Privacy and Personal Data Protection Policy

Introduction

Dear users, thank you for choosing Esfera (“we” or “Esfera”).

To provide you with the best service, we process and transfer your personal data when you use lp.esfera.com.tr (“Site”) and the Esfera product (“Product”). Your privacy and the security of your personal data are very important to us. Therefore, through this Privacy and Personal Data Protection Policy (“Policy”), we aim to transparently explain how and why we collect, use, store, and share your personal data, and summarize the rights and choices you have regarding sharing your personal data with us.

Please note that we may process and/or transfer your personal data in accordance with the purposes outlined in this Policy, either with your explicit consent or without your consent in cases where exceptions are provided under the Law No. 6698 on the Protection of Personal Data (“KVKK”) (such as explicit provision in laws, establishment or performance of a contract, fulfillment of a legal obligation, etc.).

All rights to the lp.esfera.com.tr website (“Site”) belong to Esfera. Please note that you can browse and obtain information about the Site and Product/Service without sharing any personal data.

Individuals under the age of 18 cannot engage in purchase/sale/service request transactions without the permission and/or approval of their guardian and/or custodian.

Esfera may occasionally develop new services or offer additional services. If the provision of these new or additional services leads to a significant change in how we collect or process personal data, we will provide you with additional information or new terms or policies. Unless stated otherwise, these new or additional services will be subject to this Policy.

By using the Site and the Product, you are deemed to have accepted this Policy.

Data We Collect and Usage Terms

To purchase or request the Product through the Site, you need to share personal data such as your name, email address, and phone number. We process this personal data based on the legal reason of “performance and execution of the contract” under KVKK Article 5, Paragraph 2 (c).

We process your personal data based on the legal reason of “fulfillment of legal obligations” under KVKK Article 5, Paragraph 2 (ç).

Additionally, if you contact us regarding issues related to the Site and Product, or for information and support requests, and share your personal data with us directly, we process your contact information based on the legal reasons of “performance and execution of the contract” under KVKK Article 5, Paragraph 2 (c), “personal data disclosed by the data subject” under KVKK Article 5, Paragraph 2 (d), and “legitimate interests of the data controller” under KVKK Article 5, Paragraph 2 (f). Apart from these, we may use your personal data, including your explicit consent, for promotional and advertising purposes via email, phone, SMS, etc. If you do not wish to receive notifications about product campaigns, you can unsubscribe by clicking the link at the bottom of the email or make an opt-out request through the Commercial Electronic Messaging Management System (“IYS”).

To ensure security on our Site, we use “128-bit SSL certificates” for communications between visitors and the site. We remind you that if an email message is not encrypted, its security cannot be guaranteed, and you are responsible for the security of the emails you send.

We collect your IP data to improve the security of our Site, analyze trends, manage the Site, and analyze your activities on the Site, websites you were directed to, media player usage, access times, and user experiences. This data is processed based on the legal reason of “necessity for legitimate interests of the data controller, provided it does not harm the fundamental rights and freedoms of the data subject” under KVKK Article 5, Paragraph 2 (f).

We would like to note that we protect the personal data we collect in accordance with this Privacy and Personal Data Protection Policy, as well as KVKK, related secondary regulations, and decisions of the Personal Data Protection Board, and we take all necessary administrative and technical measures.

Retention Period

We only retain your personal data for as long as necessary to provide you with access to the Site, fulfill legitimate and fundamental business purposes (e.g., maintaining Site performance, making data-driven business decisions regarding new features and offers, complying with legal obligations, and resolving disputes).

We commit to protecting our users’ personal data. We take appropriate technical and administrative measures to ensure the security of your personal data, but please note that no system is entirely secure.

To protect your privacy and confidential information, please avoid sharing your personal and confidential information with others.

Links

Our Site may provide links to other websites that are not operated by Esfera. If you visit any of these sites, you should review the privacy and other policies of those sites. We are not responsible for the policies and practices of other companies.

Your Rights

Under personal data protection legislation, you have the right to:

(i) Learn whether your personal data is processed,
(ii) Request information about the processing of your personal data,
(iii) Learn the purpose of processing your personal data and whether it is used in accordance with that purpose,
(iv) Learn about third parties to whom your personal data is transferred, whether domestically or internationally,
(v) Request correction of your personal data if it is incomplete or incorrect,
(vi) Request deletion or destruction of your personal data in accordance with the conditions prescribed by the KVKK,
(vii) Request notification to third parties to whom your personal data has been transferred, regarding the correction, deletion, or destruction of your personal data,
(viii) Object to the outcome of the processing of your data exclusively by automated systems, if it results in an adverse effect on you,
(ix) Request compensation for damages caused by unlawful processing of your personal data.

To exercise these rights, you may submit a written application to our Data Controller at Ahi Evran Mahallesi, 1. OSB, Oğuz Caddesi, no:24 Sincan/Ankara, in accordance with the Principles and Procedures of Application to the Data Controller.

Changes to Our Policy

The effective date of this Privacy and Personal Data Protection Policy is stated below. We may update this Policy if there are changes to the services we provide or the technologies we use. If we make significant changes to the Policy, we will publish an updated Privacy and Personal Data Protection Policy on our website and draw your attention to it. Additionally, we will notify you of these changes using your registered contact information (e.g., email, notification, or other equivalent methods). By continuing to use the Site after such notifications, you are deemed to have accepted the changes to the Privacy and Personal Data Protection Policy. Please refer to the “Last Updated” section below to see the most recent update of this Policy.

Thank you for reading our Policy. If you have any questions about this Policy, please contact our Data Protection Officer at Ahi Evran Mahallesi, 1. OSB, Oğuz Caddesi, no:24 Sincan/Ankara. If you believe that someone has violated this Policy and/or other policies, we would appreciate it if you inform us via the above email address.

Effective Date: 1.04.2024

Last Updated: 1.04.2024