KVKK Information Text

ABOUT THE PROCESSING OF PERSONAL DATA

INFORMATION TEXT

VLM 4 YAPI SYSTEMS INVESTMENT INC., which owns the HOMERA brand and the www.homeramodular.com domain site, takes the highest possible level of security measures to ensure that your personal data is collected, stored and shared in accordance with the law and to protect your privacy.

Our aim is to inform you in the most transparent way about the ways your personal data is collected, the purposes of processing, the people it is shared with, legal reasons and your rights, in accordance with Article 10 of the Personal Data Protection Law No. 6698 and in line with your satisfaction.

1. a) Data Controller

In accordance with the Personal Data Protection Law No. 6698 (“Law No. 6698”), your personal data is collected and processed by VLM 4 YAPI SİSTEMLERİ YATIRIM A.Ş. (“COMPANY”) as the data controller, within the scope explained below.

Title: VLM 4 BUILDING SYSTEMS INVESTMENT INC.

CRS Number: 0925-0718-1480-0001

Address : Huzur Mah. Ayazaga St. 4B/601 Maslak -Sariyer / Istanbul

Phone: +90 212 212 06 74

Email address: [email protected]

Registered Electronic Mail (KEP): [email protected]

1. b) Which Personal Data of Yours and the Purposes of Processing

1. Your Personal Data Processed

• Our Visitors

If you are a visitor/guest; (a) your personal data such as your identification number, name and surname information, camera recordings outside the privacy areas, and information about your entry and exit to the Company building; (b) if you have used the internet access service during your stay in our buildings and facilities (COMPANY headquarters and branches, HOMERA showrooms, head office), your telephone number data, internet traffic information regarding your internet access and your IP information;

• Our Online Visitors and Wifi Users

Transaction security information of our online visitors who use our website (IP address
your information), marketing information (shopping history information, cookie records) and (you can provide us with these
if you notify us) identity information, contact information (your e-mail address, full address,
your phone number);

If you are a Wi-Fi service user, your (a) telephone number data and (b) internet traffic information and IP information regarding your internet access;

• Our Customers

Authorities of our real person customers or legal entity customers and/or
employee identification information, contact information, customer transaction information (such as order information),
financial information (such as bank information), risk management, professional information, invoice, legal transaction information, user traffic information, location, marketing information (such as shopping history information);

• Our Potential Customers

Authorities of our real person customers or legal entity customers and/or
Employee identification information, contact information, professional information, customer transaction information, marketing information;

• Our Business Partners / Solution Partners

Authorities of our real person solution partners or legal entity solution partners and/or
employee identification information, contact information, dealer transaction information (order information, etc.), finance
information (balance sheet information etc.), legal transaction information, risk information, marketing information (purchase history
information);

• Our Supplier Representative

Identity information, contact information, customer transaction information, financial information, marketing information, legal transaction information, risk information, location of our natural person suppliers or legal person supplier authorities;

• Supplier Employee

Identity information, contact information, professional experience information, location (e.g. in-service training information) of the supplier employee;

• Our Working Candidates

If you are a candidate for employment; (a) the information in your identity card, photograph, Your personal data such as residence, military service information, driver's license, education documents and information, professional experience, e-mail address, career goals, information regarding previous employment, references, telephone number; (b) if you have used the internet access service during your stay in our buildings and facilities (COMPANY headquarters and branches, HOMERA showrooms, head office), telephone number data and internet traffic information and IP information regarding your internet access; (c) Your entry and exit information to the Company building, camera recordings outside privacy areas;

• Our employees

If you are an employee; (a) the information in your identity card, photograph, Your personal data such as residence, marital status, military service information, driver's license, education documents and information, e-mail address, telephone number, legal proceedings, professional experience, financial experience, finance (bank information, etc.), location, risk management, vehicle/license plate; your special personal data regarding health, criminal convictions and security measures in the presence of your explicit consent, except for the cases listed in the law; (b) if you have used the internet access service during your stay in our buildings and facilities (COMPANY headquarters and branches, HOMERA showrooms, head office), your telephone number data and internet traffic information and IP information regarding your internet access; (c) your entry and exit information to the company building, camera recording images outside the privacy areas

is being processed.

In processes related to our corporate customers, we also process signature circulars and title-position information.

