Clarification Text

PROTECTION OF PERSONAL DATA

CLARIFICATION TEXT

Dear Visitors, Members and Customers,

Pursuant to the Law No. 6698 on the Protection of Personal Data (“KVKK”), it is aimed to inform you with this text within the scope of our obligation to inform you about your personal data that we process as ELECTRA IC AR-GE A.Ş. (“ELECTRA IC” / “Company”) as data controller.

In this text

1. Your visit to ELECTRA IC AR-GE A.Ş.'s website https://fpgapro.com (“Site”) or becoming a member of the Site, shopping through the Site or sending products on behalf of third parties,
2. Your acceptance of general and personalized campaign notifications through commercial communication channels,
3. If you participate in campaigns or other events organized by ELECTRA IC AR-GE A.Ş., it is aimed to enlighten you about our personal data processing processes.

As ELECTRA IC AR-GE A.Ş., we use methods such as cookies etc. on the Site in order to conduct statistical studies regarding the use of the Site, to make targeted advertisements/promotions and to ensure that you have an effective customer experience. For detailed information about cookies, you can access the cookie disclosure text at https://fpgapro.com/ privacy_policy_cookies_usage at any time.

Your Personal Data, Purposes of Processing and Legal Grounds

If you visit our Site;

1. If you visit our Site, we use cookies etc. on the Site in order to carry out statistical studies on your usage, to make targeted advertisements/promotions and to ensure that you have an effective customer experience, and we process your data regarding the mandatory cookies required for you to use the Site based on the legal reason that “data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject” and the “explicit consent” you will give regarding marketing/tracking, functionality and performance cookies. For detailed information about cookies, you can review the cookie disclosure text at https://fpgapro.com/ privacy_policy_cookies_usage.

If you are a Site Member;

1. We process your identity (name and surname), contact (e-mail address, phone number) data for the purpose of realizing your membership and recording your member information, ensuring that you can log in as a member, informing you about your membership, fulfilling the requirements of the membership agreement, based on the legal reason that “it is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract”,
2. Your identity (name, surname), contact (e-mail address, phone number) data in order to ensure that you can log in to the Site using member information without the need to enter all membership information again and to make purchases without the need to enter membership information again, based on the legal reason that “data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned”, and transaction security (log records information) in order to ensure transaction security, based on the legal reason that “data processing is mandatory for the establishment, use or protection of a right”,
3. As a member, if you save your address information to be used when you want to shop on the Site, in addition, based on the legal reason that “it is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract”,
4. By automatically assigning your transaction security (user ID information) data in order to identify your membership in our systems during membership, based on the legal reason that “data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned” and “it is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract”,
5. In order to provide you, as a member, with the service of viewing your order history, your customer transaction (shopping date, time, amount, shopping content) and financial (payment method and payment details) information based on the legal reason that “it is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract”,
6. To ensure that the information you provide during the membership process or through other communication channels at ELECTRA IC AR-GE A.Ş. In order to ensure the accuracy and timeliness of the information you will provide through other communication channels and/or to ensure that the information you will change later is also updated for the information you have provided regarding your membership, and to fulfill our obligation to keep your personal data up to date, identity (name, surname, gender), contact (e-mail address, phone number), identity (date of birth) if you prefer to share it optionally, transaction security (user ID information) data in order to identify your membership in the system when you become a member of the Site, based on the legal reason that “it is mandatory for the data controller to fulfill its legal obligation”,
7. Providing you with special opportunities and offers according to the Site / your membership and purchases, creating general or personalized campaigns, advantages, promotions, advertisements, organizing campaigns and other events, segmentation, profiling, reporting, marketing and analysis studies, making advertisements and marketing / communication activities (notifications on the Site, pop-up display, personalized offers, customization of user screens, surveys, etc.) of ELECTRA IC AR-GE A.Ş. on the Site or other third party environments, conducting studies to improve customer experience and strategic planning, analysis and business development studies regarding operational processes. Within the scope of conducting advertisements and marketing/communication activities (notifications on the Site, pop-up display, personalized offers, customization of user screens, surveys, etc.), studies to improve customer experience and strategic planning, analysis and business development studies regarding operational processes, identity (name, surname, gender), contact (e-mail address, mobile phone number, province, district), marketing (approaches to in-site notifications / surveys / offers / campaigns, habits, favorites, likes, behaviors, preferences, search movements, segments, past purchases, cookie records, cookie and advertisement identifier / ID information, communication preferences, survey answers, demographic information), transaction security (device ID, usage period, version information, brand, model, technical specifications and operating system information of the device used, operator information used), finance (payment methods / channels and preferences, bank information where the payment is made), customer transaction (shopping amount) and optionally, if you share your identity (date of birth) data, we process your data based on the legal reason of “explicit consent”.

