KVKK Clarification Text
DISCLOSURE TEXT REGARDING THE PROTECTION OF PERSONAL DATA OF CUSTOMERS, MEMBERS AND VISITORS
DATA CONTROLLER: GÜRMEN GİYİM SANAYİ VE TİCARET A.Ş.
This Disclosure Text has been prepared by Gürmen Giyim Sanayi ve Ticaret A.Ş. (“Gürmen”) to inform you about the processing, storage, and transfer of your personal data during the services we provide to you within the scope of the Personal Data Protection Law No. 6698 (“PDPL”) and related legislation.
The purpose of this Disclosure Text is to inform you in the most transparent manner about the methods of collection, purposes of processing, categories of recipients, legal grounds, and your rights regarding your personal data in accordance with Article 10 of the Personal Data Protection Law No. 6698 (“Law”) when you visit the websites of GÜRMEN, www.kip.com.tr (KIP), and www.ramsey.com.tr (Ramsey) (“Websites”), use the mobile application belonging to the same brand, become a member, make purchases through the website/mobile application where the brand’s products are sold, or send products/gifts on behalf of third parties; and participate in campaigns, competitions, lotteries, and other events organized by GÜRMEN.
1. PROCESSED PERSONAL DATA AND PURPOSES OF PROCESSING PERSONAL DATA
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PERSONAL DATA |
SCOPE |
PURPOSE OF PROCESSING |
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IDENTITY DATA |
Name, Surname, Date of Birth, Gender, Nationality, T.C. Identity Number, Signature |
Conducting Marketing Analysis Studies Based on Your Explicit Consent to the Sending of Electronic Commercial Messages Conducting Advertising/Campaign/Promotion Processes Based on Your Explicit Consent to the Sending of Electronic Commercial Messages Conducting Product/Service Marketing Processes Based on Your Explicit Consent to the Sending of Electronic Commercial Messages Conducting After-Sales Support Processes for Goods/Services, Measuring Customer Satisfaction, Improving Customer Experience, Evaluating Product and Service Quality, Conducting Satisfaction Surveys, Analyzing Survey Results, and Contacting Customers for the Purpose of Addressing Customer Dissatisfaction (Conversations conducted within the scope of customer satisfaction are carried out solely for the purpose of evaluating customer experience, reviewing requests and complaints, and providing solutions, without having the purpose of advertising, marketing, campaigns, or product promotion.) Conducting Goods/Service Sales Processes Conducting Customer Relationship Management Processes Conducting Finance and Accounting Processes Tracking Requests and Complaints Conducting Contract Processes Conducting Activities in Compliance with Legislation |
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CONTACT |
E-mail Address, Phone, Address, WhatsApp communication applications |
Conducting Marketing Analysis Studies Based on Your Explicit Consent to the Sending of Electronic Commercial Messages Conducting Advertising/Campaign/Promotion Processes Based on Your Explicit Consent to the Sending of Electronic Commercial Messages Conducting Product/Service Marketing Processes Based on Your Explicit Consent to the Sending of Electronic Commercial Messages Conducting Contract Processes Conducting After-Sales Support Processes for Goods/Services, Measuring Customer Satisfaction, Improving Customer Experience, Evaluating Product and Service Quality, Conducting Satisfaction Surveys, Analyzing Survey Results, and Contacting Customers for the Purpose of Addressing Customer Dissatisfaction (Conversations conducted within the scope of customer satisfaction are carried out solely for the purpose of evaluating customer experience, reviewing requests and complaints, and providing solutions, without having the purpose of advertising, marketing, campaigns, or product promotion.) Conducting Goods/Service Sales Processes Conducting Customer Relationship Management Processes Tracking Requests and Complaints Conducting Finance and Accounting Processes |
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PROCESSING SECURITY |
Password, login-logout records of the membership page |
Conducting Contract Processes Conducting Advertising/Campaign/Promotion Processes Conducting Loyalty Card Membership Processes Conducting Marketing Analysis Studies Based on Your Explicit Consent to the Sending of Electronic Commercial Messages In the Event of Conducting Product/Service Marketing Processes Based on Your Explicit Consent to the Sending of Electronic Commercial Messages |
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LOCATION |
Your location data obtained automatically by the website if you allow it through browser settings, or which can be added by you manually |
Conducting Customer Relationship Management Processes |
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| CUSTOMER TRANSACTION INFORMATION |
Purchase history information, message type, message subject, subject line, contact phone, order number, product name, message content, repair, exchange, return data, loyalty card information, customer requests and complaints, customer satisfaction survey results, NPS scores, customer satisfaction call records |
Conducting After-Sales Support Processes for Goods/Services Conducting Customer Relationship Management Processes Measuring Customer Satisfaction Improving Customer Experience Evaluating Product and Service Quality Conducting Satisfaction Surveys Analyzing Survey Results Contacting Customers for the Purpose of Addressing Customer Dissatisfaction (Conversations conducted within the scope of customer satisfaction are carried out solely for the purpose of evaluating customer experience, reviewing requests and complaints, and providing solutions, without having the purpose of advertising, marketing, campaigns, or product promotion.) Tracking Requests and Complaints |
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MARKETING |
