Personal Data Processing and Protection Policy
PERSONAL DATA PROTECTION AND PROCESSING POLICY
ENTRY
- This Personal Data Processing and Protection Policy (“Policy”) refers to the administrative structure, processes and procedures to be adopted and internalized by Michel Sağ Mücevherat Sanayi ve Ticaret Limited Şirketi (Company) for the protection and lawful processing of personal data.
- This Policy has been prepared for the purpose of processing personal data of the Company's employees, employee candidates, customers, potential customers, suppliers, business partners and all other persons in accordance with the law, complying with the Law and all relevant legal requirements, and periodically auditing the Company's policies and internal procedures to ensure compliance with the rules of integrity and the law.
- With this Policy, the Company aims to ensure compliance with the Law by creating the necessary administrative structure, processes and procedures within the scope of the Law and the relevant legislation, taking the necessary technical and administrative measures for the security and protection of Personal Data, internalizing the processing and retention of Personal Data in compliance with the Law, creating the necessary awareness among employees and all business partners.
ARTICLE 1 - DEFINITIONS
- The terms used in this Policy shall have the meanings set out below.
Company / Our Company |
: |
Michel Sağ Mücevherat Sanayi ve Ticaret Limited Şirketi |
Personal Data |
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Any information relating to an identified or identifiable natural person. |
Sensitive Personal Data |
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Race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing, association/foundation or union membership, health, sexual life, criminal conviction and security measures and genetic data. |
Processing of Personal Data |
: |
Any operation performed on Personal Data such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of Personal Data by fully or partially automatic or non-automatic means provided that it is part of any data recording system. |
Personal Data Owner/Related Person: |
: |
Company Stakeholders, Company Business Partners, Company Officials, Employee Candidates, Employees, Employees of the Institutions with which we have contractual relations, Visitors, Company and Group Company Customers, Potential Customers, Third Parties and persons whose personal data are processed by the company. |
Data Recording System |
: |
Refers to the registration request where personal data is structured and processed according to certain criteria. |
Data Controller |
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The natural or legal person who determining the purposes and methods of processing personal data and is responsible for the establishment and management of the data recording system. |
Data Processor |
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A natural or legal person who processes personal data on behalf of the data controller based on the authorization granted by the data controller. |
Explicit Consent: |
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Consent regarding a specific subject, based on information and expressed with free will. |
Anonymization: |
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Process of making the data previously associated with a person impossible to be associated with an identified or identifiable natural person under any circumstances, even by matching with other data. |
Law |
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Law No. 6698 on the Protection of Personal Data. |
Board of PPD. |
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Board of Protection of Personal Data |
ARTICLE 2 - PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA
In this Policy, Personal Data is processed by the Company in accordance with the procedures and principles stipulated in the Law and this Policy. The Company acts in accordance with the following principles when processing Personal Data:
Your Personal Data is processed in accordance with the law and the rule of honesty.
The purpose of this principle is not to prevent the processing of Personal Data, but to ensure that the processing of Personal Data is carried out in accordance with the rules of honesty and the law and in a manner that does not adversely affect the rights of the person concerned.
The Data Subject must be told who the Data Controller is, for what purpose the data will be processed by the Company, the identity of the persons to whom the data may be disclosed or transferred and the rights of this data subject.
In order for Personal Data to be processed in accordance with the law, certain conditions must be met.
Personal data will be processed in the presence of one of the following conditions: Except for the processing of Personal Data with the explicit consent of the Data Owner, only if the processing is clearly stipulated by law; mandatory for the protection of the life or physical integrity of the person who is unable to disclose his/her consent due to actual impossibility or whose consent is not legally valid; mandatory of processing of the data controller to fulfill its legal obligation; making public of the processed data by the data subject himself/herself; mandatory of processing for the establishment, exercise or protection of a right; mandotory of processing for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject; provided that it does not harm the fundamental rights and freedoms of the person concerned, in the presence of one of the cases where processing is mandatory for the legitimate interests of the data controller. However, the Data Subjects of the data processed within the scope of the exceptions listed herein as limited regarding the processing of Personal Data shall be informed in a manner to cover the Disclosure Obligation stipulated pursuant to Article 16 of the Law. With the said information, it will be informed that the Personal Data is processed by the Company in accordance with this Policy and it will be confirmed that the data is processed in accordance with the Law, relevant legislation and this Policy.
