The Clarification Text About The Protection of Personal Data

In the following text It is clerified that to which extent your personal data may be processed by Golfbelek.com (hereinafter referred to as The Company). Personal data owners are the persons whose personal data may be collected, processed and transferred in accordance with Personal Data Protection Law No. 6698 (hereinafter referred to as the “PDPL”) and other related legislation.

Golfbelek.com, having the title of the data controller, as explained in this Clarification Text, may save, store, update your personal data, and in cases permitted or required by relevant legislation or by agreement, may transfer, classify, and share them with the third parties (relatives, employees of the service recipient/public and/or private legal entities which the service recipient are insured by, and other public and/or private legal entities,and with the third parties that our companies receive services or cooperate with to carry out their activities subject to the purposes specified in the legislation to which our companies are subject.) and may process them in the ways listed in “PDPL” and relevant legislation.

Golfbelek.com shows maximum sensitivity to the security of personal data. With this awareness, we process the personal data of personal data owners as explained below and within the limits set by the related legislation.

1- Definitions

• Personal Data: Any information relating to an identified or identifiable natural person,
• Personal Data Protection Law of (“PDPL”):

Personal Data the Protection Law of No. 6698, which was published in the Official Gazette on 7 April 2016,

Data Processor: Is the natural or legal person who processes Personal Data on behalf of the data controller, based on the authority given by the data controller,

Data Controller:Is the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system,

2- About the Data Controller

Your personal data may be processed by golfbelek.com within the scope of Personal Data Protection Law of No. 6698. In the scope of the Law The Company is considered as the data controller.

3- Collecting, Processing Personal Data and Purposes of processing them

• Although your personal data may vary depending on the service provided by our Company and the commercial activities of our Company; to fulfill its legal and agreement obligations, fully and properly, your data may be collected through our Company units and departments, website, social media channels, mobile applications and similar means by automatic or non-automatic methods, with all contracts/information forms and other documents regarding the transactions issued with your approval and/or signature, verbally, in writing or electronically.
• upon completion of your membership transactions through the portal regarding the services to be provided by golfbelek.com, your personal data is processed by our platform such as call center, etc. electronically and through printed documents, to fulfill our legal, financial, and commercial obligations, management of our internal audit and compliance processes, execution of accounting processes related to sales, ensuring transaction security, implementation of the company’s global risk management procedures, in connection with and limited to the fulfillment of policies and the execution of company’s reporting activities.

It can be processed by Golfbelek.com in a limited and measured way in connection with the purposes stated in this article, including but not limited to the following:

• Contact Data (name, title, address, e-mail, phone numbers),
• Identity Data (Date of birth, gender, marital status),
• Your voice (Your voice call recordings kept in accordance with customer representatives or call center standards),
• For identification purposes if necessary, a proof-of-identity sample, such as a copy of your current passport, and a recent document showing your residential address, such as a utility bill, and any other document confirming your identity,
• Financial Data (bank account information, financial regulations and contracts, bank statement, other financial data you provide in your voice call recordings kept in accordance with call center standards),
• When necessary, payment and transaction information regarding the payment to be made to a financial company, and information of the finance company,
• Technical Data and Usage Data (username and passwords, IP address and other internet identifiers, account settings, browser type and versions, time zone and location settings, compatible browser add-ons, types and versions, operating systems and platform, access to our website). and other technologies on the devices you use to access information about the use of our website, products and services),
• Within the scope of marketing information; Personal data processed for the marketing of our products and services by customizing them in line with the usage habits, tastes and needs of the person concerned, and the reports and evaluations created as a result of these processing results,
• Within the scope of visual and audio recordings; call center records, visual information processed for various processes and
• Within the scope of location information; address and location information.

Your collected personal data can be processed in accordance with the basic principles stipulated by the PDPL and within the personal data processing conditions and purposes specified in the 5th and 6th articles of the PDPL.

In addition, your personal data may be processed when you use our call center or website to use Company services, when you visit our Company or our website, and when you participate in various organizations that our company participate in.

4- To whom, for what purpose and how the processed personal data can be transferred

To ensure the legal, technical, and commercial security of persons in contact with golfbelek.com, your personal data collected by Golfbelek.com, by Articles 8 and 9 of the PDPL, maybe to transferred to 3rd persons and institutions for supply limited to the purposes specified within the scope of the personal data processing conditions specified in Articles 5 and 6 of PDP Law No. 6698.

These individuals and institutions are golfbelek.com’s; Third parties we consult, including business partners and stakeholders, suppliers, shareholders, company officials, tax and financial advisors and auditors, regulatory and supervisory institutions, Public institutions and organizations authorized to obtain legal information, and Legally authorized private law/public law legal entities Our business partners and other third parties with whom we cooperate to develop or carry out our services for the purposes specified in the law, including official authorities such as official authorities, and within the framework of the personal data transfer conditions and purposes specified in Articles 8 and 9 of the Law, to third parties in the country as well as abroad.

