As WHIRCLE, we show utmost sensitivity to the security of your personal data. Your personal data is processed and stored in accordance with the Personal Data Protection Law No. 6698 (hereinafter referred to as “KVKK”). The Personal Data Protection Law was published in the Official Gazette dated April 7, 2016 and numbered 29677. KVKK was regulated to protect the fundamental rights and freedoms of real persons, including the right to privacy, which is also protected by our Constitution and Turkish Penal Codes, and to determine the obligations of real and legal persons who process personal data. The purpose of this policy is to establish the management instructions, procedural requirements and a technical policy to ensure that the personal data of the relevant persons are processed and protected in accordance with KVKK by WHIRCLE (“VENTURE BİLGİ EĞİTİM VE REKLAM TEKNOLOJİLERİ AŞ”).

INFORMATION AS DATA CONTROLLER

In accordance with the Law on the Protection of Personal Data No. 6698 (“Law No. 6698”), your personal data will be collected and processed by us as the data controller within the scope explained below. As WHIRCLE, whose detailed corporate information is published below, residing at Büyükdere Cad No: 199/6 Şişli/İstanbul, in accordance with the KVKK No. 6698 and as the Data Controller, your personal data will be recorded, stored, updated, disclosed/transferred to 3rd Parties where permitted by the legislation, classified and processed in the ways listed in the KVKK within the framework explained on this page.

HOW YOUR PERSONAL DATA MAY BE PROCESSED

In accordance with the KVKK numbered 6698, your personal data that you share with WHIRCLE may be processed by us, in whole or in part, automatically or non-automatically provided that it is part of any data recording system, by obtaining, recording, storing, changing, rearranging, in short, by any kind of transaction performed on the data. Any transaction performed on the data within the scope of the KVKK is considered as "processing of personal data".

FOR WHAT PURPOSES DO WE COLLECT AND PROCESS YOUR INFORMATION?

WHIRCLE may collect and process data belonging to our users through the Web Pages and the Call, generally for the following purposes:

  • To provide personalized services to our users and increase user satisfaction by improving the user experience,
  • To communicate with our users to the extent they allow us to do so, and to inform them about services and opportunities,
  • To monitor the technical functions of the Site and Applications, to ensure that they operate as required and to resolve any problems that may arise,
  • To perform the services we offer in accordance with our user agreement,
  • To send newsletters or make promotions or notifications via e-mail,
  • To make promotions or notifications via SMS,
  • To answer your calls and respond to your support needs,
  • To develop our current and R&D stage applications and to market the product during the management process,
  • In case of your request or complaints on social media
  • In case of a complaint regarding the services we provide, to finalize the complaint.
  • To be used in various statistical evaluations, database creation and market research without revealing the user's identity,

In addition to this Personal Data Protection and Data Policy, other policies or procedures may have been adopted regarding the security, confidentiality, collection, etc. of other data. Therefore, we recommend that you also review other policies and legal texts.

 

PURPOSES AND LEGAL REASONS FOR PROCESSING YOUR PERSONAL DATA

Personal data you share;

  • In order to fulfill the requirements of the services we provide to our customers in accordance with the requirements of the contract and technology and to improve our products and services;
  • To record the identity, address and other necessary information to identify the transaction owner within the scope of the Law on Regulation of Electronic Commerce numbered 6563, the Law on Protection of Consumers numbered 6502 and the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce published in the Official Gazette dated 26.08.2015 and numbered 29457, which was prepared based on these regulations, the Distance Contracts Regulation published in the Official Gazette dated 27.11.2014 and numbered 29188 and other relevant legislation;
  • To organize all records and documents that will form the basis of payment systems, electronic contracts or paper transactions that are mandatory in the field of Banking and Electronic Payments; to comply with the information storage, reporting and notification obligations stipulated by legislation and other authorities;
  • To provide information to prosecutors, courts and relevant public officials on matters related to public security and legal disputes, upon request and as required by law;
  • In order to provide our members with a wide range of opportunities or to share these opportunities with individuals or institutions that can provide them within the legal framework;
    It will be processed in accordance with the KVKK numbered 6698 and relevant secondary regulations.