1. Purposes of Processing Personal Data

Your personal data collected;

• Creating and monitoring visitor records,
• Ensuring the legal, technical and commercial-occupational security of the relevant persons who have a business relationship with the Company, and ensuring the physical security and control of the Company's locations;
• Providing you with access to our website via the internet, and also fulfilling the mandatory provisions of the Law No. 5651 on the Regulation of Publications Made on the Internet and Combating Crimes Committed through Such Publications (“Law No. 5651”) and the legislation regulated under this law, as well as other laws,
• Carrying out activities in accordance with legislation, information security processes
  execution, follow-up of requests/complaints,
• To provide COMPANY products and services, to fulfill our obligations to you, to provide after-sales support services for goods/services, to carry out goods/service sales processes, to organize records and documents, to comply with information storage, reporting, information, tax and other obligations stipulated by local and international legal legislation,
• Monitoring and resolving customer complaints,
• Establishing communication to provide you with the necessary information regarding information processing requirements, system structure, the necessity of the information processing support services received, and these services and products,
• Conducting traffic measurement, statistical analysis, segmentation/profiling and CRM studies for sales and marketing activities,
• Taking your orders, carrying out your payment transactions, providing logistics cooperation with third parties and ensuring product shipment,
• Managing our customer portfolio,
• To be used in products and services to be offered within the scope of relevant legislation,
• Carrying out contract processes, fulfilling the requirements of the contracts and fulfilling the legal obligations that the COMPANY is subject to regarding the use of these services,
• In line with the purpose of determining and implementing the commercial and business strategies of the COMPANY; managing the financial operations, communication, market research and social responsibility activities, purchasing operations (demand, offer, evaluation, order, budgeting, contract), in-house system and application management operations, legal operations carried out by the COMPANY,
• Carrying out finance and accounting work, carrying out/auditing business activities,
• Carrying out investment processes,
• Monitoring and execution of legal affairs,
• Execution of supply chain management processes,
• Carrying out risk management processes and strategic planning activities,
• Evaluating job application requests and suitability for the relevant position, conducting and finalizing recruitment processes within the framework of the COMPANY's human resources policies, and taking necessary actions if the person is accepted for the relevant position;
• Preparation of personnel files, ensuring that payroll transactions are carried out, making salary payments to employees, making official notifications, making payments regarding salary garnishment deductions, carrying out occupational health/safety activities, fulfilling court decisions, distinguishing between right and wrong in customer complaints, increasing customer satisfaction, understanding customer needs and ensuring that customer-related processes are improved, monitoring and reporting sales performances, confirming that the employee who is allocated or provided with a vehicle is qualified to drive and has not lost his/her license for any reason, creating the employee's business e-mail by entering employee data into Outlook, conducting research projects regarding employees, ensuring communication for congratulatory purposes, planning training, reporting trainings, preparing training certificates, being able to follow up on employees who have participated in trainings, being able to follow up on the development processes of employees as a result of the trainings they have received, communicating with the relevant persons in case of emergency.
• Examining, evaluating and responding to requests from official authorities or you.

are processed in a way that is relevant, limited and proportionate to their intended purposes.

In case of your explicit consent,

• Your identity and contact information for the purpose of sending informational communications and commercial electronic messages regarding promotions, bulletins, collection promotions, events, advantages, discounts, campaigns within the scope of sales and marketing activities to be carried out to increase the quality of services and products in accordance with the Regulation on Commercial Communications and Commercial Electronic Messages,

• Your identity, communication, customer transaction, transaction security, marketing data in order to contact you and carry out the marketing processes of our Company's products and services, to recommend and introduce the products and services offered by our Company, including profiling and analysis activities, by customizing them according to your tastes, usage habits and needs, to measure and increase customer satisfaction, and to receive your opinions and suggestions regarding new services and products.

• Your identity, contact, customer transaction and marketing data may be processed for the purpose of conducting research, surveys and reviews regarding customer satisfaction and sending promotions and gifts.

You will be asked for your explicit consent separately from this information text, and even if you consent, you always have the right to withdraw this consent. Even if you do not give explicit consent, you can continue to benefit from all our sales and after-sales services that do not have a legal basis for explicit consent.

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Your personal data is processed in accordance with the general principles set out in Article 4 of the Law, in accordance with the law and the rules of honesty, accurately and, when necessary, up-to-date, for specific, clear and legitimate purposes, in connection with the purpose for which they are processed, limited and proportionate, and kept for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed.

1. c) To Whom and For What Purposes Can Processed Personal Data Be Transferred?

Your personal data collected is limited to and valid for all of the processing purposes specified in section b) above;

Within the framework of the provisions of transferring personal data specified in Article 8 of the KVKK numbered 6698; to the business partners, shareholders, affiliates of the COMPANY located in the country; in cases where obligations arising from the law are fulfilled and in the event of a legal dispute, to legally authorized public institutions and organizations and judicial and administrative authorities; to real or legal persons, manufacturers, suppliers, business/solution partners from whom we receive services and cooperate in the execution of business activities, product/service comparison, analysis, evaluation, advertising and the realization of our above-mentioned purposes; to program partner institutions and organizations, to institutions and service providers with whom we have agreements regarding sending the messages we send to our customers; to the cargo companies that deliver the orders placed or our gifts, promotions, catalogs to you.

