Informing text on the Law on Protection of Personal Data

Informing text on the Law on Protection of Personal Data

Tronapay Ödeme Hizmetleri A.Ş. (“TronaPay”) pays a great importance to processing and keeping any kind of personal data of all real persons associated with TronaPay, including those who use its products and services in accordance with the Law on Protection of Personal Data numbered 6698 (“KVK Law”) and to the security of such data. Being aware of this responsibility, the personal data are processed in the capacity of “Data Officer” as defined in the KVK Law, as specified below and within the limits set by the legislation.

1. Collecting and Processing the Personal Data and Purposes of Processing

Your personal data are processed for the purposes of recording the identity of and the other required information on the person making the transaction for identifying him/her, issuing all records and documents to constitute the basis of the transaction in the electronic channels or paper environment, storing them for the period stipulated in the legislation and by the other authorities, complying with the local and international legislation, fulfilling the information and document keeping, reporting, information sharing and informing obligations stipulated by the BDDK, Republic of Turkey’s Central Bank (TCMB), Financial Crimes Investigation Board (MASAK) and the other authorities, for planning, statistics, works for improving customer satisfaction and service quality, for preventing fraudulence, ensuring security, making the information researches and evaluations related to our company’s products and services you requested, managing our legal processes, carrying out Tronapay’s human resources policies/works and fulfilling all obligations of our company against you and transferred to the authorized institutions. In addition to the foregoing, your personal data may be processed for carrying out communication, promotion, marketing and campaign activities for you, in case that you grant your permission.

2. The Persons to Whom Processed Data Can Be Transferred and for What Purposes

Collected personal data can be transferred to TronaPay’s business partners, suppliers, TronaPay’s authorized persons, shareholders, legally authorized public institutions and private entities for the justifications specified in the article 1 hereof, and to organizations from which we receive service, with which we make collaboration and which are program partners in order to carry out our activities, to local/foreign financial institutions, support organizations and independent audit companies, in cases where the legislation allows us to do so.

3. The Method of and Legal Reason for Collecting Personal Data

Kişisel veriler, her türlü sözlü, yazılı ya da elektronik ortamda, yukarıda yer verilen gerekçeler doğrultusunda Tronapay tarafından sunulan ürün ve hizmetlerin belirlenen yasal çerçevede sunulabilmesi ve bu kapsamda Tronapay’in sözleşme ve yasadan doğan yükümlülüklerini eksiksiz ve doğru bir şekilde ifa edilebilmesi için elde ile edilir. Bu hukuki sebeple toplanan kişisel veriler KVK Kanunu’nun 5. ve 6. maddelerinde belirtilen kişisel veri işleme şartları ve amaçları kapsamında bu metnin (1) ve (2) numaralı maddelerinde belirtilen gerekçelerle de işlenebilmekte ve aktarılabilmektedir.

4. Rights of the Owner of the Personal Data Specified in the Article 11 of the KVK Law

In case that the owners of the personal data communicate their requests regarding their rights to TronaPay with the methods mentioned below in this Informing Text, TronaPay shall conclude the request free of charge within thirty days by the latest, depending on the quality of the request. However, in case that the Personal Data Protection Board anticipates a charge, the charge determined by TronaPay in the tariff shall be received. In this scope, the owners of the personal data hold the below-specified rights:

To learn whether personal data was processed,
To request information, if personal data was processed,
To learn the purpose of processing personal data and whether they were used in accordance with the purpose,
To know the third persons at home and abroad, to whom personal data was transferred,
To request correction, in case that the personal data is processed incompletely or incorrectly and to request notification of the procedure conducted in this scope to the third persons to whom the personal data is transferred,
To request deletion or destruction of the personal data, in case of elimination of the reasons for processing, although it was processed in accordance with the provisions of the KVK Law and the other relevant laws, and to request notification of the procedure conducted in this scope to whom the personal data is transferred,
To object to occurrence of a result against it, by analyzing processed data, exclusively through automatic systems,
To request compensation of the loss, in case of any loss due to unlawfully processing the personal data,
To object to occurrence of a result against it, by analyzing processed data, exclusively through automatic systems,
To request compensation of the loss, in case of any loss due to unlawfully processing the personal data.

5. Cases That Do Not Require Consent

Pursuant to the clause 2, article 5 of the Law on Protection of the Personal Data numbered 6698, TronaPay holds the right to process the personal data without obtaining the express consent of the person, in the below-specified cases:

It is clearly stipulated in the laws,
Processing of the personal data of the parties to the agreement is required, provided that it is directly related to acting or executing an agreement,
Mandatory for TronaPay, in its capacity of the data officer to fulfill its legal obligation,
It was made public by the relevant person himself/herself,
Data processing is mandatory for establishing, exercising or protecting a right,
Data processing is mandatory for the licit benefits of TronaPay that is the data officer, provided that it does not harm the basic rights and freedoms of the relevant person.

6. The Personal Data Owner’s Application Right

Pursuant to the clause 1, article 13 of the KVK Law, the owners of the personal data, in order to exercise the aforementioned rights of theirs, shall complete the form available at the address www.tronapay.com, and shall send a signed copy of the form and their requests containing the descriptions of the right which is one of the rights specified in the article 11 of the KVK Law and which is requested to be exercised, completing the form;

via regular mail or by hand to the address Oruçreis Mah. Giyimkent Cad. Giyim Kent 2A1 Esenler – İstanbul,
via electronic mail to the address info@tronapay.com.tr by scanning the form.