TO WHOM AND FOR WHAT PURPOSES PERSONAL DATA MAY BE TRANSFERRED

By accepting the Personal Data Policy, you have allowed the collection, storage, processing, use and transfer of your personal data, which you have given your explicit consent to be shared with WHIRCLE and WHIRCLE's domestic and international business partners within the scope of WHIRCLE applications and services, in order to provide and offer you various advantages. In addition, this information will be shared only in case of need and to the extent necessary with third parties with whom we have a contractual relationship, who have the same legal and technical responsibilities as us regarding data protection and security, and who comply with the relevant legislative provisions, in order to provide you with flawless services, to ensure that your potential shipments are delivered in a healthy manner, and to ensure that our notifications are delivered on time via phone, SMS and/or e-mail.

WHIRCLE may share your data regarding your visit to the website or mobile site or your membership, and your traffic information such as your navigation information; with public institutions and organizations that are legally authorized to request this information for your security and for WHIRCLE to fulfill its obligations under the law (such as, but not limited to, combating crime and threats to state and public security, and in cases where WHIRCLE has a legal or administrative obligation to notify or provide information).

WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU?

Your personal data may be collected in written/physical or electronic media when you receive services from WHIRCLE, use its services, enter/apply for advertising or marketing announcements, become a member or register, and through cookies.

  • Identity Information

It is possible to register or become a member of WHIRCLE through your accounts on social networks such as Facebook, Linkedin, etc. without entering information such as name, surname, date of birth, e-mail address, etc. If you choose to register or become a member of our services via social networks within the scope of this Personal Data Protection and Data Policy, you grant us the authority to process, transfer and store the data sent to us by the social networks in question.

  • Contact Information

You voluntarily share information such as your “E-mail Address”, “Address”, “City and District You Live In” and “Mobile Phone” with WHIRCLE along with your consultancy request, registration to the Web Page or call recording.

  • Photos and Visual Information

With your consultancy request, registration on the Web Page or call recording, you voluntarily share your photographs, multimedia recordings and visuals of your family and affiliates to be published.

5- Habit Information (Information in the Form)

The authorities at the receiving authority request your habit information. In this context, consumption habits, the person's sexual preference, whether or not they will enter into any illegitimate formation, preference information, religious habits, criminal habits, whether or not they have a relationship or relationship with someone of the same sex, political habits, etc. are requested. In this context, by accepting this policy, you are giving an explicit consent for the processing of this special data.

 

6- Other Information

You voluntarily share the information preferred by the Member, such as Smatch (automatic matching) information (yes/no) and other similar information with WHIRCLE.

If you choose to disclose your information or data to the public and share it in a way that other members can access and see, it will be considered disclosed by you and can be used for statistical, advertising or promotional purposes. We have no responsibility in cases where your personal data you disclose is used by third parties or other sites.

  • Other Information

You voluntarily share user-preferred information, such as Smatch (automatic matching) information (yes/no) and other similar information with WHIRCLE.

  • Information We Collect Automatically and Is Not Your Personal Data

We may collect data about you such as Login ID, IP address, log records, additional requested information, date of membership, applications made, frequency/times of logging into the site, iOS/mobile site/website user, update date, last login date, first membership date, application deleted (yes/no), usage information of applications (every action and selection made within the application), and similar technologies we use in order to adapt them to the needs of our members and visitors, to eliminate technical problems, and to control our technical infrastructure. We may collect information about your click count, frequency of opening tabs or your behavior in the digital environment regarding the titles you are interested in, depending on your use of the site through cookies or our other programs and software.

8.1. Device Information

We may collect data (such as location information) that cannot be matched with you or that can be matched with location-required applications such as the Tevkil application through the electronic devices you use (computers, laptops, tablets, smartphones, smart TVs, etc.). We may send push notifications through our mobile applications or on our website. If you do not want to receive these messages, you can reject these messages by changing the settings of your device or mobile application.

8.2. Cookies Information

Your usage information belonging to WHIRCLE can be obtained by using a technical communication file (Cookie). The technical communication files in question are small text files that a website sends to the user's browser to be stored in the main memory. The technical communication file facilitates the use of the internet by storing the status and preferences about a website. The technical communication file helps to obtain statistical information about how many people use WHIRCLE, for what purpose a person visits WHIRCLE, how many times they visit and how long they stay, and to dynamically generate content from user pages specially designed for users. The technical communication file is not designed to receive data or any other personal information from the main memory or e-mail. Most browsers are initially designed to accept the technical communication file, but users can change the settings so that the technical communication file does not arrive or a warning is given when the technical communication file is sent. The user is deemed to have given explicit approval to the use of cookies as long as they do not change these settings.

