Privacy Notice for Protection of Personal Data
Dear Visitors, Subscribers and Customers, In accordance with the provisions of Law No. 6698 on the Protection of Personal Data (the “Data Protection Law”),as the data controllerNURDOĞUŞ GİYİMSAN. VE TİC. A.Ş. , (“EXPLOSION/Company”) has the obligation to enlighten, in this context it is aimed with this privacy notice to inform you about your rights as the “Data Subject” and about the personal data processing procedures at Explosion.
- It is aimed with this information note to shed light on how and why your personal data is processed in the following situations:When you visit and/or shop at Explosion stores (“Stores”),
- When you visit (“Online Visitor”) Explosion’s website explosion.com.tr (“Website”), become a Website Member (“Website Member”), shop online via Explosion’s Website or send products/gifts to third persons,
- When you consent to receive general and personalized campaign notifications via commercial communication channels,
- When we interact via our communication channels, and
- When you participate in campaigns, contests, sweepstakes and other events that Explosion organizes.
- What are our Purposes to Process your personal data and What Types of Personal Data do We Process?
When you visit our stores: We process:
- Store Security Camera Recordings in our stores for the following reasons: in order to ensure security of you, Explosion, Explosion’s employees’ and other third parties’ against any acts, crimes or illegal behaviors which might occur in our stores, to fulfill our contractual obligations particularly in terms of our airport stores as well as to fulfill our legal obligations such as provision of information, documents and to fulfill other relevant obligations towards official/judicial institutions and organizations;
- Your name and phone number as well as your size and shoe size information, if provided as part of your request, when you ask to be notified when the product you want arrives at our stores.
When you shop at our stores: We process:
- Your name, surname, city, district, purchase (purchase date and time, amount, purchased products), and payment (payment method and details) information in order to conduct purchase transactions, to conclude and execute sales agreements, to issue invoices, to conduct accounting procedures, and to provide aftersales support services (alteration, replacement, return, product inspection, etc.); as such your e-mail address in order to transmit e-invoice/e-archive invoice of your purchase in electronic mediums, and additionally, your Turkish identification number and passport number if you are resident abroad and want to benefit from tax refunds, as such your phone number and signature if an expense receipt shall be issued,
- In addition to these, your Turkish identification number and your invoice information to be placed on the invoice, if you are a tax-payer and if your purchase amount exceeds the set receipt limits, as well as an invoice is required for legal reasons or if such invoice is requested by you in order to fulfill our legal obligations.
- Your name, surname, order number and the content of your order to ensure pickup of the products, which have been ordered online, from the Store if you use the “Click & Collect” service.
When you visit the Website:
When you sign up to the Website (Website): We process:
- Your name, surname, e-mail address and mobile phone number, in order to complete and activate your membership, to record your membership information, to ensure your login, to make notifications regarding your membership, to fulfill the requirements of the membership agreement, to enable your login to Website by way of using only login credentials without entering all membership information every time as well as to enable your shopping – again – without entering all membership information every time and your log records for the purposes of transaction security
- In addition to these, your address if you provide your address details to be used while shopping on the Website,
- User ID since it is automatically assigned during your membership,
- Your purchase (purchase date and time, amount, purchased products) and payment (payment method and details) information in order to display your order history as a member,
- Your name, surname, gender, date of birth, only if you prefer to share it,your e-mail, mobile phone number, and User ID that is assigned automatically by the system when you sign up to the Website in order to update the information you have provided Explosion during your registration or through other channels and/or information that you may change later for all your memberships (Website, etc.) and to fulfill our obligation to keep your personal data up-to-date,
- Your name, surname, gender, e-mail, mobile phone number, date of birth, only if you prefer to share, city, district, demographic information in order to communicate special deals and offers based on your Website membership and purchases, to create general or personalized campaigns, advantages, promotions and advertisements, to organize campaigns, contests, sweepstakes and other events as such to conduct segmentation, profiling, reporting, marketing and analytics activities, to carry out Explosion’s advertisements and marketing/communication activities (Website notifications, pop-ups, personalized offers, customization of user screens, surveys, etc.) on Explosion’s, Website or other third party mediums, to perform activities to improve customer experience, and to carry out strategic planning, analytics and business development activities related to operational processes; and in addition to these Website anotifications/surveys/offers/campaigns, habits, favorites, likes, behaviors, preferences, searches, segments, purchase history, cookie logs, cookie and ad identifier/ID and device ID, communication preferences, purchase amount, payment methods/channels and preferences, bank information regarding payment, brand, model, specifications and operating system information of the device used, telecom operator, and survey responses.