5- Method and Legal Reason for Collecting Your Personal Data

To be able to provide our services in line with the above-mentioned purposes and in this context for golfbelek.com to fulfill its contractual and legal responsibilities completely, your personal data is processed only for the period of time that requires it to be processed under practices of golfbelek.com and its practices of business life, in any case, after the expiry of the time period, they are deleted, destroyed or anonymized.

Your personal data collected through these methods, for the purposes specified in this text, can also be processed and transferred in accordance with the basic principles stipulated by the PDP Law within the scope of the personal data processing conditions and purposes specified in articles 5 and 6 of the PDPL.

In addition to these, having the title of the data controller, when mandatory for golfbelek.com to fulfill its legal obligations, in cases expressly specified in the laws, when mandatory to be processed for the legitimate interests of our company, provided that it does not harm the fundamental rights and freedoms of the data owner if the periods specified under this heading have elapsed if made public by the data owner, but only in this sentence, your data may be used for the realization of the purposes counted as constraints.

For the said reasons, except essential situations, your stored personal data will not be allowed access for any other purpose. when the necessary conditions expired, your personal data is to be duly deleted, destroyed, or anonymized.

Golfbelek.com; processes your personal data based on legal reasons such as legitimate interests, relevant contracts, legal obligations, and your express consent and for the purposes specified below.

• To Enable customers to create accounts and use tools such as valuation and interview, appointment functions on our website,
• To transact with suppliers for goods and services,
• To Liaisin with financial companies and (where applicable) also transferring ownership documents
• To maintain up-to-date records as required by law and internal management policies,
• To Ensure the smooth operation and performance of our website, constantly monitoring the use, security, and reputation of our website, and controlling and improving its functionality for users,
• To determine and enforce our legal rights and obligat ns, to observe in order to identify and record io fraudulent activities that may be carried out over the internet, to prevent and detect criminal behavior,
• To fulfill our legal obligations regarding data security,
• To communicate and contact with you,
• To conduct a customer satisfaction survey.

6- Retention Periods of Personal Data

During and after the end of your relationship with us, as long as necessary in connection with the legal rights and obligations of both parties,we will keep your personal data. This may mean that we will retain some types of personal data for a longer period of time than others, but we will generally retain your personal data for a limited period of time. This time depends on a number of factors, including the following:

• Laws or regulations we must enforce;
• Whether we have any legal or other disputes with you or third parties;
• Any type of information we have about you, and
• Being Requested by you or a regulatory authority that we retain your personal data for a valid reason.

After completion of the time periods required by law for them to be kept, and the completion of the judicial processes or other requirements, automatically or upon the request of the person concerned, personal data are deleted, eliminated, destroyed, or anonymized by our company.

7 – Your Rights as Personal Data Owner

Your legal rights regarding any personal data we hold about you are set out in accordance with Article 11 of the Personal Data Protection Law. Your exercise of these rights will naturally be restricted where we use them in business records and commercial communications where we need to keep limited business-related personal data depending on the situation.

As a data controller, we would like to state that you have the following rights in accordance with Article 11 of the Personal Data Protection Law:

• Learning whether your personal data is processed,
• If your personal data has been processed, requesting information about it,
• Learning the purpose of processing your personal data and whether they are used in accordance with the purpose,
• Knowing the third parties to whom your personal data is transferred, in the country or abroad,
• In case of incomplete or incorrect processing of your personal data, Requesting them to be corrected, notifying third parties that the transaction made within this scope has been transferred to your personal data,
• In case the reasons requiring processing data disappear or if the data are requested to be destroyed, even though your personal data have been processed in accordance with the relevant provisions, you may want them to be deleted, in this context if your duly processed data transferred, you may want the third parties to be notified.
• Objecting to the emergence of a result against you by analyzing your processed data exclusively through automated systems,
• Requesting compensation for the damage in case of damage is due to unlawful processing of your personal data.

In case you have any rights or requests regarding your rights listed above, you can submit your request via the PDPLApplication Form on the website www.golfbelek.com, with the necessary information to identify you, including the explanations about your right that you request to use from the rights, specified in Article 11 of the PDPL. You can use it in the following ways by filling in;

• By hand or through a notary public, You can deliver a signed copy of the form with documents identifying your identity to the address: Çağlayan Mah. Bulent Ecevit Bulv. to 117/6 Muratpaşa/Antalya
• By sending an e-mail to [email protected] or via secure e-signature, portable signature, or previously used e-mail address registered in golfbelek.com or
• To learn what