We may use cookie technology and place them on your device. If you do not accept cookies, WHIRCLE may not perform the functions you expect or may cause disruptions.

We may share data obtained through cookies with third parties for advertising purposes.
These personal data will be processed and stored in order for you to benefit from the Membership advantages, based on your explicit consent, by taking information security measures, provided that they are not used for purposes and scope other than those specified in the Privacy and Personal Data Protection Policy.

Links to Third Party Websites or Mobile Applications via WHIRCLE We may provide links to third party websites, portals or mobile applications. However, we have no responsibility for the implementation of the privacy policies on these sites or to which third parties are subject. The privacy policies on third party websites or mobile applications may differ from this Personal Data Protection and Data Policy.

 

 

HOW LONG YOUR INFORMATION WILL BE STORED

Your personal data is stored for the retention periods specified in the relevant legal legislation, or if no period is specified in the relevant legal legislation, for the period required by our Company's practices and commercial practices or for the processing purposes mentioned above, and then deleted, destroyed or anonymized in accordance with the KVKK.

If the purpose of processing personal data has ended; if the storage periods determined by the relevant legislation and our Company have also expired; personal data may only be stored as evidence in possible legal disputes or for the purpose of asserting the relevant right related to personal data or establishing a defense. In establishing the periods herein, the storage periods are determined based on the limitation periods for asserting the said right and the examples of previous requests directed to our Company on the same issues despite the expiration of the limitation periods. In this case, the stored personal data is not accessed for any other purpose and access is provided to the relevant personal data only when it is necessary to be used in the relevant legal dispute. Here again, after the mentioned period has expired, personal data is deleted, destroyed or anonymized.

Records of memberships and sales

10 years

Law No. 6098

All records related to accounting and financial transactions

10 years

Law No. 6102, Law No. 213

Cookies

Maximum 540 days

 

Commercial electronic message approval records

1 year from the date of withdrawal of approval

Law No. 6563 and related secondary legislation

Traffic information about online visitors

2 years

Law No. 5651

Personal data regarding Tarfin Agricultural Dealer and Farmer Customer

10 years after the legal relationship ends

Law No. 6102, Law No. 6098, Law No. 213,

Personal data regarding suppliers

10 years after the legal relationship ends

Law No. 6102, Law No. 6098 and Law No. 213

WHIRCLE stores the personal data it processes in accordance with Article 7 of the KVKK and Article 138 of the Turkish Penal Code only for the period stipulated in the relevant legislation or, if no period is stipulated in the legislation, for the period required for the purpose of processing personal data. The data kept will be deleted after the purpose of keeping the data has ended, and although an average of 2 years is determined, data foreseen for a longer period by legislation will continue to remain in the system for the period specified by legislation.

Personal data processed in accordance with the provisions of the KVKK and other relevant laws must be deleted, destroyed or anonymized by WHIRCLE, ex officio or upon the request of the relevant person, in a way that will not be used or recovered in any way, if the reasons requiring processing are eliminated. The procedures and principles regarding the lawful destruction or anonymization of personal data will be carried out in accordance with the principles and rules to be specified in the KVKK Regulation.

SECURITY OF PERSONAL DATA

WHIRCLE's obligations regarding data security
Pursuant to Article 12 of the KVKK, WHIRCLE's obligations regarding data security, as the data controller, are as follows:

  • Personal data;
  • To prevent unlawful processing,
  • To prevent unlawful access,
  • To take all kinds of technical and administrative measures to ensure its preservation,
    To conduct or have conducted necessary audits within the organization,

It takes the necessary measures to ensure that the persons who process personal data on its behalf or the officials working in its bodies do not disclose the personal data they learn during the course of their duties to others in violation of the provisions of the law and do not use them for purposes other than processing, even if they resign from their duties. It notifies the relevant person and the Board in the event that the processed personal data is obtained by others in violation of the law.

