1. Introduction
The security and/or protection of your personal data is among our priorities as BOA INVESTMENT HOLDINGS BV ŞİRKETİ (“Company/Our Company”). With this awareness, as a Company, we attach great importance to the processing and storage of all personal data of all persons associated with the Company, including those who benefit from our products and services, in accordance with the Personal Data Protection Law No. 6698 (“PDP Law”). In this direction, in the capacity of “Data Controller” as defined in the PDP Law and in accordance with Article 10 of the PDP Law and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform (“Communiqué”) published by the Personal Data Protection Board in the Official Gazette dated 10 MARCH 2018 and numbered 30356, in order to fulfill the duty of informing personal data owners during the acquisition of personal data; During the collection of personal data by our Company, we provide this information to personal data owners regarding the identity of our Company, the purpose for which personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method and legal reason for collecting personal data, and the rights of the personal data owner within the scope of Article 11 of the Personal Data Protection Law.
Expressions such as “we” and “our” in this Disclosure Text are used to refer to BOA INVESTMENT HOLDINGS BV. unless expressly stated otherwise.
2. Definition of Personal Data
Within the framework of Article 3/I(d) of the PDP Law, “personal data” refers to any information relating to an identified or identifiable natural person. In this context, personal data refers to any information relating to an identified or identifiable natural person. For example; your name, surname, Turkish identity number, address, telephone number, e-mail address, date of birth, the IP number you access, information regarding your transactions, etc. are your personal data. In addition, according to the PDP Law; data relating to a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and attire, memberships in associations, foundations, unions, etc., health, sexual life, criminal conviction and security measures, as well as biometric and genetic data, etc. are special personal data. In this context, anonymous information, information that has been made anonymous and other data that cannot be associated with a specific person are not considered personal data in accordance with our Company’s Policy on this matter.
Concept of Processing of Personal Data
Within the framework of Article 3/I(e) of the Personal Data Protection Law, processing of personal data refers to any operation performed on data, such as obtaining, recording, storing, preserving, changing, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, in whole or in part, by automatic means or, provided that it is part of any data recording system, by non-automatic means.
Clarification Text
3. Scope of the Clarification Text
Identity of Data Controller
According to the PDP Law, the "Data Controller" refers to 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. According to the PDP Law, the Addressee is the "Data Controller".
The Corporate Identity Information of BOA INVESTMENT HOLDINGS BV is as follows:
Trade Registry Number:
….., Istanbul
Central Registry Number:
Tax Office:
0608134727300001
……Tax Office
Tax Number:
……………..
Head Office Address:
Eski Büyükdere Street, Maslak Link Plaza No: 3-5, Floor Mezzanine (A), Maslak / Istanbul 34398
Telephone:
0 212 286 15 58
Fax:
Website:
Email Address:
Collection, Processing and Processing Purposes of Personal Data
Your Personal Data may vary depending on the service, product or commercial activity provided by our Company; and is/may be collected verbally, in writing or electronically through automatic or non-automatic methods, offices, branches, dealers, call center, website, social media channels, mobile applications and similar means.
Within the scope of Article 5.2 and Article 6.3 of the PDP Law, in order to fulfill our legal obligations, to establish or execute a contract, to fulfill our legal obligations, to establish, exercise or protect a right and to protect our legitimate interests without harming your fundamental rights and freedoms, and in terms of personal data you have made public, it may be processed without your explicit consent. Again, your personal data may be processed within the scope of the purposes specified in this Disclosure Statement, provided that your explicit consent is obtained within the scope of Article 5.1 and Article 6.2 of the PDP Law. You may obtain all our services without being included in our other membership/loyalty program/programs and memberships, especially the BOA INVESTMENT HOLDINGS BV membership/loyalty program. On the other hand, since BOA INVESTMENT HOLDINGS BV membership/loyalty program and our other loyalty programs and memberships offer special advantages to their members, by joining the programs/becoming a member in order to benefit from the program/membership advantages, you give your explicit consent to the processing of your Personal Data, except for exceptional cases.