When you shop on the Website (with or without signing up): We process:
- Your name, surname, signature, email, mobile phone number, address, size and shoe size, log records of your purchase transaction and IP address when you shop on the Website with or without signing up in order to perform the sales transactions and to fulfill the requirements of the distant sales agreement, such as to issue and transmit the e-invoice/e-archive invoice of your purchase, to deliver your order, to ensure pickup of the products, which have been ordered online, from the Store, if you use the “Click & Collect” service, and provide aftersales support services (alteration, replacement, return, product inspection, etc.),
- In case you shop by using a gift card, in addition to the standard shopping transactions, information about who purchased the gift card, your gift card usage information, history of your purchases realized by the gift card,
- Your Turkish identification number to be placed on the invoice, if your purchase amount exceeds the set legal receipt limits or if it is requested in order to fulfill our legal obligations.
- Your full name on the credit/debit card, credit/debit card number, the bank that issued the card, and bank account (IBAN number) when a refund is to be made if you choose the payment on delivery option,
- Your credit/debit card details (first 4 and last 4 numbers, expiration date, points, bank that issued the card and card type) to ensure collecting of the payment, if the payment is made by a credit/debit card,
- Your full name, bank used for payment, and details on the bank receipt, if the payment has been made by money order/ EFT ,
- Your order details (order date, time and amount, products ordered, payment method, order/gift note, reference number of the order) and your e-mail and order number, if you track your order by way using the order query screen.
When a purchased product is shipped to a third person: We process:
- The address and the name and surname included in that addresswhen products you purchased are sent to third parties in order to ensure that they are delivered to the right person and to provide aftersales support services (alteration, replacement, return, product inspection, etc.). In such cases, the responsibility to inform the said person(s) belongs to you as the person disclosing this information.
- Your address and your name and surname included in the addresswhen products/gifts third parties purchased are sent to you in order to ensure that they are delivered to you and to provide aftersales support services (alteration, replacement, return, product inspection, etc.).
When you consent to receive Explosion’s commercial communications through any channel: We process:
- Your name, surname, mobile phone number, e-mail and log records when you give permission/explicit consent to receive Explosion’s commercial communications through any channel, and in addition to these your signature when you give the commercial communication consent at the store to enable Explosion to offer general or personalized campaigns, benefits, product and service promotions, surveys and customer satisfaction applications, as such to enable Explosion to carry out commercial communication activities within the scope of promotions, advertisements, information, marketing activities though the channels (SMS, e-mail, etc.) of your preference and to enable Explosion to communicate invitations regarding campaigns, contests, , sweepstakes, receptions and other events.
When you contact us through our Communication Channels: We process:
- Your name, surname, social media user name , e-mail, mobile phone number and landline, if you have shared, when you engage with us via call center, e-mail, Website, social media and similar channels (“Communication Channels”) in order to resolve your requests and complaints, and to contact you when needed for such requests and complaints, to address you properly when you contact our call center, to ensure service/transaction security, to manage, monitor and report all customer relations processes, and improve quality standards, and in addition to these, your legal action details, requests and complaints, log records and other details you may communicate in relation and if relevant to your request or complaint,
- Your call center voice recordings to be used in our customer satisfaction-related activities and as evidence in disputes that may arise.
- Store Security Camera Recordings of your store visit, in case your requests and complaints are related to our stores,
- In addition to the above, your order and purchase history, invoices, and redemption of points/discounts/benefits when you create an order or shop on the Website.
Legal Procedures and Internal Processes We process:
- Your name, surname, gender, date of birth, if you prefer to share, in order toensure security of you, Explosion and of Explosion’s employees’ and other third parties’ against any acts, crimes or illegal behaviors, to fulfill our legal obligations, and to fulfill our legal obligations towards relevant authorized private and public institutions and organizations; to exercise our rights to file lawsuits, to reply and object to disputes before public and judicial authorities and institutions such as courts and execution offices; to conduct dispute negotiation and resolution processes; to deliver the information you have requested or demanded as part of your legal rights; to prevent usage in contrary to the contractual and legal provisions; todetect suspicious transactions and illegal use; to perform cancellations; to conduct internal audit and control, reporting, development activities as well as activities and developments to improve customer experience; to carryout strategic planning, analytics and business development activities related to operational processes; and in addition to these, your signature and Turkish identification number, mobile phone number, e-mail, address, requests and complaints, purchases, size and shoe size, invoices, payment information (first 6 and last 4 digits ofthe Credit/Debit card, payment amount, bank that issued the card, reference number), call center voice recordingsif they need to be submitted due to legal procedures or if they are provided in the documents sent by official authorities; as such your log records, User ID, IP address, if you have made the transactions on the Website, as well as Store Security Camera Recordings if you made the transaction at the store, and correspondence and file information regarding your legal procedures and disputes, ,
- With respect to Online Visitors, cookie logs (IP address, browsing data, device information (ID) and traffic data) in order to ensure information technology security and prevent malicious usage, to carry out the activities in compliance with applicable laws, and to fulfill our other legal obligations towards relevant authorized public institutions and organizations.
