Last Updated: June 2024

At Vavien Digital, we take your privacy seriously. We understand the importance of protecting your personal information and are committed to ensuring your trust in our services.

This Privacy Notice aims to inform you of how we collect and use the personal data of our prospects, customers, business partners and their respective employees or consultants (collectively, “you”) in accordance with the Turkish Personal Data Protection Law (“PDPL”) and the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and to explain how you can exercise your rights under these laws.

1. Data Controller Information

Name: Vavien Dijital Bilgi Teknolojileri Reklamcilik Ve Eğitim Ticaret Limited Şirketi

Postal address: Cevat Paşa Mah. Ordu Sokak No:21/1 D:2 Merkez Çanakkale, Türkiye

E-mail: [email protected]

2. Collection of Your Personal Data

We collect personal data directly from you when you:

• visit our website (by using cookies; for more detail, please see our Cookie Policy);
• visit our offices;
• contact us via our email, contact form on our website, phone or our other channels;
• use our services;
• attend our meetings or events; or
• interact with us by other means.

We may also collect your personal data from other sources, such as our customers and business partners.

3. Personal Data We Process, Purpose of Processing and Legal Bases

We process the personal data of our customers as mentioned below:

Personal Data	Purpose of Processing	Legal Bases
Name, surname, e-mail address, phone number, job title, financial information	to provide our Services to you	– Processing is necessary for the performance of our contract
Name, surname, e-mail address, phone number, job title	to introduce you to our other customers, business partners and third parties based on your needs	– Obtaining your consent
Name, surname, e-mail address, request and complaint information	to fulfil your requests and complaints submitted via e-mail or contact form	– Processing is necessary for the performance of our contract – Processing is necessary for the purposes of our legitimate interests
Name, surname, job title, your comments about Vavien Digital	to publish your comments about our Company on our website and social media platforms for marketing purposes	– Obtaining your consent
Name, surname, job title, your comments about Vavien Digital, visual and audio information, including your photographs and videos	to take promotional videos and photographs of you for marketing purposes and post them on our website and social media platforms	– Obtaining your consent
Name, surname, job title	to share our references for our service with prospects upon their request	– Obtaining your consent
Name, surname, e-mail address, phone number.	to send you marketing communication about Vavien Digital	– Obtaining your consent – Processing is necessary for the purposes of our legitimate interests

We process the personal data of our prospects as mentioned below:

Personal Data	Purpose of Processing	Legal Bases
Name, surname, e-mail address, phone number, job title	to contact you and introduce our Company and our services, upon the reference of our customer	– Processing is necessary for the purposes of our legitimate interests
Name, surname, e-mail address, phone number, job title	to promote our services to you when you present your business card or contact us by email, phone or contact form.	– Processing is necessary for the purposes of our legitimate interests

 

We process the personal data of our business partners as mentioned below:

Personal Data	Purpose of Processing	Legal Bases
Name, surname, e-mail address, phone number, job title	to share your information with our customers based on our customers’ needs	– Processing is necessary for the performance of our contract – Processing is necessary for the purposes of our legitimate interests

              

4. Disclosure of Your Personal Data

We may disclose your personal data to:

• our suppliers and information technology service providers for the purposes specified in Section 3, including performing our contractual obligations, maintaining the security of our operation;
• our business partners and consultants to provide our services and carry out our business activities;
• our legal advisers to protect or defend our rights or property in the event of a dispute or legal claim;
• the government and regulatory authorities and other organisations to meet legal and regulatory requirements;
• banks and other service providers to carry out financial and accounting matters.

To comply with the GDPR, we ensure that our suppliers and service providers, whether located outside the EEA or not, take appropriate technical and organisational security measures in accordance with applicable data protection laws and use them solely for the purposes specified by us.

5. Retention of Your Personal Data

We take all the necessary measures to ensure that your data is treated securely in accordance with this Privacy Policy, and no transfer of your personal data will take place to an organisation or a country unless stated in this Privacy Policy, and there are adequate controls in place including the security of your data and other personal information.

We will retain your personal data only for as long as it is necessary for the purposes set out in this Privacy Policy. If we no longer have a legal basis or a purpose for processing your personal data, we delete such personal data.

6. Right to Withdraw Consent

If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. To withdraw your consent, please contact us at [email protected].

Once we receive notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

7. Children

Our website and services are not directed to individuals under the age of 16. We do not knowingly collect personal data from such individuals without parental consent and require our customers to fully comply with applicable law in the data collected from children under the age of 16. If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us by using the information in the “Contact Us” section below, and we will take steps to delete such Personal Data from our systems.

8. Your Rights

Under Article 11 of the KVKK, you are entitled to:

• learn whether your personal data is processed or not;
• demand information as to whether your personal data have been processed;
• learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose;
• know the third parties to whom your personal data are transferred in-country or abroad;
• request the rectification of the incomplete or inaccurate data, if any;
• request the erasure or destruction of your personal data under the conditions referred to in Article 7 of the KVKK;
• request reporting of operations as the rectification of the incomplete or inaccurate data or the erasure or destruction to the third parties to whom your personal data have been transferred;
• object to the occurrence of a result against you by analysing the data processed solely through automated systems;
• claim compensation for the damage arising from the unlawful processing of your personal data.

If you are from the European Economic Area or in certain countries, you are also entitled (with some exceptions and restrictions) to:

• Access: You have the right to request information about how we process your personal data and to obtain a copy of that personal data.
• Rectification: You have the right to request the rectification of inaccurate personal data about you and for any incomplete personal information about you to be completed.
• Objection: You have the right to object to the processing of your personal information, which is based on our legitimate interests.
• Deletion: You can delete your account by using the corresponding functionality directly on the service.
• Automated decision-making: You have the right to object to a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.
• Restriction: You have the right to ask us to restrict our processing of your personal data so that we no longer process that personal data until the restriction is lifted.
• Portability: You have the right to receive your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and to have that personal data transmitted to another organisation in certain circumstances.
• Complaint: You have a right to lodge a complaint with the authorised data protection authority if you have concerns about how we process your personal data. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

You may, at any time, exercise any of the above rights by contacting us via [email protected] together with proof of your identity, i.e. a copy of your ID card, passport, or any other valid identifying document.

9. Links to Other Sites

Our website may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third-party site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for any content, privacy policies or practices of third-party sites or services.

10. Changes to This Privacy Policy

We reserve the right to update and change this Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or push notification. We also recommend you check back frequently to see any updates or changes to our Policy.

11. Contact Us

If you have any questions about this Privacy Policy, please contact us by email: [email protected]