PRIVACY AGREEMENT
Protecting the privacy of visitors to the https://www.sameasbefore.co/ website operated by Same as Before (“Same as Before” or “Company”) is one of the leading principles of our Company. This Privacy Policy, which has the characteristics of a personal data protection policy, destruction policy and disclosure text, regulates the rules regarding privacy that our Company abides by while carrying out its activities.
1.Data Controller and Contact Person
Your personal data is processed by Same as Before, acting as the data controller, in accordance with the requirements of current technology and headquartered at “Arap Cami Mah. Tersane Cad. Kürekçiler Kapısı Sok. No:47/30 Beyoğlu / İstanbul”, using the procedures specified below.
2. Purpose and Legal Reasons for Processing Personal Data
In cases where you become a member of our website and/or benefit from our services, in order to provide you with better service and fulfill our contractual obligations, we need some personal information such as your name, surname, e-mail address, telephone number, address information, gender, Same as Before card number, date of birth, the IP address you use to access our website, your current location information, your user name and password you use on our website, your computer and connection information such as the type and version of the internet browser you use, your operating system and information about the websites that allow you to access our website. In addition to this information, collective statistical data that does not include personal information such as the frequency and times of visiting our website are also processed for the purposes of analyzing and understanding visitor movements and preferences, carrying out the activities of the customer communication center, presenting our beauty suggestions, allowing you to benefit from job opportunities, providing information about Same as Before and herbal cosmetics, and receiving your ideas and suggestions.
For research purposes, we combine data about website visits with anonymous demographic information and may use this information in aggregate form to provide more useful content. We may perform profiling by combining site visit data with your personal information to provide personalized content on our website.
Our legal obligations requiring us to process your personal data arise from the European Union General Data Protection Regulation, the Personal Data Protection Law No. 6698, the Turkish Penal Code No. 5237 and other data protection legislation. In addition, we need the processing of the personal data of our members in order to fulfill our obligations within the scope of the performance of the contracts in the commercial relationship we have established within the framework of the said legislation and to provide the best service.
3. Personal Data Processing Principles
Your personal data is processed by the company in accordance with the following principles.
•Processing in Accordance with Law and Fairness
The Company acts in accordance with the principle of honesty in the processing of personal data. In this context, the Company does not process personal data for purposes other than those announced to the relevant persons.
•Ensuring that Personal Data is Accurate and Up-to-date when Necessary
Necessary measures are taken within technical possibilities to ensure that personal data processed by the Company is accurate and up-to-date, and destruction processes are organized. Control mechanisms have been established to correct and confirm the accuracy of the personal data of the relevant persons in case of errors.
•Processing for Specific, Clear and Legitimate Purposes
The data processing activities carried out by the Company are carried out only for legitimate purposes, in accordance with predetermined rules and the law. Before starting the data processing activity, the personal data processing purposes are determined and these purposes are clearly announced to the data owners when their personal data is obtained. If the Company’s personal data processing purposes change, this Privacy Policy is updated and efforts are made to announce the change to the data owners through different possible channels.
• Being Relevant, Limited and Proportionate to the Purpose for Which They Are Processed
Personal data is processed in a manner limited to the realization of previously determined purposes by the Company, and the processing of personal data not related to the realization of the purpose is avoided. Only the data necessary for the realization of the determined purposes is collected from the relevant persons.
•Storage for the period required by the relevant legislation or for the purpose for which they are processed.
The Company stores personal data only for the period specified in the relevant legislation or required for the purpose for which they are processed. In this context, if a period is stipulated for the storage of personal data in the relevant legislation, personal data is stored for a period limited to these periods, otherwise, personal data is stored for the period required for the processing purposes specified in this Privacy Policy.
4. Places to Which Processed Personal Data Are Transferred and Purpose of Transfer
Your personal data may be transferred to our authorized members of the website, our business partners, tax consultants, subcontractors and relevant official institutions within the scope of legal obligations in accordance with the relevant legal legislation and membership relationship. The purpose of processing personal data and the purpose of transferring the data are parallel.