If you make purchases through online Channels (with or without being a Member);

1. In case you shop on the Site as a member or through the Site without being a member, to ensure that the shopping transaction is carried out and the e-invoice / e-archive invoice related to your shopping is issued and sent to you, within the scope of fulfilling the requirements of the distance sales contract, preparing orders, packaging, preparing delivery notes, shipping, updating delivery information, ensuring that your order can be delivered to you, distinguishing the records of you that we have created in our system from the records of other customers, providing after-sales support services (such as exchange, return, product inspection) in order to provide identification (name, surname, signature), contact (e-mail address, phone number, address), customer transaction (information about the product you have purchased, shopping date, time, amount, shopping content), transaction security (log records and IP address) data regarding your shopping transaction, as well as financial (bank information and IBAN number) information if necessary for return transactions, based on the legal reasons that “it is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract” and “it is mandatory for the data controller to fulfill its legal obligation”,
2. In the event that you shop on the Site as a member or without being a member on the Site, if you choose to participate in the satisfaction survey sent regarding the product you have purchased, your contact (e-mail address), customer transaction (information about the product you have purchased, shopping date, time, amount, shopping content) and points data regarding the product you have purchased in order to measure your satisfaction, based on the legal reason that “data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject”,
3. In the event that you shop on the Site as a member or without being a member on the Site, if you choose to participate in the satisfaction survey sent regarding the product you have purchased, your contact (e-mail address), customer transaction (information about the product you have purchased, shopping date, time, amount, shopping content) and points data regarding the product you have purchased in order to measure your satisfaction, based on the legal reason that “data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject”,
4. If the purchase is made by credit/debit card, in order to ensure that the payment can be collected, your financial (credit/debit card information (first 4 and last 4 digits, expiration date, points, bank to which the card belongs and card type information)) data and transaction security (IP address information) in order to ensure transaction security, based on the legal reason that “it is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract”,
5. If the purchase is made by Wire Transfer / EFT method, your identity (name and surname), finance (bank information where the transaction is made), customer transaction (information on the receipt) data, if shared, based on the legal reason that “it is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract”,
6. If you inquire about your order through the order inquiry screen, your order information consisting of customer transaction data (such as order details, date, time, quantity, order content, product information, payment method, order note, and reference number for the order), as well as your communication data (email address) and customer transaction data (order number), will be processed based on the legal grounds of “necessity of processing personal data belonging to the parties of a contract, provided that it is directly related to the establishment or performance of the contract.”
7. If you make a purchase through websites selling ELECTRA IC AR-GE A.Ş. products, your identity data (name and surname), communication data (email address, delivery, and billing address), and customer transaction data (order details including product information, price, order date, and order content) will be processed for the purposes of issuing and sending e-invoices/e-archive invoices, fulfilling the requirements of the distance sales contract, preparing the order, packaging, preparing the delivery note, shipping, updating delivery information, and ensuring the delivery of your order to you. These processes are based on the legal grounds of “necessity of processing personal data belonging to the parties of a contract, provided that it is directly related to the establishment or performance of the contract,” and “necessity for the data controller to fulfill its legal obligations.”
8. If you return products purchased via bank transfer under post-sales support, your identity data (name and surname), financial data (bank name, IBAN number), and customer transaction data (purchase date, time, amount, and content) will be processed for the purpose of completing the return process. These processes are based on the legal grounds of “necessity of processing personal data belonging to the parties of a contract, provided that it is directly related to the establishment or performance of the contract,” and “necessity for the data controller to fulfill its legal obligations.” If you request the return process to be carried out without re-entering all information, this data may also be recorded based on the legal grounds of “necessity of processing data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.”
9. During your visit to and use of the site, we process your usage data to identify and resolve technical/software errors or deficiencies encountered on the site, based on the legal grounds of “necessity of data processing for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.”