Your Personal Data is processed for specific, explicit and legitimate purposes.
- Personal Data may be processed within the framework of the specific purposes notified to the Data Subject when the data is first collected or for any other purpose specifically permitted by the Law. This means that Personal Data cannot be collected for a specific purpose and then used for another purpose.
Your Personal Data is processed in a limited, measured and necessary for the purpose.
- Personal data should only be collected to the extent required by the specific purpose notified to the Data Subject. Any data that is not necessary for this purpose should not be collected.
Your Personal Data is accurate and up-to-date when necessary.
- Opportunities should be provided for Data Subjects to update their data and Data Subjects should be informed about these opportunities. During the collection of personal data, Data Subjects should be informed about the update processes. The timeliness of the data should be confirmed by the employees at certain intervals and all data that are outdated or not useful to be processed in an up-to-date manner should be deleted or anonymized if there is no possibility of updating.
- Personal Data should not be kept for longer than the period stipulated in accordance with the relevant legislation or as required by the purpose. In other words, when the processing of personal data is no longer necessary or no longer needed, personal data should be destroyed or deleted from the Company systems or anonymized. Personal Data should not be stored and archived with the assumption that it may need to be used in the future.
- Each business unit must assess the time required for processing different types of Personal Data and determine in writing the required period of time.
ARTICLE 3 - CONDITIONS FOR PROCESSING PERSONAL DATA
The Company may process Personal Data by obtaining their explicit consent after informing the personal data owners within the scope of fulfilling the disclosure obligation. However, in the presence of one of the following conditions, Personal Data may be processed without the explicit consent of the data owner.
- The Company may process the Personal Data of Personal Data Owners in cases expressly stipulated in the laws even without explicit consent. For example; pursuant to Article 230 of the Tax Procedure Law, the explicit consent of the relevant person will not be sought in order to include the name of the relevant person on the invoice.
- Personal Data may be processed without explicit consent in order to protect the life or physical integrity of persons who are unable to disclose their consent due to actual impossibility or whose consent cannot be recognized as valid, or of another person.
- Provided that it is directly related to the establishment or performance of a contract by the Company, Personal Data of the parties to the contract may be processed. For example, the account number information of the creditor party may be obtained for the payment of the money in accordance with a contract.
- The Company may process the Personal Data of Personal Data Owners if it is mandatory in order to fulfill its legal obligations as a data controller.
- The Company may process the Personal Data of Personal Data Owners made public by the Company itself, in other words, the Personal Data disclosed to the public in any way, since the legal benefit to be protected has disappeared.
- The Company may process the Personal Data of Personal Data Owners without seeking explicit consent in cases where data processing is mandatory for the exercise or protection of a legitimate right.
- Provided that it does not harm the fundamental rights and freedoms of Personal Data Owners protected under the Law and Policy, the Company may process the Personal Data of Personal Data Owners in cases where the processing of Personal Data is mandatory for the provision of legitimate interests. The Company shows the necessary sensitivity to comply with the basic principles regarding the protection of Personal Data and to observe the balance of interests of Personal Data Owners.
ARTICLE 4 - PROCESSING CONDITIONS OF SPECIAL CATEGORIES OF PERSONAL DATA
Pursuant to Article 6 of the Law, the Company may process sensitive personal data by obtaining the explicit consent of the personal data owner as a rule. However, in the presence of one of the following conditions, Special Categories of Personal Data may be processed without the explicit consent of the data subject.
Sensitive Personal Data other than the health and sexual life of the personal data owner may be processed in cases stipulated by law, and Sensitive Personal Data relating to the health and sexual life of the personal data owner may only be processed by persons or authorized institutions and organizations under the obligation of confidentiality for the protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing.
