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Privacy Notice on the Processing of Personal Data

“PORLAND PORSELEN SANAYİ VE TİCARET ANONİM ŞİRKETİ”

INFORMATION NOTICE REGARDING THE PROCESSING OF PERSONAL DATA

1. What is personal data, and who processes it?

Pursuant to Article 3 of the Law No. 6698 on the Protection of Personal Data (“KVKK”), personal data means any information relating to an identified or identifiable natural person.
Porland Porselen Sanayi ve Ticaret Anonim Şirketi (“Company”) may, in its capacity as “data controller” under the KVKK, record, store, update, process, disclose to third parties, and transfer your personal data in accordance with the law.

2. For what purposes can your personal data be processed?

Your personal data collected as listed below may be processed under the following legal grounds:

Identity Information:

  • Based on your explicit consent,
  • Where it is necessary for the establishment or performance of a contract to which you are a party (Art. 5/2-c)

Contact Information:

  • Based on your explicit consent,
  • Where it is necessary for the establishment or performance of a contract to which you are a party (Art. 5/2-c)

Transaction Security Information:

  • Based on your explicit consent,
  • Where it is necessary for the establishment or performance of a contract to which you are a party (Art. 5/2-c)

Your data may be collected and processed, by automatic or non-automatic means, via the following channels:

  • Electronically via non-automated means through our website https://pioli.co/,
  • Electronically via cookies that communicate with your device (which typically collect anonymized data),
  • Electronically via emails through our marketing network managed and operated by the Company,
  • Through communications carried out via our corporate email addresses.

The personal data collected through the methods listed above may be processed by the Company for the purposes detailed below:

Under Articles 5.2 and 6.3 of the KVKK:
As a rule, your personal data is processed based on your explicit consent. However, in exceptional cases allowed by law, your data may be processed without your consent, including:

  • To fulfill legal obligations (e.g., tax, consumer protection, obligations under the Turkish Code of Obligations or Commercial Code),
  • If you are unable to give consent due to actual impossibility,
  • To address your inquiries and complaints, and in case of legal disputes,
  • For legitimate interests such as cost efficiency, effective use of resources, monitoring call center service quality, ensuring security, assessing and resolving your requests — provided that this does not violate your fundamental rights and freedoms.

Additionally, personal data that has been made public by you (e.g., via social media or your website) may be processed within the limits set by law without requiring further consent. For any processing not covered by these conditions, your explicit consent will be sought.

Under Articles 5.1 and 6.2 of the KVKK:
With your explicit consent, your data may also be processed for:
i. Communication, advertising, marketing, product/service offers, information sharing, and promotions,
ii. Archiving for marketing and future business collaboration,
iii. Contract management,
iv. Execution of marketing activities,
v. Ensuring continuity of communication and marketing efforts,
vi. Providing personalized content during website visits,
vii. Sending electronic commercial messages (e.g., newsletters, campaigns, surveys, advertisements).

3.To whom and for what purposes can your personal data be transferred?

Your collected personal data may be transferred:

  • To fulfill legal obligations,
  • For operational activities carried out by our business units,
    To the following parties:
    a) Our business partners,
    b) Authorized Company personnel,
    c) Our affiliates,
    d) Public institutions and private entities legally authorized to request such data,

In accordance with Articles 8 and 9 of the KVKK.

4.What is the legal basis and method for collecting your personal data?

Your personal data is collected via the forms on our website, based on the legal grounds mentioned in Article 2 of this Information and Consent Text. The collected data may be processed and transferred for the purposes outlined in Articles 2 and 3, in compliance with the KVKK.

5.Transfer of Personal Data to Third Parties and/or Abroad

Your personal data may be processed in accordance with the purposes mentioned above and based on your explicit consent as provided through your approval of this Information and Consent Text.

If necessary for providing benefits under the law or contractual obligations, this data may be shared with domestic or foreign entities. It may also be used for legal record-keeping and auditing purposes.

Your personal data may further be shared with our business partners, affiliates, suppliers, legally authorized public institutions, and other relevant third parties for the following purposes, in compliance with Articles 8 and 9 of the KVKK:

  • Execution of advertising and promotional activities,
  • Provision, improvement, and fulfillment of services/products,
  • Execution of business processes and ensuring compliance with laws and internal policies,
  • Customer communication (subject to your explicit consent),
  • Product/service offers, promotions, and marketing activities,
  • Market research and portfolio management aligned with your interests and preferences,
  • Ensuring legal and commercial security of the Company and related parties,
  • Improving website user experience and commercial strategy execution.

6.What communication-related personal data is processed?

For the reasons stated in Article 2, the contents of emails sent to the Company’s official addresses, contact details registered through the website, and the IP addresses of the devices used to access the site may be monitored, backed up, reported, and analyzed at any time without prior notice, by the Company or authorized persons.

7.For how long is your personal data processed?

The personal data shared through the channels mentioned in this Information Notice will be processed for as long as required by applicable legislation — particularly the KVKK — or until the legitimate purposes for processing cease to exist.

8. What are your rights under Article 11 of the KVKK?

As per Article 11 of Law No. 6698, you have the right to:

  • Learn whether your personal data is being processed,
  • Request information if it has been processed,
  • Learn the purpose of processing and whether it is being used accordingly,
  • Know the third parties to whom data is transferred domestically or abroad,
  • Request correction if data is incomplete or inaccurate,
  • Request deletion or destruction of personal data under conditions set by Article 7,
  • Object to outcomes against you resulting from automated processing,
  • Demand compensation if you suffer damage due to unlawful processing.

9.How can you exercise your rights?

You may submit your requests regarding your rights using a signed written application, or via secure electronic signature, mobile signature, registered email (KEP), or through your email address previously registered with the Company.

For written applications:
Address: Büyükdere Cad. No:245 USO Center, Floor 12, No:43, Maslak – Sarıyer / Istanbul, Turkey
If someone else is applying on your behalf, they must provide a notarized power of attorney.

Properly submitted requests will be answered free of charge within 30 days. If the response exceeds 10 pages, a fee of 1 Turkish Lira per page may be charged for each additional page. If the response is provided in physical media such as CD or flash drive, the cost of the media may be charged.

This Information and Consent Text regarding the processing of your personal data by our Company has been made available for your review and has been shared with you for that purpose.