Privacy Policy

PRIVACY POLICY

NOMINATION SRL, via F.lli Bandiera 22, 50019 Sesto Fiorentino, VAT identification number 05018590488, e-mail: customerservice@nomination.com , in the capacity of Data Controller (hereinafter referred to as "Data Controller") in the Data Processing of its customers regarding the protection of personal data. attaches utmost importance to its rights and legal obligations.

In accordance with the general provisions of the Law on the Protection of Personal Data No. 6698 (hereinafter referred to as "KVKK") and the protection of natural persons regarding the processing of personal data and the free movement of such data, this Privacy Statement ("Declaration"), https://nominationturkey.com (hereinafter). hereinafter referred to as the "Site" or "Website") and using other tools (e.g. social media, cookies, etc.) and our methods of processing the personal data of our customers in accordance with the above-mentioned regulation and the transparency principle of KVKK. We invite you to read this statement carefully.

1. TYPES OF PERSONAL DATA COLLECTED ABOUT THE CUSTOMER

Personal data collected by this Website independently or through third parties for the purposes described in this Policy includes:

Subscription to the newsletter, creating an account on the Site and filling out various forms, as well as contact information provided by the customer (for example, name, surname, date of birth, nationality, e-mail address, postal address, telephone number and other personal data);

Information on any electronic business transaction that takes place, including in connection with the submission of purchase forms as well as pre-sales and post-sales assistance;

Personal data that may be included in communications sent by the Customer, for example to report a problem or to express a request, uncertainty or comment regarding the Site and/or its content;

Information from surveys we may conduct on the Site from time to time for research purposes, if the customer decides to respond or participate;

Personal data and usage data collected by third parties, for example data that the Customer wishes to share with us on public social networks (Facebook, Instagram, etc.) and/or that we may collect from other publicly available databases. Registration and access via a social profile requires express consent, which must be given before logging in, which will allow the execution of transactions with the user's account. For more information, please refer to the privacy policy on the relevant social media website;

Personal data regarding navigation are processed to ensure the correct functioning of the Website or for marketing purposes. We recommend that you read our " Cookie Policy " (viewable on this page) for more information.

It is not mandatory to provide such data. Personal Data may be freely provided by the Customer or, in the case of Usage Data, automatically collected during use of this Website. The transmission of personal data (in particular, personal information, e-mail address, postal address and telephone number) is necessary to provide the services offered by the Site at the request of the Customer, to conclude transactions or, if necessary, to fulfill obligations stipulated by applicable laws or regulations. Refusing to provide personal data necessary to meet the purposes described above may prevent us from complying with legal provisions and other applicable standards. As a result, failure to provide personal data may, in some cases, legitimately and rightfully prevent us from providing the services offered on the Site.

The provision of other personal data beyond what is necessary in order to comply with legal or contractual obligations and to properly consult our services with necessary data regarding site navigation, on the contrary, is optional and will not have any impact on your use of the Site and its services. We will always inform you whether the provision of personal data is mandatory or optional, and we will indicate the data mandatory for the provision of the services requested on the Site with an appropriate symbol (*). Customers who have doubts about which Data is mandatory are advised to contact the Data Controller. The end use of Cookies - or other tracking tools - by this Website is for the purpose of providing the Service requested by the Customer, and also for other purposes described in this document and in the Cookie Policy, where not expressly stated.

The Client assumes responsibility for any third-party Personal Data obtained, published or shared through this Website and warrants that they have the right to transmit or disseminate such data, freeing the Data Controller from any responsibility for third parties.

2. LEGAL BASIS OF PROCESSING

Processing is necessary to execute a contract and/or take pre-contractual measures;

Processing takes place based on the prior and express consent of the Customer, for example to carry out marketing activities;

Processing is necessary to comply with a legal obligation to which the Data Controller is subject;

The processing is necessary to perform a task carried out in the public interest or to exercise public powers in which the Data Controller has invested;

Processing is necessary for the protection of the legitimate interests of the Data Controller or third parties;

It should be noted that NOMINATION SRL Company may, based on its main legitimate interest, contact you to suggest services and products similar to those you have already acquired. It should be noted that under current legislation, this type of communication (called "soft spam") does not require consent. The Client may, in any case and at any time, request that such processing of his data be suspended, and the Data Controller must put this into effect without delay.