Measures taken by WHIRCLE regarding data security
In order to fulfill its obligations regarding the security of personal data and to act quickly in cases where security poses a risk, WHIRCLE takes the following measures:

Technical and administrative measures taken to prevent unlawful access to personal data. The technical and administrative measures to be taken regarding the processing, transfer and storage of personal data are listed in the relevant sections. Although WHIRCLE is obliged to take these measures completely and prevent unlawful access; if third parties still have unlawful access to personal data; it takes all technical and administrative measures in accordance with the relevant legislation and Board decisions regarding the protection of personal data to prevent harm to the relevant parties.

Measures taken for the protection of personal data and their auditing are periodically monitored and audited to ensure that the data recording systems used within WHIRCLE are created and used in accordance with the KVKK and relevant legislation, and a report is made to the authorized person or board in this regard.
WHIRCLE is obliged to inform and raise awareness of the natural or legal persons who process personal data on its behalf based on the authority granted to it, regarding the legal protection of personal data; and also to determine provisions for the legal protection of personal data within the framework of the contracts concluded with these persons.

Measures to be taken in case of unauthorized disclosure of personal data
WHIRCLE is obliged to take measures to prevent unauthorized disclosure of personal data and to establish an internal policy in this regard. In addition, in such cases, WHIRCLE, as the data controller, is obliged to inform the persons whose personal data are unauthorizedly disclosed and the KVKK Board. From the moment Users and/or Members (Natural Persons) start using the Site, they accept that all information collected from them will be used by WHIRCLE as described in this Personal Data Protection and Data Policy. Information regarding Users and/or Members (Natural Persons) is provided to WHIRCLE entirely with their own free will. Users and/or Members (Natural Persons) are free to provide or not provide this personal information to WHIRCLE. It is the responsibility of the Users and/or Members (Natural Persons) to ensure that the information provided by the Users and/or Members (Natural Persons) is accurate and complete. Users and/or Members (Natural Persons) should not provide false, misleading or incomplete information.

AGE OF RECEIVING SERVICES

We do not knowingly process the data of users under the age of 18. All of our departments, including the real and legal persons we cooperate with, are aware of the sensitivity of your children's personal data and we take the utmost care to protect this data. Sharing the personal data of your child under the age of 18 with us is the responsibility of the parent or legal representative.

YOUR RIGHTS

Article 11 of the KVKK No. 6698 entered into force on October 7, 2016, and pursuant to the relevant article, the rights of the Personal Data Owner after this date are as follows:

  1. Personal Data Owner, by applying to WHIRCLE, can obtain information regarding himself/herself;
  2. Learning whether personal data is being processed,
  1. To request information regarding the processing of personal data,
  1. To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
  2. To know the third parties to whom personal data is transferred, either domestically or abroad,
  1. To request correction of personal data if it is processed incompletely or incorrectly,
  1. Request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVKK,
  2. To request that, in case of correction, deletion or destruction of personal data, these operations be notified to third parties to whom personal data has been transferred,
  3. To object to a result that is to the detriment of the person himself/herself, as a result of the analysis of the processed data exclusively through automatic systems,
  4. To request compensation for damages in case of damages due to unlawful processing of personal data,

 

APPLICATION METHOD

If you would like to learn how your information is processed and/or transferred and/or processed in relation to the above conditions, you can write to info@vb.com.tr.
If you wish, you can send your petition/question/complaint to the address Büyükdere Cad No: 199/6 Şişli/İstanbul, along with your name-surname, signed in wet ink and documents that prove your identity, to WHIRCLE, the person responsible for your data, as the recipient. The requests in your application will be finalized free of charge within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost for the Company, the fee determined by the Personal Data Protection Board may be charged.

By sharing your personal data on our website, applications and other channels, you accept our Personal Data Policy and the terms and conditions regarding processing, processing methods, transfer, sale of data and other related issues in our policy, the use of data shared with WHIRCLE on the website, applications and social media channels, notifications and suggestions, and the sharing with third parties for commercial purposes provided that it is for the benefit of the members, and you accept this, and you will apply to WHIRCLE before exercising your legal rights. This is defined as “consent that is of great importance, based on information and expressed with free will, regarding a specific issue” in the KVKK. explicit consent You declare that you accept this.