Our company, GUSTO GİYİM SANAYİİ ve TİCARET ANONİM ŞİRKETİ, is the "Data Controller" in accordance with the Law No. 6998 on the Protection of Personal Data published in the Official Gazette on 07.04.2016. We attach utmost importance to the security of your personal data. With this awareness, we process and store all kinds of personal data belonging to individuals associated with the Company, including those who benefit from our products and services, in compliance with the Law No. 6698 on the Protection of Personal Data and within the limits determined by the legislation. As the "Data Controller" in accordance with the definition in the Law on the Protection of Personal Data, we process your personal data in the manner explained and within the framework set by the legislation, fully understanding our responsibility.
Definitions
Data: It refers to the information stored electronically on a computer or in certain paper-based filing systems.
Personal Data: It refers to any kind of information related to an identified or identifiable natural person. GUSTO may collect data, generally referred to as "web log information" (including information such as users' internet browsers, mobile devices, operating systems, visited pages, other internet pages accessed by users, date and time of visits to the relevant internet page, specific pages visited, and more) through internet websites to understand customer preferences, provide better service, and for similar purposes. In this context, cookies may be used when visiting the pages on the internet site. In the event that personal data is obtained through these means or the data collected through this method is processed together and if they refer to a specific person, cookies and web log information will also be subject to this Policy.
Sensitive Personal Data: It refers to data related to race, ethnic origin, political opinions, philosophical beliefs, religion, sect, other beliefs, dress and clothing, association, foundation, or union membership, health, sexual life, criminal conviction and security measures, and biometric data. Sensitive data can only be processed under strict conditions and usually requires the explicit consent of the data subject.
Data Subject: It covers all natural persons, including employees, whose Personal Data is processed by GUSTO. The data subject does not have to be a Turkish citizen or reside in Turkey. All data subjects have legal rights regarding their personal data.
Data Controller: It refers to the real or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. These individuals have responsibilities to establish practices and principles in accordance with the Law. The data controller for all personal data used in GUSTO's business processes is GUSTO itself.
Data Processor: Any person who processes personal data on behalf of and based on the authority given by a data controller. Employees of the data controller are outside of this definition, but if applicable, suppliers, business partners, and other third parties processing personal data on behalf of GUSTO may be included in this definition.
Data Processing: It covers all kinds of activities related to the use of data. It includes obtaining, recording, or storing data, as well as operations performed on the data such as organizing, changing, retrieving, using, disclosing, deleting, or destroying the data. Transferring data to third parties also constitutes data processing.
GUSTO as the data controller may collect, record, store, retain, modify, update, periodically review, reorganize, classify, process, and share your personal and/or sensitive personal data, in whole or in part, through various channels including our call centers, written communication channels, social media pages, mobile communication channels, in-store communication channels, and/or any other channels, within the scope of your consent. The data may also be shared/transferred to third-party individuals or legal entities with whom GUSTO collaborates or with whom GUSTO is legally obligated, or with competent public institutions and organizations in Turkey or abroad, as required by law or service-related obligations.
GUSTO informs you that your personal data may be processed in accordance with the Law No. 6698 on the Protection of Personal Data and related legislation, solely for purposes such as enabling GUSTO customers to benefit from our services, informing you about our campaigns with your consent, recording your suggestions and complaints, improving our service standards, and determining and implementing GUSTO's commercial and business strategies.
GUSTO processes your personal data in accordance with the Law No. 6698 on the Protection of Personal Data and related legislation, taking the necessary security and privacy measures, either with your explicit consent or based on the security and privacy principles specified in the Law, both domestically and abroad, as required by the activities of the Company, in order to establish and maintain the business relationship between the data owners and our customers, and/or to conduct negotiations for this purpose, provide services, opportunities, and facilities, and improve the quality of services. GUSTO may share your personal data with our group companies, business partners, customers with whom we have contractual agreements or provide services, suppliers, auditing firms, or competent public institutions or organizations authorized to request such data, or other relevant authorities, within the framework of legal or service-related requirements.
EXCEPTIONS WHERE CONSENT IS NOT REQUIRED
In accordance with Article 5(2) of the Law No. 6698 on the Protection of Personal Data, personal data of the parties to a contract may be processed without explicit consent if it is clearly provided for in the laws, directly related to the establishment or performance of a contract, necessary for the fulfillment of the legal obligation of the data controller as the data controller, publicly disclosed by the data subject, necessary for the establishment, exercise, or protection of a right, required for the legitimate interests of the data controller or a third party, provided that it does not harm the fundamental rights and freedoms of the data subject.