In addition, it is always possible to request the Data Controller to explain the concrete legal basis for each processing activity and in particular to indicate whether there is a basis for the processing activity.

3. OBJECTIVES OF DATA PROCESSING

Personal data provided by you are processed without your explicit consent for the following service purposes in accordance with KVKK:

• a) Management and execution of pre-contractual and contractual obligations, including the correct execution of purchases on the "Site";
• b) adding data to the company's database to monitor contract execution, including for billing purposes;
• c) All relevant activities and results, including the stipulation and execution of the contract and the correction and modification of exemplary products and services;
• d) the management of financial and accounting compliance and all related activities, including, for example, invoicing, documentation, tax-free refunds, credit protection, administrative services, administrative services and executive functional services;
• e) Compliance with legal obligations stipulated by law, regulation and Community legislation
• f) Exercise of the Data Controller's rights, including those enforceable in a court of law.

Subject to special permission, for the following additional purposes:

• g) To improve the range of products and services offered and to receive communications, newsletters, informative and/or promotional materials, to assess the level of customer satisfaction or to evaluate events and initiatives, market research or other commercial research and direct selling, products, sales, promotional campaigns, events and activities; using conventional and/or automated means that do not require operator intervention to receive information and updates on other initiatives via automated (e-mail, SMS, newsletter, MMS and/or instant messaging) and conventional (phone calls and/or mail with operators) communication means direct marketing by the Data Controller;
• h) Communication, newsletters by third parties, in the capacity of Commercial Partners operating in the relevant product sector, via automated (e-mail, SMS, newsletter, MMS and/or instant messaging) and traditional (telephone calls and/or mail) communication tools traditional and/or automated processes that do not require operator intervention to receive informative and/or promotional materials, to evaluate the level of customer satisfaction or to comment on events and initiatives, market research or other commercial research and direct sales, statistics, interaction with social networks and external platforms, content direct marketing through means;
• i) Identifying preferences, behaviors and interests in relation to products and services used in order to improve the range of products and services offered, in part through electronic processing of data and profile and analysis of the Customer's habits and consumption preferences, in order to tailor products and initiatives to the Customer's tastes and needs. profiling activities performed by automated means that provide
• j) Research activities that use non-automated tools to investigate consumption habits in order to tailor products and initiatives to the Customer's tastes. The exclusive purpose of such activities is to provide customers and users with products, services and initiatives that are better suited to their needs, using methods that do not invade their personal space.

Data owners can exercise their right to object, in whole or in part, to the processing of their data for the purposes described in articles g), h), i) and j) at any time and free of charge.

The provision of personal data for the purposes described in items g), h), i) and j) is optional and its use is subject to the provision of express consent. If you refuse to give consent, this will make it impossible for you to subscribe to the "Newsletter", "Joy of Life Club" and will prevent you from receiving informative and promotional information, brochures and communications about the products, promotions and services offered by our Company.

Please note that in the context of sending promotional materials, promotional materials, informative materials and/or brochures, consent to the processing of personal data can be withdrawn at any time by selecting the relevant "delete" box, which you can access via a link in the sent communications.

Such data (especially personal information, e-mail address, postal address, telephone number and bank details - in the case of payment by credit card), the conclusion of contracts for the purchase of products through the site or certain "pre-sales" and "after-sales" services or to comply with obligations arising from legal or regulatory standards. As noted above, failure to provide this data may, depending on the particular situation, constitute a legitimate and justifiable reason for not entering into a contract for the purchase of online products and/or the provision of linked services.

We also inform you that our Company uses visitors' IP addresses in a completely anonymous manner to monitor traffic on the Site.