Cookie records, information obtained through Marketing – Campaign studies; favorites, likes, behaviors, preferences, search activities, segments, cookie and advertising identifier/identity information, communication preferences, demographic information, customer requests/complaints, location |
Conducting Goods/Service Sales Processes Conducting After-Sales Support Processes for Goods/Services Conducting Advertising/Campaign/Promotion Processes Based on Your Explicit Consent to the Sending of Electronic Commercial Messages Conducting Finance and Accounting Processes Conducting Marketing Analysis Studies Based on Your Explicit Consent to the Sending of Electronic Commercial Messages Conducting Product/Service Marketing Processes Based on Your Explicit Consent to the Sending of Electronic Commercial Messages |
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VISUAL AND AUDITORY RECORDS |
CCTV visual recording information |
Conducting Activities in Compliance with Legislation Ensuring Physical Premises Security Conducting Occupational Health / Safety Activities Creating and Tracking Visitor Records |
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OTHER |
Passport, Flight Information (if you make purchases from our airport stores), Sole Proprietorship Information, Size – Measurement information |
Conducting Goods/Service Sales Processes Conducting Activities in Compliance with Legislation Conducting Contract Processes
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3. METHODS OF COLLECTION AND LEGAL GROUNDS FOR YOUR PERSONAL DATA
Your personal data is collected through our stores, websites, mobile applications, and call center using automatic, partially automatic, or non-automatic methods. In this context, your personal data is obtained by recording purchases, collections, deliveries, returns, exchanges, and other transactions carried out at Ramsey and Kip stores belonging to Gürmen, on their websites, and in their mobile applications; records obtained through security cameras and other technical systems; Loyalty Card membership processes; requests and complaints submitted by you; call center conversations; website and mobile application usage records; and information you provide orally or in writing to store employees.
In addition, feedback shared by you within the scope of NPS (Net Promoter Score) and similar satisfaction surveys conducted for the purposes of measuring customer satisfaction, improving customer experience, evaluating product and service quality, and addressing customer dissatisfaction, as well as information obtained during customer satisfaction conversations carried out to evaluate this feedback, may also be processed as personal data. (Satisfaction surveys and customer satisfaction conversations conducted within this scope are carried out independently of marketing activities and do not constitute electronic commercial messages.)
Furthermore, information and documents obtained from official institutions and organizations, judicial and administrative authorities, records related to inspection and evaluation processes, and other information transmitted to us within the scope of relevant legislation are also included among the methods of collecting personal data.
Within the framework of the above purposes and pursuant to the legal grounds specified in Articles 5/2 and 6 of the PDPL;
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PROCESSED PERSONAL DATA |
LEGAL GROUNDS |
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Identity Data, Contact Information, Address, Location, |
The data subject's explicit consent (in terms of electronic commercial messages, advertising, campaigns, and marketing activities), The necessity of processing the personal data of the parties to the contract, The establishment, protection, and exercise of a right, The necessity of processing for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject, are the legal grounds for processing. |
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Passport Information, Flight Information, Sole Proprietorship Information, Nationality, T.C. Identity Number, Signature personal data (if you make purchases from our airport stores), |
Provided that it is directly related to the establishment or performance of a contract, the necessity of processing the personal data of the parties to the contract is processed based on the legal grounds of necessity for the data controller to fulfill its legal obligations. |
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Password, login-logout records of the membership page are your personal data, |
Provided that it is directly related to the establishment or performance of a contract, the necessity of processing the personal data of the parties to the contract, Provided that it does not harm the fundamental rights and freedoms of the data subject, the necessity of processing for the legitimate interests of the data controller are the legal grounds for processing. |
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Cookie records, information obtained through Marketing-Campaign studies; favorites, likes, behaviors, preferences, search activities, segments, cookie and advertising identifier/identity information, communication preferences, survey answers, demographic information, customer requests/complaints, etc. are your personal data, |
Provided that it is directly related to the establishment or performance of a contract, the necessity of processing the personal data of the parties to the contract, The data subject's explicit consent, are the legal grounds for processing. |
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Purchase history information, message type, message subject, subject line, message content, order number, product name, invoice number are your personal data, customer requests and complaints, customer satisfaction survey results, NPS scores, customer satisfaction call records |