Our Company may share the personal data it collects with institutions and organizations it cooperates with in order to carry out its activities, with persons and organizations at home and abroad from whom it receives data storage services in the cloud environment, with domestic and foreign organizations with which it has agreements regarding sending commercial electronic messages to its members, with cargo companies, with auxiliary tools within the scope of various marketing activities in order to provide better service to its members and to ensure member satisfaction, with various agencies and advertising companies at home and abroad, with survey companies, with other third parties at home and abroad, and with relevant business partners.
Our company cooperates with intermediary institutions for auxiliary tasks such as sending notifications, mail or e-mail, making credit card payments, etc. on our behalf. Your personal data may be shared with these institutions in accordance with the relevant legislation so that they can fulfill their duties, and we would like to state that the relevant institutions do not have the right to use this data for any other activity.
5. Method of Collection of Personal Data and Legal Reason
Your personal data is collected in written and electronic media by our Company through various methods, especially through intra-Company networks, through cookies, fully or partially through automatic methods, as part of the data recording system, in order to carry out our activities. Your personal data may also be processed and transferred in accordance with the basic principles, data processing conditions and exceptions stipulated by the relevant legislation, for the purposes specified in this Privacy Policy, Cookie Policy, Disclosure Text, all procedures and rules on the Site and the Membership Agreement.
6. Storage and Deletion of Personal Data
Data processing activities at the Company are separated on the basis of data categories, and if the legal and operational reason requiring the processing of each data group is eliminated, the data is deleted, destroyed or anonymized in a way that it cannot be associated with an identified or identifiable natural person in any way, even if the personal data is matched with other data.
Your personal data may be stored for the duration of the legal limitation periods in order to fulfill our legal or administrative obligations or to exercise our rights (for example, to be able to make a defense before the courts).
7.Automatic Decision Making
Automated decision making is defined as the ability to make decisions through technology without human intervention. Automatic decision making can be used in the following cases:
7.1. Profiling
Profiling means the automated processing of personal data for the purpose of evaluating certain personal characteristics about a person and, in particular, analysing or predicting certain characteristics about that person, particularly work performance, economic situation, health, personal, educational and/or professional preferences, interests, reliability, behaviour, location or movements.
Profiling techniques may be used in cases where personalized notifications or content are presented or sent to you. This means that your personal data may be collected by us in the various scenarios mentioned above and that such data may be used to analyze, evaluate or predict your personal preferences, interests, behavior and/or location.
Based on the analysis, notifications or content specifically tailored to your interests or needs may be presented or sent to you.
You have the right to object to the use of your personal data for “profiling” purposes and to limit the use of your data within the scope of this process through privacy options.
8. International Transfer of Your Personal Data
We reserve the right to send your personal data being processed to third parties and affiliates abroad, limited to our legitimate interests, by taking all necessary precautions.
Our company may transfer your personal data to foreign countries for legitimate and lawful data processing purposes if the European Commission issues an “adequacy decision” and the relevant country’s data protection authority accepts that the necessary protection can be provided. If there is no “adequacy decision” regarding the countries to which personal data is transferred and the Institution is of the opinion that the countries in question cannot provide the necessary protection, the personal data in question will be transferred to the relevant country, provided that your consent is obtained, after the data controllers in these countries undertake in writing to provide the necessary protection.
9.Cookies
Cookies are small text files that websites send to computers or other devices connected to the Internet in order to identify the browser on its own or to store certain information or settings in the browser. The browser may notify you when certain types of cookies are received or provide information on how to restrict or disable certain cookies. Without cookies, you may not be able to benefit from all the features of the website. Analysis services provided by third parties, such as Corometrics and Google Analytics, may be used on our website. Service providers that manage these services analyze the ways in which site visitors use the site using technologies such as cookies, internet provider records and internet cursors. The information obtained through these tools (including IP addresses) is shared with the relevant service providers who will use this information to evaluate the use of the websites. The content of pixel signals may be used by us when the website is visited or e-mails sent are opened.
For more detailed information about the use of cookies, you can review our Cookie Policy in the link below.
10. Measures Taken to Ensure the Security of Personal Data
In line with the importance our Company attaches to the protection of personal data and ensuring data security, in accordance with the relevant provisions of the Law and Regulation, by our Company;
– To prevent unlawful processing of personal data,
– To prevent unlawful access to personal data,
– To ensure the preservation of personal data
All necessary technical and administrative measures are taken to ensure an appropriate level of security.