4. PROCESSING TOOLS AND PLACE OF COLLECTED PERSONAL DATA

4.1 Processing and security tools

The data controller has adopted the relevant security measures aimed at preventing unauthorized access, dissemination, alteration or destruction of Personal Data. Specifically, this uses technology to encrypt data in SSL as well as complying with ISO/IEC 27000 standards. Regarding the stated purposes, the data of the users are subject to automatic and manual processing by specially appointed and authorized persons in accordance with the principles of accuracy, legality and transparency, as well as the applicable laws on the protection of personal data and security measures, and the provisions of the KVKK. The processing of users' personal data is carried out through processes such as data collection, recording, arrangement, preservation, consultation, detailing, modification, extraction, comparison, use, transmission, deletion and destruction. The Data Controller may also use cookies (temporary markers designed to identify physical persons online) in order to qualify, provide, improve and personalize the products and services offered. The data controller has adopted automated decision-making procedures, including profiling. To ensure the best possible protection of personal data, we recommend that you protect the devices you use to browse (for example, with an up-to-date anti-virus system), beyond the limits of control exercised by us, and that your internet provider takes appropriate measures (for example, firewalls and anti-spam filters) for online data transfer. ) is recommended.

In some cases, in addition to the Data Controller, the following may access the Data: other persons involved in the organization of this Website and affiliated and/or affiliated companies of XXXCompany (administrative, commercial, marketing and legal personnel and system administrators) or, if necessary, acting on behalf of the Data Controller. Designated external persons, including Data Processors (such as third party technical service providers, postal couriers, consultants, hosting providers, information companies, communications agencies, credit institutions for the management of credit card payments). An updated list of Data Processors can be requested from the Data Controller at any time.

4.2 Where Data is Processed and Transferred

The data is processed at the Responsible's premises and any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.

Personal Data is saved on servers located in Turkey, however, the Data Controller reserves the right to transfer such servers to other countries, if necessary, in accordance with the provisions of the KVKK.

The Client has the right to obtain information on the legal basis for the transfer of the Data outside of Turkey or to an international public law body or an international organization consisting of two or more countries, as well as information on the security measures adopted by the Data Controller to protect the Data.

5. STORAGE TIME

The retention period of users' personal data is determined for a period no longer than necessary to fulfill the purposes of data collection and processing and in accordance with the timeframes prescribed by law. Because:

Personal data collected for purposes connected with the execution of a contract between the Data Controller and the User will only be processed until this contract is executed. Personal data collected for sales purposes are stored for a period of not longer than 10 years in accordance with financial and legal regulations.

Personal data collected for purposes related to the legitimate interest of the Data Controller will be processed until that interest is met. The User can obtain more information regarding the legitimate interest pursued by the Data Controller from the relevant sections of this document or by contacting the Data Controller.

Data processing Based on the consent of the User, the Data Controller may retain Personal Data for a longer period of time until such consent is withdrawn. In addition, the Data Controller may be required to retain Personal Data for a longer period to comply with a legal obligation or an order from a relevant authority. Personal Data will be deleted at the end of the retention period. Therefore, at the expiration of this period, the right to access, delete and rectify, as well as the right to portability of data, can no longer be exercised.

6. RIGHTS OF THE DATA SUBJECT

The Data Owner can use the following rights at any time:

The right to withdraw consent at any time. The data subject may withdraw his previously given consent for the processing of his Personal Data. The data subject should contact us directly at the following address: customerservice@nomination.com . To withdraw your consent to receive our newsletter, you can do this automatically by following the link you will find at the bottom of each communication.

The right to access your own Data. The data subject has the right to obtain information about the Data processed by the Data Controller, about certain aspects of the processing and to obtain a copy of the processed Data. The data subject can contact us directly at customerservice@nomination.com .

Right of rectification. The person concerned can confirm the accuracy of their Data and request that this Data be updated and/or corrected. The data subject can contact us directly at customerservice@nomination.com .

