This data protection declaration clarifies the type, scope and purpose of the processing of personal data (hereinafter referred to as „data“) within our online offer and the websites, functions and contents connected with it as well as external online presences, such as our Social Media Profile. (hereinafter jointly referred to as the „online offer“). With regard to the terms used, such as „processing“ or „responsible person“, we refer to the definitions in Art. 4 of the Basic Data Protection Regulation (DSGVO).
Aydinli A.Y.O.S.B Mah. 4 SOK. No:9
34953 Tuzla / Istanbul
the types of data processed:
– Stock data (for example, names, addresses).
– Contact data (e.g., e-mail, telephone numbers).
– Content data (e.g., text entries, photographs, videos).
– Usage data (e.g., websites visited, interest in content, access times).
– Meta/communication data (e.g., device information, IP addresses).
Categories of data subjects
Visitors and users of the online offer (in the following we will refer to the persons concerned collectively as „users“).
Purpose of processing
– Provision of the online offer, its functions and contents.
– Answering of contact requests and communication with users.
– security measures.
– Reach measuring/marketing
„Personal data“ shall mean any information relating to an identified or identifiable natural person (hereinafter referred to as „data subject“); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an on-line identifier (e.g. a cookie), or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
„Processing“ means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually all processing of data.
controller“ shall mean the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the processing of personal data
Relevant legal basis
In accordance with Art. 13 DSGVO, we inform you of the legal basis of our data processing. If the legal basis is not stated in the data protection declaration, the following applies: The legal basis for obtaining consents is Art. 6 Para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the purpose of fulfilling our services and implementing contractual measures and answering enquiries is Art. 6 Para. 1 lit. b DSGVO, the legal basis for processing for the purpose of fulfilling our legal obligations is Art. 6 Para. 1 lit. c DSGVO, and the legal basis for processing for the purpose of safeguarding our legitimate interests is Art. 6 Para. 1 lit. f DSGVO. In the event that vital interests of the data subject or another natural person require the processing of personal data, Article 6 paragraph 1 lit. d DSGVO serves as the legal basis.
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies (processors or third parties), transfer it to them or otherwise grant them access to the data, this will only be done on the basis of a legal authorisation (e.g. if the data must be transferred to third parties, such as payment service providers, in accordance with Art. 6 Para. 1 letter b DSGVO for the fulfilment of the contract), if you have given your consent, if a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosters, etc.).
If we commission third parties to process data on the basis of a so-called „contract processing agreement“, this is done on the basis of Art. 28 DSGVO.
Transfers to third countries
If we process data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this is done in the context of using the services of third parties or disclosure or transfer of data to third parties, this will only take place if it is done to fulfil our (pre-)contractual obligations, on the basis of your consent, on the basis of a legal obligation or on the basis of our legitimate interests. Subject to legal or contractual permissions, we will only process or transfer data to a third country if the special requirements of Art. 44 ff. DSGVO. In other words, processing is carried out, for example, on the basis of special guarantees, such as the officially recognised determination of a level of data protection corresponding to that of the EU (e.g. for the USA through the „Privacy Shield“) or compliance with officially recognised special contractual obligations (so-called „standard contractual clauses“).
Rights of data subjects
You have the right to request confirmation as to whether or not data in question is being processed and to obtain information about this data and to receive further information and a copy of the data in accordance with Art. 15 DSGVO.
You have accordingly. Art. 16 DPA, you have the right to request the completion of data concerning you or the correction of incorrect data concerning you.
Under Art. 17 DSGVO, you have the right to demand that data concerning you be deleted immediately, or alternatively, under Art. 18 DSGVO, to demand that the processing of the data be restricted.
You have the right to request that the data concerning you which you have made available to us be received in accordance with Art. 20 DSGVO and to demand that it be passed on to other responsible parties.
You also have the right to lodge a complaint with the competent supervisory authority in accordance with Art. 77 DSGVO.
Right of withdrawal
You have the right to revoke consents granted in accordance with Art. 7 Para. 3 DSGVO with effect for the future
Right of objection
You can object to the future processing of data concerning you at any time in accordance with Art. 21 DSGVO. In particular, you may object to processing for the purposes of direct advertising.
Cookies and right of objection for direct advertising
Cookies“ are small files that are stored on the user’s computer. Different information can be stored within the cookies. A cookie is primarily used to store information about a user (or the device on which the cookie is stored) during or after his visit to an online offer. Temporary cookies, or „session cookies“ or „transient cookies“, are cookies that are deleted after a user leaves an online offer and closes his browser. In such a cookie, for example, the contents of a shopping cart in an online shop or a login jam can be stored. Cookies are described as „permanent“ or „persistent“ if they remain stored even after the browser is closed. For example, the login status can be saved if the user visits it after several days. Likewise, the interests of the users can be stored in such a cookie, which are used for range measurement or marketing purposes. As a „third party cookie“, cookies will be offered by providers other than the person responsible for operating the online service (otherwise, if it is only his cookies, it is called a „first-party cookie“).
