INFORMATION TEXT
PURPOSE AND SCOPE OF THE POLICY
This Privacy Policy (“Policy”) has been prepared by Mila Teneva (“MILA TENEVA”) as the Data Controller in accordance with the Law No. 6698 on the Protection of Personal Data (“Law”) and relevant legislation to establish the general framework for personal data processing activities and to provide explanations regarding the principles adopted for the protection of personal data, thereby ensuring transparency and clarity regarding personal data processed by MILA TENEVA.
GENERAL PRINCIPLES OF PERSONAL DATA PROCESSING
MILA TENEVA’s personal data processing activities are based on the following principles:
- Compliance with the law and honesty,
- Ensuring that personal data is accurate and up-to-date when necessary,
- Processing for specific, explicit, and legitimate purposes,
- Being relevant, limited, and proportionate to the purposes for which the data is processed,
- Retaining the data for the period required by the relevant legislation or for the purpose for which it was processed.
Under these principles, MILA TENEVA processes and deletes personal data related to customers, guest customers, employees, job applicants, potential buyers and service users, dealers, suppliers and supplier representatives/employees, visitors, online visitors, shareholders/partners, business partners, and service providers in compliance with the Law and relevant legislation in physical or electronic environments, securely and in accordance with this Policy.
LEGAL BASIS FOR PERSONAL DATA PROCESSING
There are regulations regarding personal data processing in various laws. The basic principles for the protection of personal data are primarily determined by the Law No. 6698 on the Protection of Personal Data. Additionally, MILA TENEVA processes personal data based on laws such as the Law No. 6502 on the Protection of Consumers, the Distance Contracts Regulation, the Law No. 6563 on the Regulation of Electronic Commerce, the Commercial Communication and Commercial Electronic Messages Regulation, the Turkish Penal Code No. 5237, and the Law No. 5651 on the Regulation of Publications Made on the Internet and Combating Crimes Committed Through Such Publications.
MILA TENEVA’S OBLIGATION TO INFORM
MILA TENEVA fulfills its obligation to inform as per Article 10 of the Law and the Communique on Procedures and Principles for Fulfilling the Obligation to Inform (“Communique”). To meet this obligation, MILA TENEVA provides information texts and, when necessary, explicit consent texts to individuals based on the data processed.
Under this obligation to inform, the following information is provided to the Data Subjects in accordance with the Law:
- The identity of the data controller and, if applicable, its representative,
- The purposes for which personal data will be processed,
- To whom and for what purposes the processed personal data may be transferred,
- The method of collecting personal data and the legal basis for processing,
- Other rights listed in Article 11 of the KVKK.
CATEGORIES OF PERSONAL DATA
a) Member Customer
- Identity Data: Name, surname, identity card details, birth date, gender, Turkish ID number
- Contact Data: Address, email, mobile phone number, landline number
- Location Data: Location information
- Financial Data: Account number, IBAN number, invoice details, credit card usage information, bank customer number
- Customer Transaction Data: Purchased product information, order records, shopping history, special day records, commercial electronic message consent, utilized campaigns, delivery information, message and call center records
- Marketing Data: Cookie records, user past activities, targeting, records related to habits and preferences
- Legal Transaction Data: Requests and complaints records, attachment and alimony information, commercial electronic message consent, legal transaction file records, notifications, information in correspondence with judicial and administrative authorities
- Transaction Security Data: IP address, password information, traffic data, website/mobile app login/logout data, username information
- Risk Management Data: IP address, password, and username information
- Visual and Auditory Data: Call center records, camera recordings
b) Guest Customer
- Identity Data: Name, surname, Turkish ID number
- Contact Data: Address, email, mobile phone number, landline number, postal code
- Location Data: City, district
- Financial Data: Account number, IBAN number, invoice details, credit card usage information, bank customer number
- Guest Customer Transaction Data: Purchased product information, order records, shopping history, special day records, commercial electronic message consent, utilized campaigns, delivery information, message and call center records
- Marketing Data: Cookie records, targeting, records related to habits and preferences
- Legal Transaction Data: Requests and complaints records, commercial electronic message consent, legal transaction file records, information in correspondence with judicial and administrative authorities
- Transaction Security Data: Password information, traffic data, website/mobile app login/logout data
- Risk Management Data: IP address
