PDPL

Clarification Text Regarding the Processing of Personal Data


Protection of personal data SM ISITMA SOĞUTMA ITH IHR TİC LTD ŞTİ is among the most important priorities. With full awareness of our responsibility in this regard, our Company, acting in the capacity of data controller, processes and protects personal data in accordance with the Personal Data Protection Law No. 6698 (“Law”) and other relevant legislation.

With this Clarification Text on the Processing of Personal Data, it is aimed to provide the necessary transparency by informing you about the personal data processed in accordance with the Law in line with your use of our products and services we offer to our customers. Detailed information on the processing of your personal data can be found in the Policy on Processing and Protection of Personal Data (“Policy”) at www.roseair.com.tr/kvk-islenmesi-politikasi.pdf.

A. PROCESSING OF YOUR PERSONAL DATA

Your personal data may be processed by our Company for the following purposes within the framework of personal data processing conditions in accordance with the basic principles specified in the Law:

1) Processing of your personal data when you shop for our products and services through our e-commerce site, stores or dealers by our company

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LEGAL REASON; Pursuant to Article 5 of the Law, personal data may be processed provided that the fundamental rights and freedoms of the persons concerned are not harmed in the presence of the legitimate interest of the data controller. In this direction, personal data are processed in line with the legitimate interest of our Company due to the importance of ensuring customer satisfaction, ensuring continuity, preventing customer loss and gaining new customers.

4) SM SITMA SOĞUTMA ITH IHR TİC LTD ŞTİ processing of your personal data within the scope of fulfilling our legal obligations and carrying out commercial activities;



Your Identity Information (name, surname information)

– Contact Information (e-mail, telephone number, address information)

– Customer Transaction Information (purchased product information, order completion information, return/change information, previous orders information, installation information, warranty information, authorised service information, dealer information, customer requests and complaints information)

Fulfilment of our obligations arising from the legislation.

– Providing information to official institutions or organisations, submitting the requested information and documents

– Execution of accounting and finance processes


LEGAL GROUNDS The requirement of being expressly stipulated in the laws specified in Article 5 of the Law (e.g., the Tax Procedure Law determines which data must be included in the invoice),

The legal obligation set out in Article 5 of the Law (e.g. data controllers have an obligation to ensure data security pursuant to the Law),

Data processing is mandatory for the establishment, exercise or protection of a right specified in Article 5 of the Law (e.g. if it is subject to any legal dispute, it has the quality of evidence),

Pursuant to Article 5 of the Law, personal data may be processed in the presence of the legitimate interest of the data controller, provided that the fundamental rights and freedoms of the data subjects are not harmed. Accordingly, the processing of personal data within the scope of our Company’s commercial activities is evaluated within the relevant scope.

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