, for the purposes determined under the  relevant category for each data category mentioned above, and particularly for the purposes of ensuring  business continuity within the scope of our Company’s operations and engaging in potential cooperations, 
  • Your personal data, limited to identity, contact, request / complaint / recommendation, financial,  transaction security, customer transaction, professional experience, risk, and legal action personal data  categories, to our foreign shareholder, for the purposes determined under the relevant category for each  data category mentioned above, and particularly for the purposes of planning and/or performance of  communications, audit, and reporting activities in terms of ensuring compliance with global policies and  procedures of our shareholder, 
  • Your personal data, limited to identity, contact, request / complaint / recommendation, financial, customer  transaction, legal action, transaction security, risk, and professional experience personal data categories, to  local and/or foreign potential buyers, sellers, and other respondent parties of the transaction, and their  employees, consultants, and database service providers involved in the relevant process under the  obligation of confidentiality, for the purposes determined under the relevant category for each data  category mentioned above, and particularly for the purposes of performance of legal and financial  inspection activities of our Company in potential mergers, takeovers, joint ventures, demergers, and other  structural changes, and 
  • Your personal data, limited to identity, contact, request / complaint / recommendation, audio-visual,  financial, customer transaction, location, professional experience, risk, transaction security, and legal  action personal data categories, to local competent public institutions and organizations (e.g. courts,  notaries, tax offices) for the purposes determined under the relevant category for each data category  mentioned above, and particularly for the purposes of performance of legal obligations of our Company  and follow-up of legal affairs. 
  1. Processing Duration of Your Personal Data 

Your personal data, obtained in the course of operations of our Company, are retained and destroyed pursuant  to the general principles and regulations specified in the policies and procedures of our Company, issued in line  with the provisions of particularly the Constitution, LPPD, the Regulation on Deletion, Disposal, or  Anonymization of Personal Data, and other applicable legislation. 

In this scope, your personal data shall be destroyed if all of the abovementioned personal data processing  conditions completely cease to exist. Your personal data processed based on the condition of explicit consent  for personal data processing shall be destroyed in the first destruction cycle if you withdraw your explicit  consent. Please review section 6 of this Disclosure in term of your requests for destruction of your personal  data. 

  1. Your Rights Pursuant to the LPPD 

We hereby inform you that you are entitled to the following rights as a data subject in accordance with article  11 of the LPPD: 

  • To find out whether your Personal Data was processed, 
  • To request pertinent information if your Personal Data was processed, 
  • To find out the purpose of processing and whether your Personal Data was purposefully used, To find out local and foreign third parties to whom your Personal Data was transferred, To request correction of your personal data if it was incompletely or incorrectly processed, and request  notification of this procedure to third parties to whom your personal data was transferred, 

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  • To request deletion or destruction of your personal data in case the reasons for processing no longer exist  and, in this scope and if your personal data were processed incompletely or incorrectly, to request  notification of performed procedures to third parties, to whom your personal data was transferred, even  though your Personal Data was processed pursuant to the LPPD and other provisions of applicable law, 
  • To object to an outcome against the person due to the analysis of processed data exclusively by means of  automated systems, 
  • To request compensation if they incur losses due to unlawful processing of personal data. 

You can submit your applications, concerning your rights mentioned above, to our Company by completing  https://airfel.com/tr/tr/sozlesmeler/kisisel-verilerin-korunmasi (in writing or electronically by means of  registered e-mail (KEP) address, secure e-signature, mobile signature or your e-mail address that you previously  notified to our Company and that is registered in our systems with information / documents* (e.g. T.R. ID no. or  passport number for citizens of our countries, residence / work address for notification, mobile phone /  telephone / fax number, e-mail address) that validate your identity in order to enable our Company to identify  that you are the real beneficiary) pursuant to the provisions of the Communiqué on Principles and Procedures  for Application to the Data Controller or through the channels specified in the Data Subject Application Form of  the data controller in compliance with the principle and procedure explained above and regulated in the  applicable legislation. Your applications shall be finalized at no charge, as soon as possible and at the latest  within thirty (30) days according to the nature of your request; however, a fee may be charged to you according  to the tariff to be determined by the Personal Data Protection Board if the procedure requires additional costs. 

We would like to remind you that no private personal data (e.g. religion or blood type information) should  be included in the scope of such documents.