In cases where the purchased product is sent to a third party:

1. If you send products to third parties, we process the recipient's address and identity data (name and surname) within the address, as well as their communication data (email address), to ensure the delivery of the order and to provide post-sales support services (such as exchange, returns, and product inspection). This processing is based on the legal grounds of “necessity of processing personal data belonging to the parties of a contract, provided that it is directly related to the establishment or performance of the contract.” In such cases, the responsibility for informing these individuals and obtaining their consent, where necessary, lies with you as the person sharing this information.
2. If third parties send products to you, we process your communication data (address) and identity data (name and surname) within the address, as well as your email address, to ensure the delivery of the order and to provide post-sales support services (such as exchange, returns, and product inspection). This processing is based on the legal grounds of “necessity of processing personal data belonging to the parties of a contract, provided that it is directly related to the establishment or performance of the contract,” and “necessity of data processing for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.”

If you grant commercial communication permission to ELECTRA IC AR-GE A.Ş. through any channel:

1. If you provide commercial communication permission/explicit consent to ELECTRA IC AR-GE A.Ş. through any channel, your identity (name and surname), contact information (phone number, email address), transaction security (user ID, log records), and commercial communication consent records will be processed based on the legal grounds of "explicit consent" for the purposes of carrying out general or personalized campaigns, offers, product and service promotions, surveys related to our services, and customer satisfaction practices; providing information about promotions, advertisements, and marketing activities; and sending invitations related to campaigns, events, or other activities through the channels you choose (SMS, email, etc.). If you provide this consent in-store, your signature will also be processed.

You may, at any time and without any justification: (i) stop receiving the relevant commercial communication by performing the opt-out process indicated in the commercial electronic messages we send; and/or (ii) withdraw your explicit consent regarding the Site/membership and terminate the associated membership, thereby halting personal data processing activities based on explicit consent.

Legal Processes and Internal Activities

1. To ensure the safety of you, ELECTRA IC AR-GE A.Ş., its employees, and other third parties against any potential acts, crimes, or behaviors that violate regulations; to fulfill our obligations arising from legislation; to comply with our legal responsibilities towards authorized and competent private or public institutions and organizations; to exercise any legal rights such as lawsuits, responses, and objections in the event of disputes before official authorities like courts, enforcement offices, or arbitration boards; to manage negotiation and resolution processes related to disputes; to provide the necessary information if you request it or submit an application within the scope of your legal rights; to prevent unauthorized or unlawful use of contracts and regulations; to detect suspicious transactions and illegal use; to perform cancellation processes; to conduct internal audit and control, reporting, testing, and development activities; to carry out improvements aimed at enhancing customer experience; and to undertake strategic planning, analysis, and business development activities related to operational processes, we process:

• Your identity information (name, surname, gender),
• If optionally shared, your identity information (date of birth),
• Identity information (signature and national ID number) if included due to legal processes or in documents sent by official authorities,
• Contact information (phone number, email address, address),
• Legal transaction information (your requests and complaints),
• Your shopping details, product information related to purchased products, order notes, and invoices,
• Financial information (the first 6 and last 4 digits of your credit/bank card, payment amount, the bank associated with the card, reference number),
• Legal transaction details and correspondence or file information related to dispute processes,

based on the legal grounds of "necessity of data processing for the establishment, exercise, or protection of a right" and "necessity of data processing for the data controller to fulfill its legal obligations," to meet our evidentiary obligations under the law, including approved clarification and consent texts and related records.

1. For Online Visitors, we process:

• Cookie records (browsing information, device information (ID), and traffic data),
• Transaction security data (log records, IP address) related to activities on the Site,

to ensure IT security, prevent malicious use, conduct activities in compliance with regulations, and fulfill our other legal obligations to authorized and competent public institutions and organizations, based on the legal grounds of "necessity of data processing for the data controller to fulfill its legal obligations" and "explicit provision by law."

Our Method of Collecting Your Personal Data

We collect your personal data through the following methods:

• Information provided during your purchases on the Site or through websites selling ELECTRA IC AR-GE A.Ş. products, or during your membership registration on the Site, which are recorded in our systems by ELECTRA IC AR-GE A.Ş., its business partners, or suppliers.
• Recording all transactions such as purchases, collections, deliveries, operations, survey responses, registrations, behavioral activities, and actions made through the Site into our systems.
• Recording the requests and complaints you convey to us during interactions through our communication channels or your calls with our call center.
• Automatically recording information/documents related to you that are received from official institutions, organizations, and judicial/administrative authorities.
• Recording documentation related to your return/examination processes through non-automated methods.