- Auditory Data: Call center conversation records
c) Potential Product or Service Buyers / Online Visitor Data
- Transaction Security Data: Password information, traffic data, website/mobile app login/logout data
- Risk Management Data: IP address
- Legal Transaction Data: Requests and complaints records, legal transaction file records, information in correspondence with judicial and administrative authorities
d) Data of the Person to Whom the Purchased Product Will Be Delivered
- Identity Data: Name, surname, Turkish ID number, birth date, gender
- Contact Data: Address, email, mobile phone number, landline number, postal code
- Location Data: City, district
- Financial Data: Invoice details
e) Dealer/Dealer Candidate/Seller/Supplier/Seller Candidate/Seller or Supplier Employee or Representative Personal Data
- Identity Data: Name, surname, Turkish ID number
- Contact Data: Address, email, mobile phone number, landline number, postal code
- Location Data: City, district
- Financial Data: Account number, IBAN number, invoice details, credit card usage information, bank customer number
- Legal Transaction Data: Requests and complaints records, signature circular, signature declaration, activity certificate, trade registry gazette
- Visual and Auditory Data: Call center records, photos
PURPOSES AND LEGAL GROUNDS FOR THE PROCESSING OF YOUR PERSONAL DATA
We provide the information about the purposes and legal grounds for processing your personal data below:
a) Member Customer Data
- Verifying the identity information of customers performing transactions through the website/mobile app, performing membership processes, and granting customers the rights associated with membership
- Enabling customers to shop through the website and/or mobile app, communicating with customers regarding the products/services they have purchased or will purchase, and addressing their requests/complaints
- Fulfilling the obligations under the Distance Sales Agreement and relevant articles of the Law on the Protection of Consumers, and contacting customers regarding the terms and current status of the contracts, providing necessary information
- Creating invoice and accounting records for orders
- Organizing all records and documents that will serve as the basis for transactions in electronic (internet/mobile, etc.) or paper format
- Improving and developing the services offered to customers, executing business development processes
- Responding to information requests from relevant authorities
- Informing customers about products they may be interested in and transferring campaigns based on their interests
- Conducting market analysis, targeting, profiling, and analysis studies to carry out advertising, marketing, and promotional activities tailored to the customer’s preferences and interests, and sending commercial electronic messages for promotional, marketing, advertising, campaign, and celebration purposes
- Improving the experience of customers shopping through the website and/or mobile app, conducting loyalty processes for products and services, ensuring customer satisfaction, and organizing surveys electronically and/or physically through partner organizations
- Evaluating customers’ requests, suggestions, and complaints
- Ensuring information and transaction security while using our services
- Tracking and conducting legal processes
- Running and auditing business activities, improving and developing services
- Fulfilling our legal obligations and utilizing our rights arising from applicable laws
b) Guest Customer Data
- Verifying the identity information of guest customers performing transactions through the website/mobile app
- Enabling guest customers to shop through the website and/or mobile app, communicating with guest customers regarding the products/services they have purchased or will purchase, and addressing their requests/complaints
- Fulfilling the obligations under the Distance Sales Agreement and relevant articles of the Law on the Protection of Consumers, and contacting guest customers regarding the terms and current status of contracts, providing necessary information
- Creating invoice and accounting records for orders
- Organizing all records and documents that will serve as the basis for transactions in electronic (internet/mobile, etc.) or paper format
- Improving and developing the services offered to guest customers, executing business development processes
- Responding to information requests from relevant authorities
- Conducting market analysis, targeting, profiling, and analysis studies to carry out advertising, marketing, and promotional activities tailored to the guest customer’s preferences and interests, and sending commercial electronic messages for promotional, marketing, advertising, campaign, and celebration purposes
- Improving the experience of guest customers shopping through the website and/or mobile app, conducting loyalty processes for products and services, ensuring customer satisfaction, and organizing surveys electronically and/or physically through partner organizations
- Evaluating guest customers’ requests, suggestions, and complaints
- Ensuring information and transaction security while using our services