If users do not want cookies to be stored on their computer, they are asked to deactivate the corresponding option in the system settings of their browser. Stored cookies can be deleted in the system settings of the browser. The exclusion of cookies can lead to functional limitations of this online offer.
Deletion of data
The data processed by us will be deleted or restricted in their processing in accordance with articles 17 and 18 DSGVO. Unless expressly stated within the scope of this data protection declaration, the data stored by us will be deleted as soon as they are no longer required for their intended purpose and the deletion does not conflict with any statutory storage obligations. If the data are not deleted because they are required for other and legally permissible purposes, their processing will be restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons.
According to legal requirements in Germany, data is stored in particular for 6 years in accordance with § 257 Paragraph 1 HGB (commercial books, inventories, opening balance sheets, annual financial statements, commercial letters, accounting vouchers, etc.) and for 10 years in accordance with § 147 Paragraph 1 AO (books, records, management reports, accounting vouchers, commercial and business letters, documents relevant for taxation, etc.).
Additionally we process
– Contract data (e.g., subject matter of the contract, duration, customer category).
– Payment data (e.g., bank details, payment history)
from our customers, interested parties and business partners for the purpose of providing contractual services, service and customer care, marketing, advertising and market research.
Collection of access data and log files
We, or our hosting provider, on the basis of our legitimate interests as defined in Art. 6 para. 1 lit. f. DSGVO data about every access to the server on which this service is located (so-called server log files). The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user’s operating system, referrer URL (the previously visited site), IP address and the requesting provider.
For security reasons (e.g. to clarify misuse or fraud), log file information is stored for a maximum of 7 days and then deleted. Data whose further storage is required for evidential purposes is excluded from deletion until final clarification of the respective incident.
Provision of contractual services
We process inventory data (e.g., names and addresses as well as contact data of users), contract data (e.g., services used, names of contact persons, payment information) for the purpose of fulfilling our contractual obligations and services in accordance with Art. 6 para. 1 lit b. DSGVO. The entries marked as obligatory in online forms are required for the conclusion of the contract.
In the context of the use of our online services, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c DSGVO.
We process usage data (e.g., the websites visited by our online offer, interest in our products) and content data (e.g., entries in the contact form or user profile) for advertising purposes in a user profile in order to show the user, for example, product information based on the services they have used so far.
The deletion of the data is carried out after the expiry of legal warranty and comparable obligations, the necessity for the storage of the data is reviewed every three years; in the case of legal archiving obligations, the deletion is carried out after their expiry. Details in any customer account shall remain until the deletion of the same.
Users can optionally create a user account. During the registration process, the required mandatory data will be provided to the users. The data entered during registration is used for the purpose of using the offer. Users can be informed by e-mail about information relevant to the offer or registration, such as changes in the scope of the offer or technical circumstances. If users have terminated their user account, their data will be deleted with regard to the user account, subject to their retention is necessary for reasons of commercial or tax law in accordance with Art. 6 Para. 1 lit. c DSGVO. It is the users‘ responsibility to back up their data before the end of the contract if they have terminated it. We are entitled to irretrievably delete all user data stored during the term of the contract.
Within the scope of the use of our registration and login functions as well as the use of the user accounts, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user’s protection against misuse and other unauthorized use. This data will not be passed on to third parties unless it is necessary to pursue our claims or there is a legal obligation to do so in accordance with Art. 6 Para. 1 lit. c DSGVO. The IP addresses are anonymised or deleted after 7 days at the latest.
When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s details are processed for the purpose of handling the contact request and its processing in accordance with Art. 6 Para. 1 lit. b) DSGVO. The user’s details may be stored in a customer relationship management system („CRM system“) or comparable enquiry organisation.
We delete the enquiries if they are no longer required. We review the necessity every two years; furthermore, the statutory archiving obligations apply.
Google is certified under the Privacy Shield Agreement and thus offers a guarantee to comply with European data protection law (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
Google will use this information on our behalf in order to evaluate the use of our website by the users, to compile reports on the activities within this website and to provide us with further services related to the use of this website and the internet. The processed data can be used to create pseudonymous user profiles of the users.
We only use Google Analytics with activated IP anonymisation. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the USA and shortened there.
The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent the storage of cookies by adjusting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plug-in available under the following link: http://tools.google.com/dlpage/gaoptout?hl=de.
You can find further information on data use by Google, setting and objection options on the websites of Google: https://www.google.com/intl/de/policies/privacy/partners („Data use by Google when you use websites or apps of our partners“), http://www.google.com/policies/technologies/ads („Data use for advertising purposes“), http://www.google.de/settings/ads („Manage information that Google uses to show you advertising“).