Within the Company, Special Categories of Personal Data are processed only for the fulfillment of legal and administrative/judicial authority requirements and provided that they are directly related to the operation of the Company and their access is limited and secure at the highest level. Provided that all necessary administrative and technical measures, including the measures specified by the Personal Data Protection Board, are taken to demonstrate full compliance with the Law, such data may be processed without seeking the consent of the Data Owner in the case of (i) in the event that the processing is expressly stipulated in the laws regardşng the data other than special categories of personal data other than health and sexual life, and (ii) for data relating to health and sexual life, only for the protection of public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing, in the event that it is processed by persons or authorized institutions and organizations under the obligation of confidentiality.
However, even if these exception conditions occur, the Company obtains the explicit consent of the Data Owner by fulfilling the requirements of the obligation to inform the Data Owner regarding the processing of Special Categories of Personal Data. In the event that the exceptions are not in question or if there is any doubt about their applicability, the Special Categories of Personal Data obtained without explicit consent are immediately destroyed. In such cases, the Company's PDP Committee unit is immediately informed to coordinate the necessary measures and, if applicable, to notify the relevant Data Subject and the Board as soon as possible.
Sensitive Personal Data of employees, including health data, may also be processed by the Human Resources business unit in accordance with the Company's Policy on the Protection of Sensitive Personal Data to the extent required by the legislation. In addition, some health data may be processed by workplace physicians and occupational safety experts. Health data processed by Human Resources and workplace physicians are processed in accordance with the provisions of the Regulation on Personal Health Data and are not shared with any business unit, including the relevant units. Access to such data is limited at the highest level. Sharing with third parties for archiving purposes regarding this data group is protected by encryption systems and no person other than the relevant units has access to health data. The data processed by the occupational physician is not shared with any third party, even for archiving purposes. Pursuant to the legal legislation, the health data related to the workplace physician is transferred to the Central Health Data System of the Ministry of Health within the framework of the standards to be determined by the Ministry of Health in accordance with the Regulation on Personal Health Data.
ARTICLE 5 - DISCLOSURE OBLIGATION
During the acquisition of Personal Data, the Company is obliged to inform the natural persons whose data will be processed in accordance with the legislation. The scope of this information obligation is as follows:
- Identity of the data controller and its representative, if any,
- The purpose for which Personal Data will be processed,
- To whom and for what purpose the processed Personal Data may be transferred,
- Management and legal grounds for collecting Personal Data,
- The rights of the Data Subject specified under heading (7).
The Company shall provide the necessary information to be processed in its systems and shall obtain informed consent from the Data Subjects regarding data processing in order to prove that the disclosure obligation has been fulfilled.
Personal Data may be collected verbally, in writing or electronically by automatic or non-automatic means through all sales channels, stores, branches, websites, e-mail address, social media channels and customer service call center line and all other similar channels, including electronic commerce and sales stores.
Obtaining Personal Data in Written Form:
During the acquisition of Personal Data in writing, the Disclosure Obligation regarding the processing of data will be fulfilled, provided that reference is made to this Policy and the relevant forms and information are used. In addition, all forms and contracts, including the Authorized Contact Forms to be received from the persons with whom a customer relationship is established, include the explicit consent of the Data Subject regarding the processing of Personal Data. In customer relations, new forms, documents and information are used to certify compliance with the Law, and all relevant employees have been trained to provide sufficiently detailed information and references to the natural person in this regard.
Obtaining Personal Data Verbally:
Information on the obligation to inform regarding the processing of Personal Data is provided when obtaining new data that does not already exist and when obtaining data through any communication method, in any way related to existing customers already processed in accordance with the forms already received. During verbal data acquisition, it is reminded that the interview is recorded, provided that prior information is given, and it is confirmed that consent is given that Personal Data will be processed in accordance with this Policy and existing forms, if any.
Obtaining Personal Data in Electronic Environment:
All contracts and documents / link addresses / web pages, including distance sales contracts that require the acquisition and processing of Personal Data, including data obtained through electronic commerce channels and other internet channels of the Company, including this Policy, meet the legal requirements regarding the explicit consent and disclosure obligation regarding the processing of Personal Data. This Policy is available on the Company's website. In order to obtain data at each connection address that may require data acquisition, the Company uses systems that certify that the disclosure obligation has been fulfilled by the Company and/or that explicit consent approval has been obtained.