Limitation or right of processing. Under certain conditions, the data subject may request that the processing of their Data be limited. In this case, the Data Controller will not process the data for any reason other than keeping it.

The right to have your Personal Data deleted or removed. Under certain conditions, the Data Owner may request the deletion of his Data by the Data Controller.

The right to portability of data. The Data Subject has the right to receive its Data in a structured, commonly used and machine-readable format and, where technically possible, to have such Data transferred without hindrance to another data controller. This provision applies if the Data is processed by automated means and the processing performed is based on the consent of the Customer, a contract to which the Customer is a party, or any associated contractual measures.

Right to make a complaint. The data subject may file a complaint with the relevant supervisory authority or initiate legal action for the protection of personal data.

The right to object to the processing of data for commercial purposes. The data subject always has the right to object to the processing of his data if it is used for direct marketing and commercial purposes.

7. TOOLS FOR EXERCISE OF RIGHTS

At any time, you may exercise your rights described above in writing, by sending a registered letter to Company NOMINATION SRL, Address Via F.lli Bandiera 22, 50019 Sesto Fiorentino (FI) , (with acknowledgment of receipt) or alternatively, by sending an e-mail to customerservice@nomination.com . to the mail address or nm- customerservice@nomination.com . e-mail address and customerservice@nomination.com .it approved e-mail address. Requests are handled free of charge and processed by the Data Controller as soon as possible and in any case within a month.

8. RIGHTS OF MINORS

The services provided by the Data Controller and the Site managed by the Data Controller are not targeted to those under the age of 16 (or below the age limit determined by the legislation in the country of residence of the User), for whom the Data Controller does not knowingly collect (and subsequently use) information and personal data. In order to protect the security and privacy of minors, wherever such information is unintentionally collected and/or recorded, the Data Controller undertakes to delete it immediately upon request. Registration on the Site means confirmation that the User is of legal age in the country of residence.

9. CHANGES TO THIS STATEMENT

The Data Controller reserves the right to make changes to this privacy policy at any time, for example, in order to comply with new requirements brought by applicable legislation or technical requirements, and will inform about such changes on this page. Therefore, we ask that you consult this page regularly with reference to the most recent version.

If changes are made that affect the processing activities whose legal basis is consent, the Data Controller undertakes to obtain the User's consent again, if necessary.

10. COOKIE POLICY

This Website uses Cookies.

For more information and to view the detailed statement, the User can refer to the Cookie Policy on this page.

11. MORE INFORMATION ON THE PROCESSING OF DATA

Legal Defense

The User's Personal Data may be used by the Data Controller in preparation for legal action or to establish a final defense against misuse of this Website or connected Services by the User.

The User declares that he is aware that the Data Controller may be obliged to disclose the Data by order of the public authorities.

System Digital Logging and Maintenance

For reasons connected with its operation and maintenance, this Site and the final third party services used by the Site may collect system Logs or files that record interactions and which may also contain Personal Data such as the User's IP address.

Information not covered in this Policy

More information on the processing of Personal Data can be requested at any time from the Data Controller using the contact details provided.

COOKIE POLICY

Cookies are short lines of text that are stored on your computer by the websites you visit. They are widely used to make websites run more efficiently and to provide information to the website owner. They are used to store information about visitors' preferences and to save user-specific information (authentication, language, location and other). Some of the collected information is used for statistical and marketing purposes.

Species:

• Session cookies (they are deleted when the browser is closed)
• Persistent cookies (they are deleted after a certain period of time)
• First-party cookies (they can only be read by the domain visited)
• Third-party cookies (created and subject to external domains different from the website visited)

The table below summarizes which cookies are used.

Most web browsers allow to control cookie management via settings. For more information about cookies, including how to verify saved cookies, how to manage and delete cookie settings, please visit www.aboutcookies.org or www.allaboutcookies.org.

To disable tracking by Google Analytics on all websites, please visithttp://tools.google.com/dlpage/gaoptout .