Your collected personal data is/will be processed in accordance with the personal data processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law and other applicable legal regulations for the purposes of ensuring that our business units carry out the necessary work to enable you to benefit from the products and services offered by our Company, that the products and services offered by our Company are customized and recommended to you according to your tastes, usage habits and needs, that the legal and commercial security of our Company and the persons who have a business relationship with our Company (administrative operations for communication carried out by our Company, ensuring the physical security and control of the Company's locations, business partner/customer/supplier (authorized persons or employees) evaluation processes, legal compliance process, financial affairs, etc.), that the commercial and business strategies of our Company are determined and implemented, and that the human resources policies of our Company are carried out.
To Whom and for What Purposes Can Processed Personal Data Be Transferred Domestically and/or Abroad?
Your personal data collected; Carrying out the necessary work by our business units to make you benefit from the products and services offered by our Company, customising the products and services offered by our Company according to your likes, usage habits and needs, ensuring the legal and commercial security of our Company and the persons who have a business relationship with our Company (administrative operations for communication carried out by our Company, ensuring the physical security and supervision of the Company's locations, business partner / customer / supplier (authorized or employees) evaluation processes, legal compliance process, financial affairs, etc.). b.) for the purposes of determining and implementing the commercial and business strategies of our Company and ensuring the execution of our Company's human resources policies,
To the administrative and official authorities that are legally required to be transferred, to the relevant persons and institutions for the fulfilment of the legal obligation, to independent audit companies, tax consultants and other external professional consultants, lawyers, insurance companies, partners, domestic and foreign third parties from which services are or will be received, our shareholders, business partners, suppliers, legally authorised public institutions and private persons, both within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law and within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law.
Method and Legal Grounds for Collecting Personal Data
Your personal data, audit and consultancy services, written / digital applications made to our Company's employees, our website, calling our phone numbers, social media, SMS channels, and other verbal, written or electronic media, automatic or non-automatic methods and other channels through which our Company communicates with you or may communicate with you in the future are obtained for the purposes of carrying out our activities, fulfilling our contractual and legal obligations between you and us, and the personal data obtained are stored within the legal periods in accordance with the relevant Legislation.
Rights of the Personal Data Owner listed in Article 11 of the KVK Law
As personal data owners, if you submit your requests regarding your rights to our Company by the methods set out below in this Clarification Text, our Company will finalise the request free of charge within thirty days at the latest, depending on the nature of the request. However, if a fee is stipulated by the Personal Data Protection Board, the fee in the tariff determined by our Company will be charged. In this context, personal data owners, in accordance with Article 11 of the PDP Law;
To learn whether his/her Personal Data is processed or not, to request information if it has been processed, to learn the purpose of processing his/her Personal Data and whether they are used in accordance with their purpose, to know the third parties to whom his/her personal data is transferred domestically or abroad, to request correction of his/her personal data in case of incomplete or incorrect processing, to request deletion or destruction of his/her personal data in case the reasons requiring the processing of his/her personal data disappear, to be evaluated within the principles of purpose, duration and legitimacy, In the event that their Personal Data is corrected, deleted or destroyed, they have the right to request that these transactions be notified to third parties to whom personal data is transferred, to object to this result in the event that a result arises against them in the event that their processed personal data is analysed exclusively through automated systems, to request the compensation of the damage in case their Personal Data is processed unlawfully and they suffer damage for this reason.
Pursuant to paragraph 1 of Article 13 of the KVK Law, you can submit your request to exercise your rights mentioned above to our Company in writing or by other methods determined by the Personal Data Protection Board. Since the Personal Data Protection Board has not determined any method at this stage, you must submit your application to our Company in writing in accordance with the KVK Law. In this context, the channels and procedures to submit your written application to our Company within the scope of Article 11 of the KVK Law are explained below:
In order to exercise your rights mentioned above, you can send your request containing the necessary information identifying your identity and your explanations regarding the right you request to exercise among the rights specified in Article 11 of the KVK Law; by filling out the form at www.boainvestmenbv.com, you can send a signed copy of the form to Eski Büyükdere Caddesi, Maslak Link Plaza No: 3-5, Kat Asma Kat (A), Maslak / Istanbul 34398 by hand with documents identifying your identity, send it through a notary public or other methods specified in the KVK Law, or send the relevant form to .......... with secure electronic signature.
In cases where your personal data is processed with explicit consent, we would like to emphasize that if you withdraw your explicit consent, you will be removed from the membership / loyalty programme where the processing based on such explicit consent is required and you will not be able to benefit from the advantages you have benefited from as of the relevant date.