ARTICLE 6 - MANNER OF COLLECTION OF PERSONAL DATA
The personal data you share can be processed and collected as follows:
- Information such as name, surname, address, telephone, business or private e-mail address, preferences on the pages logged in using the username and password, IP records of the transactions performed, cookie data collected by the browser, data containing browsing time and details, location data through forms on the www.missluciajewelry.com website and mobile applications;
- In a physical or virtual environment, face-to-face or distance, verbal or written or electronic media for purposes such as establishing a commercial relationship with the Company, making job applications, making offers, business cards, CVs, making offers and other means;
- In addition, data obtained indirectly through different channels, from (micro) websites and social media used for websites, blogs, contests, surveys, surveys, games, campaigns and similar purposes, e-bulletin reading or clicking movements, data provided by public databases, profiles and data open to sharing from social networking sites such as social media platforms (Facebook, Twitter, Google, Instagram, Snapchat, etc.)
ARTICLE 7 - PROCESSED PERSONAL DATA
Employee Candidate Data
Identity Data: Data such as name-surname, Turkish ID number, date of birth
Contact Data: Cell phone number, home address, personal e-mail address, etc.
Personnel Data: Curriculum vitae information, salary information,
Professional Experience Data: Diploma information, Courses attended, On-the-job training information, Certificates, Transcript information
Personal data collected regarding employee candidates, in accordance with the Employee Candidate Clarification Text, is processed within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698, provided that data processing is mandatory for our legitimate interests, provided that it is related to the establishment of the contract for the purposes of conducting job application processes and developing the Company's recruitment policies, provided that it is related to the establishment of the contract, provided that it does not harm the fundamental rights and freedoms of the person concerned. Data relating to the prospective employee is deleted after a reasonable period of time if the employee is not hired. In case of employment, these data continue to be kept in the personal file of the person.
Employee Data
Identity Data: Data such as name-surname, Turkish ID number, date of birth
Contact Data: Cell phone number, home address, personal e-mail address, etc.
Personnel Data: Curriculum vitae information, salary information,
Professional Experience Data: Diploma information, Courses attended, On-the-job training information, Certificates, Transcript information
Finance Data: Bank account information, IBAN information
Audiovisual Recordings: Photographs and video recordings
Family Members and Relatives Data: Contact information of family members and relatives
Location Data: Company vehicle GPS information,
Transaction Security Data: IP address information, Website login and logout information, Password and password information
Physical Space Security: Entry and exit records, camera records
Legal Action Data: Information on litigation/execution processes
Health Data: Documents such as health report, work accident report
Criminal Conviction Data: Criminal Record
Data relating to the Employee is processed during the employment relationship and until the end of the periods stipulated in the legislation following the termination of the employment relationship, in line with the data processing purposes explained in detail in the Employee Clarification Text based on the legal reasons that are clearly stipulated in the laws, the establishment or performance of a contract, the fulfillment of our legal obligations, the establishment, use or protection of a right, and legitimate interest.
Customer and Potential Customer Dat
Identity Data: First and last name, date of birth, gender, marital status
Contact Data: Cell phone number, address, e-mail address;
Finance Data: Bank details, credit card details
Legal Action Data: Information on litigation/execution processes
Physical Space Security: Camera recordings
Customer Transaction Information: Requests you send us, order information
Marketing Data: Shopping history information, Survey, Cookie records, Information obtained through campaigns
Audiovisual Recordings: Photographs and video recordings
Customers are processed without being subject to explicit consent processes based on the legal reasons 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” and “it is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject”. On the other hand, if the data subject gives explicit consent, the data shared can also be processed within the framework of the Company's advertising, promotion and marketing activities.
Service Providers and Business Partners Data
Identity Data: Full Name
Contact Data: Cell phone number, address, e-mail address;
Personnel Data: Curriculum Vitae
Professional Experience Data: Diploma information, Courses attended, On-the-job training information,
Audiovisual Recordings: Photographs and video recordings
Physical Space Security: Camera recordings
Criminal Conviction Data: Criminal Record
Health Data: Health Report
Finance Data: Bank details, credit card details
The Company may process the data of company officials and employees of service providers, suppliers and business partners 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”.
