VIAVETA’S POLICY ON PROCESSING AND PROTECTION OF PERSONAL DATA

1. The purpose of our policy on processing of personal data and the position of our company as data controller:

Our company, ViaVeta (“the “Company”), possesses the capacity of “data controller” under the Law on the Protection of Personal Data (the “Law”) in regard to personal data of customers and aims to inform the customers on the personal data processing procedures performed by ViaVeta through the Text of our policy on processing personal data and pursuant to the relevant Law, and to obtain their explicit consents for the cases described in the Clause 3 below.

2. Purpose of Processing Personal Data of Customers:

The personal data of the customers are processed for the performance of the operations to enable the relevant persons to utilize the products and services offered by ViaVeta and for the implementation of the relevant business processes, performance of operations to enable the commercial activities implemented by ViaVeta and implementation of the relevant business processes, planning and performance of the commercial and/or business strategies of ViaVeta, assurance of the legal, technical and commercial business security of ViaVeta and the persons in a business relationship with ViaVeta and planning and performance of the activities required to suggest and promote these products and services offered by ViaVeta customizing based on the likes, using habits and needs of the relevant persons under the personal data processing terms and purposes set out in the Clauses 5 and 6 of the Law.

Detailed information on the processing of personal data by ViaVeta can be found in the Policy on the Processing and Protection of Personal Data issued by Via Veta under the relevant Law at https://www.viaveta

3. Personal Data to be Processed in line with the Express Consent of Data Subjects and Purposes of Processing:

Express consent of the customers must be obtained for the processing of personal data by ViaVeta in following cases where the personal data processing requirements set out in the clause of the Law are not able to be met.

In this regard, personal data of the customers may be processed in line with the consent of the Customer and shared with the Parties specified in the Text of the policy on the processing of personal data for the purposes of creation of campaigns for customers, cross selling, implementation activities to improve the user experience by tracking the Customer movements, and to develop the VieVeta web site and mobile application performance and customization based on the Customer needs, performance of direct or indirect marketing, customized marketing and remarketing activities, performance of customized segmentation, targeting, analysis and in-house reporting activities, market researches, planning and performance of customer satisfaction activities and planning and performance of customer relations management processes as well as planning and performance of sales and marketing processes of Via Veta’s products and/or services, planning and performance of the processes of building and/or enhancing loyalty to the products and/or services offered by Via Veta.

4. Transfer of Personal Data of Customers:

The personal data of the customers may be shared with ViaVeta and our company officers, shareholders, business partners, suppliers, legally authorized public institutions and organizations and legally authorized private institutions for the performance of the operations to enable the relevant persons to utilize the products and services offered by ViaVeta and for the implementation of the relevant business processes, performance of operations to enable the commercial activities implemented by ViaVeta and implementation of the relevant business processes, planning and performance of the commercial and/or business strategies of ViaVeta, assurance of the legal, technical and commercial business security of ViaVeta and the persons in a business relationship with ViaVeta and planning and performance of the activities required to suggest and promote these products and services offered by ViaVeta customizing based on the likes, using habits and needs of the relevant persons under the personal data processing terms and purposes set out in the Clauses 8 and 9 of the Law.

5. Method and Legal Reason for Collecting Personal Data:

Personal data are collected from customers in electronic environment. Personal data collected for the aforementioned legal reasons can be processed and transferred for the purposes set out in the clauses of the Law and the text of the Policy on processing of personal data.

6. Rights of Customers As Personal Data Subject:
As per the Law on the Protection of Personal Data, data subjects have the right (i) to learn whether his/her personal data are processed or not, (ii) to request information if his/her personal data are processed,
(iii) to learn the purpose of his data processing and whether this data is used for intended purposes, (iv) know the third parties to whom his personal data is transferred at home or abroad, (v) to request the rectification of the incomplete or inaccurate data, if any, to request notification of the operations carried out to third parties to whom his personal data has been transferred, (vi) Although it has been processed in accordance with the Law and other relevant provisions, to request the deletion or destruction of the personal data if the reasons requiring processing have been disappeared and to notify the third parties to whom the personal data has been transferred,
(vii) to object to the processing, exclusively by automatic means, of his/her personal data, which leads to an unfavorable consequence for the data subject and (viii) to request compensation for the damage arising from the unlawful processing of his/her personal data.

The requests for the use of the rights in question shall be able to be conducted by personal data subjects by the means set out in the Policy on the Processing and Protection of Personal Data issued by Via Veta under the relevant Law at https://www.viaveta

ViaVeta will assess and conclude such requests within 30 days. Via Veta reserves the right to charge the fees shown in the tariff rates determined by the Personal Data Protection Board (if any) regarding the requests.

Last Update: 18/08/2019

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