Transfer of Your Personal Data

As ELECTRA IC AR-GE A.Ş., we transfer your personal data to third parties only for the purposes specified in this text and in accordance with Articles 8 and 9 of the Personal Data Protection Law (KVKK). Within this scope:

1. To business partners, suppliers, and service providers within Turkey; for purposes such as delivering the products you purchase related to your membership, orders, or shopping, providing logistics and after-sales support services, resolving your requests and complaints, communicating with you when necessary, and receiving IT, marketing/advertising/analysis activities, or consultancy services requiring expertise. These include electronic communication service providers, call centers, entities collecting personal data through devices, marketing/advertising/analysis service providers, database and server service providers, infrastructure maintenance and support providers, software licensing service providers, legal and financial consultancy providers, e-invoice/e-archive invoice service providers, independent audit service providers, delivery/cargo/courier, archiving, and storage service providers.
2. To authorized private or public institutions and organizations, judicial authorities, and official bodies; to fulfill our obligations to provide information and documents and to meet other related requirements, to exercise legal rights such as filing lawsuits or responses, as per the laws and secondary legislation listed below:
3. To courts, enforcement, and bankruptcy offices under the Code of Civil Procedure (Law No. 6100),
4. To law enforcement agencies, prosecutors, and courts under the Code of Criminal Procedure (Law No. 5271),
5. To administrative courts under the Administrative Procedure Law (Law No. 2577),
6. To the Personal Data Protection Authority under the Personal Data Protection Law (Law No. 6698),
7. To the Message Management System Inc. and the Ministry of Commerce of Turkey under the Regulation of Electronic Commerce Law (Law No. 6563),
8. To the Ministry of Commerce of Turkey, Consumer Courts, and Consumer Arbitration Committees under the Consumer Protection Law (Law No. 6502).
9. Additionally, we may transfer your personal data to other relevant institutions, organizations, and public authorities upon request to fulfill obligations arising from other legislation.
10. To suppliers and payment institutions; for tracking suspicious transactions, detecting them, and preventing illegal activities, we transfer data when necessary to suppliers providing consultancy services and payment institutions related to the transaction.
11. To suppliers, for activities aimed at increasing Site traffic.
12. To banks and electronic payment service providers, if you make your payment via credit/bank card, your credit/bank card information is transferred to the relevant bank, electronic payment institution, or third-party service provider without being recorded by ELECTRA IC AR-GE A.Ş.
13. International Transfer: Additionally, with your explicit consent provided through the consent form, we transfer your personal data abroad in accordance with Article 9 of the Personal Data Protection Law (KVKK) for the purposes of obtaining product and service support in areas such as information technology, marketing/analysis/segmentation/advertising activities, or consultancy requiring expertise. This includes ELECTRA IC AR-GE A.Ş.'s service providers and business partners located abroad (e.g., social media, software development and support services, advertising, digital marketing and analytics services, product support providers, location data collection services through devices, hosting, maintenance and development services, online survey service providers). Additionally, due to the servers of our suppliers being located abroad, we transfer identity, contact, financial, transaction security, marketing, customer transaction, and legal transaction data, as well as visual and audio recordings, abroad to suppliers' systems. This transfer is conducted in accordance with the conditions set forth in Article 9 of KVKK.

Your Rights under KVKK

Regarding your personal data processed by ELECTRA IC AR-GE A.Ş., you can submit your requests within the scope of Article 11 of the Personal Data Protection Law (KVKK) in writing or via registered electronic mail (KEP), secure electronic signature, mobile signature, or by using the electronic mail address previously provided to ELECTRA IC AR-GE A.Ş. and registered in our system. You can always send your requests to the following addresses:

Data Controller: ELECTRA IC AR-GE A.Ş.

Email: info@electraic.com

KEP Address: electra.ic@hs04.kep.tr

Address: Sanayi Mah. Teknopark Bulvarı, No:1/9A 203 34906 - Pendik / Istanbul, TURKEY