Provided that it is directly related to the establishment or performance of a contract, the necessity of processing the personal data of the parties to the contract, Within the scope of measuring customer satisfaction, conducting after-sales support processes, and improving customer experience; provided that it does not harm the fundamental rights and freedoms of the data subject, the necessity of processing for the legitimate interests of the data controller are the legal grounds for processing |
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Size – Measurement Information are your personal data, |
Provided that it is directly related to the establishment or performance of a contract, the necessity of processing the personal data of the parties to the contract, the establishment, protection, and exercise of a right, Provided that it does not harm the fundamental rights and freedoms of the data subject, the necessity of processing for the legitimate interests of the data controller are the legal grounds for processing. |
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Visual and Auditory Records are your personal data, |
Necessity for the data controller to fulfill its legal obligations Provided that it does not harm the fundamental rights and freedoms of the data subject, the necessity of processing data for the legitimate interests of the data controller are the legal grounds for processing. |
4. TRANSFER OF PERSONAL DATA
Your personal data may be shared by Gürmen in accordance with the purposes specified above and limited to the fulfillment of these purposes; with legally authorized public institutions and private individuals or organizations, and in cases where required by the legitimate interests of the data controller, with third parties to be specifically determined, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the PDPL, and may be processed domestically or abroad.
Your personal data may be transferred to public institutions and organizations authorized by law to request it; to our companies within the Gürmen Group; and to our business partners and suppliers with whom we cooperate for the purpose of providing our products and services (for example, cargo companies for product delivery, call center service providers for customer relations, etc.). These transfers are carried out pursuant to Articles 8 and 9 of the Law, within the framework of the processing purposes and legal grounds specified above.
5. PERSONAL DATA RETENTION PERIOD
Your personal data is stored securely in accordance with applicable legislation and is retained for the period stipulated in the relevant legislation or as necessary for the purposes for which it is processed, and in no event longer than the applicable limitation periods. When the purpose of processing no longer exists or the legal retention period has expired, your personal data is securely deleted, destroyed, or anonymized.
6. RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA
In accordance with Article 11 of the KVKK, data subjects whose personal data is processed have the following rights:
a. To learn whether their personal data is being processed,
b. To request information about the processing of their personal data,
c. To learn the purpose of the processing of their personal data and whether it is being used in accordance with that purpose,
d. To learn the identity of the third parties to whom their personal data is transferred domestically or abroad,
e. To request the correction of their personal data if it has been processed incompletely or inaccurately and to request that the action taken be notified to the third parties to whom the personal data was transferred,
f. To request the deletion, destruction, or anonymization of their personal data when the reasons for processing no longer exist and to request that the action taken be notified to the third parties to whom the personal data was transferred,
g. To object to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them,
h. To request compensation if they have suffered damage due to the unlawful processing of their personal data.
You may submit your requests and applications regarding your personal data to Gürmen through any of the following channels:
- In writing, by hand delivery or by mail:
Mehmet Nesih Özmen Mah. Keresteciler Sitesi Kızılcık Sok. No: 23, 34173 Merter / Güngören / Istanbul - By email: gurmen@gurmen.com.tr
- Via registered electronic mail (KEP) address: gurmengiyimas@hs01.kep.tr
- Via secure electronic signature, mobile signature, or the email address you have previously provided to Gürmen.
Your applications will be concluded within no later than thirty (30) days depending on the nature of the request.
If your application requires an additional fee, the fee determined in the tariff set by the Personal Data Protection Board may be charged.
Gürmen reserves the right to verify your identity before responding to the application.
Information required in your application:
- Your name, surname, and signature (if the application is in writing),
- Your T.C. Identity Number (or passport number or identity number if you are a foreign national),
- Your residential or business address for notification purposes,
- If any, your email address, telephone or fax number for notification purposes,
- The subject of your request,
- If any, information and documents related to the subject.
7. Right to Consent to and Object to Commercial Electronic Messages
Persons who consent to the sending of commercial electronic messages to Gürmen may withdraw their consent at any time without stating any reason. Objections may be submitted at Kip stores or through the communication channels set out in the Commercial Message Information and Consent Text [S1] [ÖK2].
Upon receipt of your objection, the sending of commercial electronic messages to you through the channels you have specified will be stopped, except for mandatory notifications within the scope of legal obligations.