CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA
(Pursuant to the Law No. 6698 on the Protection of Personal Data)
This Clarification Text has been prepared by Ularte Sınai Yapı ve Ticaret A.Ş. (“Company”), acting in the capacity of data controller within the scope of the Law No. 6698 on the Protection of Personal Data (“Law” or “KVKK”) and the applicable secondary legislation, for the purpose of informing data subjects regarding the personal data processing activities carried out by the Company in accordance with Article 10 of the Law.
- Information About the Data Controller
Pursuant to the KVKK, your personal data are processed by the data controller whose details are provided below:
Title: Ularte Sınai Yapı ve Ticaret A.Ş.
Address: Büyükdere Cad., No:160, 1. Levent, 34330 Istanbul / Türkiye
Phone: +90 212 281 99 05
Fax: +90 212 281 99 06
E-mail: kvkk@ularte.com
Website: www.galpan.com
- Your Personal Data Processed
The following personal data may be processed by our Company:
• Identity data (name-surname)
• Contact data (e-mail address, phone number, IP address)
• Transaction security data (cookie records, session information, log data)
• Request/complaint management data (content submitted through contact form)
These are processed by automated or partially automated means.
- Purposes of Processing Personal Data
The collected personal data are processed in accordance with the principles set forth in Article 4 of the Law, namely: lawfulness and fairness; being accurate and up-to-date; being processed for specific, explicit, and legitimate purposes; and being relevant, limited and proportionate to the purposes for which they are processed.
Your data are processed for the following purposes:
• Evaluating visitor requests and providing feedback,
• Ensuring the security and continuity of the website,
• Maintaining electronic records and fulfilling legal obligations,
• Serving as evidence in potential future disputes,
• Providing information to authorized persons, institutions, and organizations.
- Legal Grounds for Processing Personal Data
Your personal data are processed on the basis of the data processing conditions set out in Article 5 of the Law:
• Art. 5/2-a: Processing is explicitly provided for by law,
• Art. 5/2-c: Processing is necessary for the establishment or performance of a contract,
• Art. 5/2-ç: Processing is necessary for the data controller to fulfill its legal obligations,
• Art. 5/2-e: Processing is necessary for the establishment, exercise or protection of a right,
• Art. 5/2-f: Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.
In cases where explicit consent is required, no processing shall take place without obtaining your prior consent.
- Methods of Collecting Personal Data
Your personal data are collected through the following methods:
- Contact forms submitted directly via the website,
• Digital usage data collected through cookies,
• Applications made via electronic mail.
The data are collected electronically through automated or partially automated methods.
- Transfer of Personal Data
Your personal data may be transferred, limited to the purposes stated above and in the cases clearly stipulated in Article 8 of the KVKK, to:
- Authorized public institutions and organizations (BTK, courts, law enforcement authorities, etc.),
• Domestic service providers providing necessary technical and infrastructure services,
• Third parties providing legal consultancy and audit services.
No personal data is transferred abroad, and such transfer will not be made without your explicit consent, except where permitted by law.
- Retention Period of Personal Data
Your personal data are retained for the period required for the purpose of processing and, upon expiry of such period, are deleted, destroyed, or anonymized in accordance with Article 7 of the KVKK and the Regulation on the Deletion, Destruction or Anonymization of Personal Data.
• Contact form data: Maximum 3 years
• Traffic and log data: Minimum 2 years (as required by Law No. 5651)
• Cookie data: 6 months to 2 years, depending on the purpose of use
- Rights of the Data Subject
Pursuant to Article 11 of the KVKK, as the data subject, you may apply to our Company and exercise the following rights:
• To learn whether your personal data are processed,
• To request information regarding such processing,
• To learn the purpose of the processing and whether the data are used in accordance with this purpose,
• To know the third parties to whom your data are transferred domestically or abroad,
• To request the rectification of incomplete or inaccurate data,
• To request the deletion or destruction of personal data under Article 7 of the Law,
• To request notification to third parties of rectification or deletion of personal data,
• To object to any result against you arising from the analysis of processed data exclusively through automated systems,
• To request compensation if you suffer damage due to the unlawful processing of personal data.
- Method of Application and Evaluation Process
You may submit your requests regarding the rights listed above in accordance with Article 13 of the Law and the “Communiqué on the Procedures and Principles of Application to the Data Controller”, via the following methods:
• In writing to: Büyükdere Cad., No:160, 1. Levent, 34330 Istanbul / Türkiye,
• By e-mail to: kvkk@ularte.com
Applications are evaluated and finalized within 30 (thirty) days at the latest. The response will be sent to the applicant via the method corresponding to the method used in the application.
This Clarification Text has been issued by our Company to fulfill the obligation to inform data subjects regarding personal data processing activities pursuant to Article 10 of the Law No. 6698.