11. Your Rights and Options
This section 11 summarises your rights under data protection legislation.
(a) Right to be Informed:
You have the right to receive clear, transparent and easily understandable information about how we use your personal data and your rights. For this reason, the information in this Privacy Policy is provided to you.
(b) Right of Access:
You have the right to obtain confirmation as to whether your data is being processed and, if so, to access your personal data together with additional information. Such additional information includes details on the purposes of processing, the categories of personal data concerned and the recipients of the personal data. Provided that the rights and freedoms of others are not affected, we will provide you with a copy of your personal data. The first copy will be provided free of charge, however, a reasonable fee may be charged for additional copies.
(c) Right to Request Correction:
You have the right to request correction of your personal data if it is incorrect or out of date, or to request completion if it is incomplete. While you have the right to request correction within the scope of the relevant legislation, we would like to point out that your personal data on our website can be easily corrected and updated by you via the settings tab on your profile.
(d) Right to be Erasured/Forgotten:
In some cases, you have the right to request the deletion of your personal data without reasonable delay. However, there are exceptions to the right to deletion. General exceptions include situations where processing is necessary, such as the exercise of the right to freedom of expression and information, the fulfilment of legal obligations, or the establishment, exercise or defence of legal claims.
(e) Right to Restriction of Processing:
In some cases, you have the right to restrict the processing of your personal data. These situations are: if you contest the accuracy of your personal data; if the processing is unlawful but you oppose deletion; if we no longer need your data to be processed but we need this data for the establishment, exercise or defense of our legal claims, but you object to the processing of your data in line with our legitimate interests, this is the stage at which we assess whether our legitimate interests will prevail over your rights and freedoms. If processing is restricted for these reasons, we reserve the right to retain your personal data. However, your personal data may only be processed if you consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person or in the event of an important public interest.
(f) Right to Object to Processing:
You have the right to object to the processing of your personal data based on your particular situation, limited to the cases where the processing is necessary for the performance of a task carried out in the public interest or the exercise of an official authority vested in the data controller, or where the processing is necessary to achieve legitimate interests by the data controller or a third party. In the event of such an objection; the processing of your personal data will be terminated if we cannot provide legitimate reasons that outweigh your interests, rights and freedoms, or if the processing is not required for the establishment, exercise or defense of legal claims.
You have the right to object to the processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, the processing of your personal data for these purposes will be terminated.
You have the right to object to the processing of your personal data for scientific, historical research or statistical data acquisition purposes, provided that the processing is not necessary for the performance of a task in the public interest, limited to these specific cases.
(g) Right to Data Portability:
You have the right to have your personal data transferred, transferred or copied from our database to another database. These rights are limited only to cases where the processing of personal data provided by you is carried out automatically and based on a contract or your consent.
(h) Right to Withdraw Consent:
Where the processing of your personal data is based on your consent, you have the right to withdraw this consent at any time. Such withdrawal will not prejudice the lawfulness of the processing in respect of data processed before the time of withdrawal.
(i) Right to File a Complaint with the Competent Authority:
If you believe that the processing of your personal data by us has led to a breach of data protection legislation, you have the right to lodge a complaint with the competent authority regarding the protection of personal data. We will always try to resolve your complaint at the first stage and before applying to the competent authority, you can always contact us using the contact information provided below.
To obtain more information regarding the Privacy Policy or to make any request regarding your rights specified above, you can fill out the application form in the link below and send it via e-mail to [*].
Our website may provide links to other websites for your information and convenience. These websites may be operated independently of our Company. The linked websites may have their own privacy statements and policies, and if you visit any linked website, it is strongly recommended that you review the privacy statements and policies of these sites. Our Company is not responsible in any way for these websites, the use of these websites, the content on these websites, or the privacy of these sites, unless these sites are controlled by our Company or the websites are owned by our Company.
This Privacy Policy issued by the Company is dated [*] and may be updated periodically without prior notice to reflect our personal information practices. In the event of any significant changes to our Privacy Policy, a prominent notice will be placed on our website to notify you. In addition, you can find the last update date of this Privacy Policy at the top of this Privacy Policy.