Within the framework of the provisions on transfer of personal data specified in Article 9 of the KVKK numbered 6698, in order to ensure legal and commercial security, it may be transferred to service providers whose servers are located abroad, to the COMPANY's business partners, shareholders, affiliates located abroad; to real persons or legal entities located abroad from whom we receive services and cooperate in order to carry out business activities, product/service comparison, analysis, evaluation, advertising and to realize our above-mentioned purposes, manufacturers, suppliers, business/solution partners; to program partner institutions and organizations located abroad, and to institutions with which we have agreements regarding sending the messages we send to our customers.

d) Method and Legal Reason for Collecting Personal Data

Your Personal Data is collected both fully or partially by automatic means and by non-automatic means that are part of the data recording system;

As a result of applications made directly by you or by persons authorized to act on your behalf, through the website or contracted websites or physically, shared business cards, visits, communication and information access channels such as our customer service call center line, e-mail addresses, social media channels and WhatsApp support service line, as well as membership agreements, sales agreements and other agreements, campaigns, applications, meetings and forms established through communication with our Dealers, written and electronic media, information forms you have filled out at fairs and your requests for information verbally, in writing or electronically;

As stated in Articles 5 and 6 of the Law;

• It is clearly stated in the laws,
• It is mandatory for our company to fulfill its legal obligations,
• The processing is directly related to the establishment or performance of the contract and is necessary,
• Processing is mandatory for the legitimate interests of our Company, provided that it does not harm your fundamental rights and freedoms,
• It has been made public by you,
• Processing is necessary for the establishment, exercise or protection of a right,
• Your explicit consent

It collects data based on legal reasons such as:

11. d) Rights of the Personal Data Owner Listed in Article 11 of Law No. 6698

As personal data owners, if you submit your requests regarding your rights through the methods set out below, the COMPANY will finalize the request as soon as possible and within thirty days at the latest, depending on the nature of the request. No fee will be charged for the response up to ten pages. A processing fee of 1 Turkish Lira will be charged for each page over ten pages. If the response to the application is given on a recording medium such as a CD or flash memory, the fee that may be requested by our company will not exceed the cost of the recording medium.

In this context, personal data owners;

• Learning whether personal data is being processed,
• To request information regarding the processing of personal data,
• To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
• To know the third parties to whom personal data is transferred, either domestically or abroad,
• To request correction of personal data if it is processed incompletely or incorrectly and to request notification of the action taken to third parties to whom personal data is transferred,
• To request the deletion or destruction of personal data in case the reasons requiring processing are eliminated, even though it has been processed in accordance with the provisions of Law No. 6698 and other relevant laws, and to request that the action taken within this scope be notified to third parties to whom personal data has been transferred,
• To object to a result that is to the detriment of the person himself/herself, as a result of the analysis of the processed data exclusively through automatic systems,
• In case of damage caused by unlawful processing of personal data, the person has the right to demand compensation for the damage.

You may submit your request regarding the exercise of your rights specified above in accordance with the first paragraph of Article 13 of Law No. 6698 and the Communiqué on the Procedures and Principles of Application to the Data Controller No. 30356 and dated 10.03.2018, in Turkish and in writing or by using the registered electronic mail (KEP) address, secure electronic signature, mobile signature or the electronic mail address previously notified to the COMPANY and registered in our system. In applications, only information about the applicant will be provided and it will not be possible to obtain information about other family members and third parties. The COMPANY reserves the right to verify your identity before responding.

In your application;

1. a) Your name, surname and signature if the application is in writing,
2. b) For citizens of the Republic of Türkiye, your Turkish identity number, if you are a foreigner, your nationality, passport number or ID number if you have one,
3. c) Your residence or workplace address for notification,

d) Your notification e-mail address, telephone and fax number, if any,

1. d) The subject of your request,

It is mandatory to have it and if there is any information and documents related to the subject, they must be attached to the application.

You can submit your applications that you want to make in writing, by attaching the necessary documents, to our Company’s address as the data controller, “Huzur Mah. Ayazağa Cad. 4B/601 Maslak -Sarıyer / İstanbul”. You can download the application form from the “Data Owner Application Form” link at the bottom of this page.

You can find our e-mail addresses to which you can send your applications via e-mail in the "Data Subject Application E-mail Addresses" section at the bottom of this page.

Depending on the nature of your request, the information and documents that will allow identification must be provided to us completely and accurately. If the requested information and documents are not provided as required, the COMPANY may experience problems in conducting the research to be conducted based on your request in a complete and qualified manner. In this case, the COMPANY declares that it reserves its legal rights. Therefore, your application must be sent completely and including the requested information and documents according to the nature of your request.

Data Owner Communication Methods:

Written Application:

You can send it to the address “Huzur Mah. Ayazağa Cad. 4B/601 Maslak -Sarıyer / İstanbul”.

Email Application:

[email protected] e-mail or [email protected] KEP address e-mail.