Clarification Text on the Processing of Personal Data
This Clarification Text has been prepared by WAS İnşaat Sanayi ve Ticaret Anonim Şirketi, acting in its capacity as the Data Controller pursuant to the Law No. 6698 on the Protection of Personal Data ("KVKK"), regarding the use of personal data obtained from Personal Data Subjects and/or third parties in connection with the website www.was.com.tr ("Site"). The purpose of this text is to inform you transparently about the collection methods, processing purposes, legal grounds, transfer principles of your personal data, and your rights as a data subject.
Your Personal Data shared under the KVKK will be collected and processed by our Company as the Data Controller within the scope outlined below.
1. DEFINITIONS AND ABBREVIATIONS
In this Clarification Text:
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Company: Refers to WAS İnşaat Sanayi ve Ticaret Anonim Şirketi, located at Cihangir Mah. Güvercin Cad. Baha İş Merkezi B Blok Kat: 2 Avcılar / Istanbul, Turkey.
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Personal Data: Refers to any information relating to an identified or identifiable natural person.
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Processing of Personal Data: Refers to any operation performed on personal data, such as collection, recording, storage, retention, alteration, reorganization, disclosure, transfer, acquisition, making available, classification, or prevention of use, whether by automated or non-automated means provided that it is part of a data recording system.
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Personal Data Subject: Refers to the natural person whose personal data is processed.
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KVKK: Refers to the Law No. 6698 on the Protection of Personal Data, published in the Official Gazette on April 7, 2016.
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Data Processor: Refers to the natural or legal person processing personal data on behalf of the data controller based on the authority granted by the data controller.
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Data Controller: Refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.
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Website / Site: Refers to www.was.com.tr.
2. PROCESSED PERSONAL DATA
Although the types and quantity of personal data processed may vary depending on the nature of your relationship with the Company, the personal data provided by you or obtained from third parties includes the following:
Personal Data CategoryPersonal Data Collected
Identity DataName, surname, Turkish ID number, date of birth, gender
Contact DataAddress details, phone numbers, email addresses
Financial DataCredit card details, bank account information, card number, expiration date, and CVV code
Cookie DataIn-site navigation behaviors, location, browser and operating system details, session duration, interests, IP address
Marketing DataPurchase history, survey responses, campaign participation details, website usage data
Visual and Audio RecordsCCTV footage from store visits, call center voice recordings, video/audio records from support channels
Transaction Security DataInternet access logs, user session information
3. GENERAL PRINCIPLES, CONDITIONS AND PURPOSES OF PROCESSING PERSONAL DATA
In accordance with Article 4 of the KVKK, your personal data is processed lawfully and fairly, accurately and up-to-date when necessary, for specified, explicit, and legitimate purposes, relevant, limited, and proportionate to the purposes for which it is processed, and retained for the period stipulated by applicable legislation or required for the processing purpose.
Pursuant to Article 5 of the KVKK, personal data cannot be processed without the explicit consent of the Data Subject. However, personal data may be processed without explicit consent under the following conditions:
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Expressly provided for by law,
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Mandatory to protect the life or physical integrity of a person who is physically unable to express consent or whose consent is not legally valid,
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Necessary for the processing of personal data belonging to the parties to a contract, provided that it is directly related to the establishment or performance of that contract,
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Mandatory for the Data Controller to fulfill its legal obligations,
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Made public by the Data Subject themselves,
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Mandatory for the establishment, exercise, or protection of a right,
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Mandatory for the legitimate interests of the Data Controller, provided that it does not harm the fundamental rights and freedoms of the Data Subject.
Purposes of Processing:
Our Company processes your personal data for purposes including fulfilling legal obligations, executing business processes required to deliver our products and services, conducting commercial operations, planning business strategies, ensuring legal and technical security, customizing product/service offerings based on user preferences, managing customer satisfaction and marketing activities, tracking orders and deliveries, and reporting to authorized authorities as required by law.
4. METHODS AND LEGAL GROUNDS FOR PERSONAL DATA COLLECTION
Your personal data is collected through electronic and physical channels such as www.was.com.tr, email, call centers, store visits, security cameras, and mobile applications. Processing operations are carried out based on the legal grounds of contract performance and the legitimate interests of the Data Controller.
5. TRANSFER OF PERSONAL DATA, PURPOSES AND RETENTION PERIODS
Personal Data CategoryRecipientsTransfer PurposesRetention Period
Identity DataCargo companies, banks, shareholders, company executives, affiliates, public authorities, suppliersProvision and delivery of products/services, payment handling, customer data management, dispute resolution10 years following contract termination
Contact DataCargo companies, shareholders, company executives, affiliates, public authorities, suppliersCommunication, delivery management, promotional and campaign notifications10 years following contract termination
Financial DataBanks, internal departments, shareholders, company executivesProcessing, verification, and accounting of financial transactions10 years following contract termination
Marketing DataAnalytics firms, advertising agencies, research firms, infrastructure providersDelivering targeted campaigns and recommendations based on user behavior10 years
Visual and Audio RecordsShareholders, company executives, affiliates, public authorities, infrastructure providersCustomer support delivery, legal dispute resolution5 years
Transaction Security DataShareholders, company executives, affiliates, public authorities, infrastructure providersEnsuring system security, technical support, legal compliance10 years
Cookies and IP AddressAnalytics firms, advertising agencies, research firms, infrastructure providersEnhancing user experience and marketing activitiesSubject to Privacy and Cookie Policy
6. SECURITY OF YOUR PERSONAL DATA
Our Company implements appropriate technical and organizational measures consistent with data protection laws to safeguard your data against unauthorized access, loss, alteration, or disclosure. Personal data is accessible only to authorized personnel and is deleted, destroyed, or anonymized upon expiration of the processing period in accordance with our Data Retention and Destruction Policy.
7. RIGHTS AND OBLIGATIONS OF THE DATA SUBJECT
7.1. Obligations
Data subjects are responsible for ensuring that the personal data shared with the Company is accurate and up to date. If personal data belonging to third parties is provided, the data subject is responsible for obtaining valid consent in accordance with applicable legislation.
7.2. Rights
Under Article 11 of the KVKK, data subjects have the right to:
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Learn whether personal data is processed,
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Request information if personal data has been processed,
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Learn the purpose of processing and whether data is used in accordance with its purpose,
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Know third parties to whom data is transferred domestically or abroad,
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Request correction of incomplete or inaccurate data,
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Request deletion or destruction of data under Article 7 of the KVKK,
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Request notification of correction or deletion operations to third parties to whom data was transferred,
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Object to processing results that arise solely through automated analysis causing an adverse effect,
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Request compensation for damages incurred due to unlawful processing.
Application Procedure
You may submit your written request along with proof of identity to "Cihangir Mah. Güvercin Cad. Baha İş Merkezi B Blok Kat: 2 Avcılar / Istanbul" by hand, post, or notary public. Your request will be processed free of charge as soon as possible and within 30 days at the latest.
COMPANY CONTACT INFORMATION
WAS İnşaat Sanayi ve Ticaret A.Ş.
Address: Cihangir Mah. Güvercin Cad. Baha İş Merkezi B Blok Kat: 2 Avcılar / Istanbul, Turkey
Tel: +90 212 422 87 83
Email: info@was.com.tr