2. What are the Methods and Legal Grounds for Processing Your Personal Data?
We collect your personal data through the Stores, including franchisees with whom we use a shared customer management and cash register system, through our business partners or suppliers usingStore Security Camera Recordings and devices at the store by automated methods such as recording your verbal interactions with the sales representatives and the information you provide to them, by storing information related to your purchases at the Stores/Website or the information you provide during registration on the Website, and performing transactions through these channels, recording of all kinds of shopping, collection, delivery, transaction, survey filling, registration, behavioral actions and transactions on the Store/Websiteto our systems, , recording the requests and complaints you communicate to us through the Communication Channels, Head Quarters or Stores during our interactions, and by automated methods such as recording of your conversations with the call center, recording the information/documents related to you sent by the official and judicial institutions and organizations, and recording the records of your return/review processes to the relevant documents. We collect/process your personal data on legal grounds detailed below:
- Regarding completion of your Website membership, fulfillment of our duties arising from the membership agreements and sales and aftersales support processes, “Processing of personal data of the parties to an agreement is required, provided that it is directly related to the establishment or performance of an agreement”,
- Regarding personal data processing procedures and commercial communications of marketing, segmentation and analytics activities within the scope of Website membership, your “explicit consent”, Regarding Website membership, and Website use, “processing of personal data is required for the legitimate interests of the data controller” in order to detect and prevent suspicious transactions, to ensure transaction security, to perform operational processes (strategic planning, analytics and business development activities) and customer relations processes,
- RegardingStore Security Camera Recordings processes at the stores,“processing of personal data is required for the legitimate interests of the data controller,” “data processing and transfer isrequired for establishing, exercising or protecting rights” and “fulfilling legal obligations”,
- Regarding our obligations arising from applicable legislation, “fulfilling legal obligations” and “explicitly prescribed by law”,
- Regarding legal disputes, investigations and other judicial/official processes, “data processing and data transfer is required for establishing, exercising or protecting rights”,
- Personal data has been made public by the person concerned.
You may (i) stop commercial communication by performing the action (reject) specified in the commercial electronic messages we send, and/or (ii) withdraw your explicit consent regarding the Website membership and terminate the relevant membership at any time and without any reason, in this way you may stop processing procedures of your personal data based on explicit consent.
3. To Whom and For What Purposes Do We Transfer Your Personal Data? At Explosion, we transfer your personal data to third parties only for the purposes stated in this Privacy Notce for e Protection of Personal Data and in accordance with Articles 8 and 9 of the Data Protection Law.
- We transfer personal data to business partners, suppliers and service providers resident in Turkey or abroad (electronic communication service providers, call centers, tailors that provide alteration services, personal data aggregators through devices, marketing/advertisement/analytics service providers, database and server service providers , infrastructure maintenance and support service providers, legal counsels and financial consultancy service providers, e-invoice/e-archive invoice service providers, independent auditors, shipping/cargo/courier, archiving and warehouse service providers) for purposes such as delivery of the products you have purchased related to your membership, orders or purchases, providing logistics and aftersales support services, resolving your requests and complaints and contacting you when necessary for these, and procuring information technology, marketing/advertising/analytics activities or specialty consulting services, etc., provided that the data is used within the scope of the services, that are provided in order to enable Explosion to carry out its activities.
- We transfer personal data to relevant authorized private and public institutions and organizations and official/judicial authorities in order to fulfill our legal obligations to provide information, documents and other relevant obligations, and to exercise our rights to file lawsuits, reply and object to disputes before the said authorities and institutions,
- When required, we transfer personal data to our consultancy service providers and payment institutions, that are involved with the relevant transaction, to monitor and detect suspicious transactions and prevent illegal transactions.
- We transfer personal data to our suppliers as part of the activities to increase traffic on the Website.
- We transfer personal data to third parties such as banks and electronic payment organizations, etc. when the payment is made by a credit/debit card, provided that it is transferred to the relevant payment institution without being registered by Explosion.
- We transfer personal data to the franchisees with whom we use a shared customer management and cash register system to carry out business procedures.
4. What are Your Rights Under the Data Protection Law?
You may communicate your requests related to your personal data, which has been processed by Explosion within the scope of Article 11 of the Data Protection Law and in accordance with the Communiqué on Procedures and Principles of Applications to the Data Controller, at any time either in written form or your e-mail address you have previously shared with Explosion and which is available in our records to the addresses provided below.
Data Controller:NURDOĞUŞ GİYİMSAN. VE TİC. A.Ş.