Disclosure, use, and transfer of data to fulfill GUSTO's legal obligations arising from the applicable legislation, and/or for the purpose of meeting the obligations to disclose secrets to persons who may request them under the laws, and/or for the purpose of fulfilling the obligation to transfer data, which may be required by the legislation or publicly disclosed or required to be disclosed in official records, balance sheets, or activity reports, without the need for separate consent for such data, GUSTO has the right to disclose, share, process, and transfer such data to the relevant individuals without breaching the confidentiality obligations of GUSTO.
RIGHTS
GUSTO will respond to the following requests of data subjects:
a) To learn whether GUSTO processes their personal data and, if so, which personal data is being processed,
b) To obtain information about the purposes of the processing activities,
c) To know the third parties to whom GUSTO transfers personal data, whether domestically or internationally,
d) To request the correction of personal data if it is incomplete or inaccurate,
e) To request the erasure or destruction of personal data in accordance with the law,
f) If personal data is corrected, erased, or destroyed, to request that these actions be notified to third parties to whom the personal data has been transferred,
g) To object to any negative consequences arising from the analysis of processed data solely through automated systems,
h) To obtain a copy of their personal data.
You can contact us regarding your opinions and questions.
In accordance with Article 13(1) of the Law on the Protection of Personal Data, you can submit your request to exercise the above-mentioned rights to our Company in writing or through other methods determined by the Personal Data Protection Board.
INFORMATION OBLIGATION
GUSTO is obliged to inform the individuals whose data is being processed during the collection of Personal Data. The scope of this information obligation is as follows:
GUSTO will provide the necessary information through data collection tools from Third Parties for processing in its systems and will obtain informed consent from the data subjects as proof of fulfilling the information obligation. Personal Data may be collected by GUSTO through all sales channels, branches, websites, call centers, and similar channels, including electronic commerce, retail, and wholesale stores, both through automated or non-automated means, verbally, in writing, or electronically.
Written Collection of Personal Data: During the written collection of Personal Data, the information obligation regarding the processing of data will be fulfilled by referring to this Policy and using revised relevant forms and information. Additionally, all types of forms and contracts, including the Consent for Communication Forms obtained from individuals with whom a customer relationship is established, will be revised to demonstrate the data subject's explicit consent regarding the processing of Personal Data, even if the processing of the relevant data group may be considered an exception within the scope of the Law. New forms, documents, and notifications that demonstrate compliance with the law will be used in customer relationships, and all relevant employees will be trained to provide the individual with sufficient detailed information and references. It is ensured that the collection of Personal Data is obtained through written forms that include informed consents.
Verbal Collection of Personal Data: Existing customers who are already processed based on the Consent for Communication Forms will be provided with information regarding the processing of Personal Data in any way, including obtaining new data from individuals who are not currently customers or through the Call Center. During the verbal collection of data, it will be reminded that the conversation is recorded after prior information is provided, and confirmation will be obtained that their Personal Data will be processed in accordance with this Policy and, if applicable, included in the existing Consent for Communication Forms. Employees and the Call Center will be reevaluated and implemented within this framework.
Electronic Collection of Personal Data: Data obtained through electronic commerce channels and other internet channels of GUSTO will also be revised, including all contracts, documents, links, and web pages that involve the collection and processing of Personal Data, to fulfill the information obligation regarding the processing of Personal Data. This Policy will be accessible from all internet pages, and systems will be established by GUSTO on its internet websites that require the approval of data processing for data obtained through links that may require data collection. Unless explicit consent for the processing of Personal Data is clearly indicated, no information or document entered will be automatically recorded by any GUSTO system and will not be processed in any way.
CONCLUSION AND RESPONSIBILITY
GUSTO is improving its processes to manage all its operations in compliance with the Law and fulfill the requirements of the Law on the Protection of Personal Data, in line with the Constitution of the Republic of Turkey, the Turkish Penal Code, and international general principles of personal data protection. Within this scope, this general Policy, prepared to be implemented in all business units, binds all business units and employees regarding the processing of Personal Data by GUSTO.
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