ARTICLE 8 - PURPOSES OF PROCESSING PERSONAL DATA
The Company processes personal data for various purposes, limited to the purposes and conditions within the personal data processing conditions specified in the legislation; but not limited to those listed here
- Execution of Emergency Management Processes
- Execution of Information Security Processes
- Execution of Employee Candidate / Intern / Student Selection and Placement Processes
- Execution of Employee Candidate Application Processes
- Execution of Employee Satisfaction and Loyalty Processes
- Fulfillment of Employment Contract and Regulatory Obligations for Employees
- Execution of Employee Vested Benefits and Benefits Processes
- Conducting Audit / Ethics Activities
- Conducting Training Activities
- Execution of Access Authorizations
- Execution of Activities in Compliance with the Legislation
- Execution of Finance and Accounting Affairs
- Ensuring Physical Space Security
- Execution of Assignment Processes
- Monitoring and Execution of Legal Affairs
- Conducting Internal Audit/ Investigation Activities
- Execution of Communication Activities
- Planning Human Resources Processes
- Execution / Supervision of Business Activities
- Execution of Occupational Health / Safety Activities
- Receiving and Evaluating Suggestions for Improvement of Business Processes
- Execution of Business Continuity Ensuring Activities
- Execution of Logistics Activities
- Execution of Goods / Service Procurement Processes
- Execution of Goods / Services After Sales Support Services
- Execution of Goods / Service Sales Processes
- Execution of Goods / Services Production and Operation Processes
- Execution of Customer Relationship Management Processes
- Execution of Activities for Customer Satisfaction
- Organization and Event Management
- Conducting Marketing Analysis Studies
- Execution of Performance Evaluation Processes
- Execution of Advertising / Campaign / Promotion Processes
- Execution of Storage and Archive Activities
- Execution of Contract Processes
- Tracking Requests / Complaints
- Execution of Supply Chain Management Processes
- Execution of Wage Policy
- Execution of Marketing Processes of Products / Services
- Providing Information to Authorized Persons, Institutions and Organizations
- Execution of Management Activities
- Creating and Tracking Visitor Records
ARTICLE 9 - CAMERA SURVEILLANCE OF COMPANY HEADQUARTERS AND STORES
If you visit our Company headquarters and stores, your visual data may be obtained through a closed circuit camera system and may be stored for a period of time for the purposes specified below in accordance with the Law on Private Security Services and the relevant legislation.
The use of closed circuit camera systems aims to prevent and monitor criminal behavior, to ensure the security of precious metals, money, valuable documents and all kinds of goods in our Company headquarters and stores, and to protect the health and safety of our visitors and employees. In this respect, the monitoring areas, number and the time of monitoring of the security cameras are sufficient to achieve the security purpose and are limited to this purpose. The privacy of the person is not subject to monitoring in areas that may result in interference in excess of security purposes. In addition to the enlightenment regarding general issues, our Company places notification letters and warning signs at the entrances of the areas where monitoring is carried out. Thus, it is aimed to protect the rights of data subjects whose personal data are processed and to ensure transparency in personal data processing. All necessary technical and administrative measures are taken by our Company to ensure the security of your data obtained through the closed circuit camera system.
The records collected through closed circuit security camera systems are kept for 60 (sixty) days from the date of recording in our Company headquarters and 100 (one hundred) days in our stores and are automatically deleted from the records at the end of this period.
ARTICLE 10 - TRANSFER OF PERSONAL DATA
The personal data you share may be transferred to domestic official institutions and organizations, banks, our group companies, subsidiaries, business partners, suppliers and service providers in Turkey and abroad for the purposes specified in Article 3 of this Clarification Text within the scope of the provisions of the KVKK (Personal Data Protection Law) regarding the transfer of personal data and transfer abroad.
ARTICLE 11 - PROTECTION OF PERSONAL DATA AND STORAGE PERIOD
The Company is obliged to take software measures such as hashing, encryption, transaction recording, access management and physical security measures in order to protect the systems and databases where your personal data you share, to prevent unlawful processing of personal data in accordance with Article 12 of the KVKK (Personal Data Protection Law), to prevent unauthorized access; to ensure their preservation. If it is learned that personal data is obtained by others illegally, the situation will be immediately notified to the Personal Data Protection Board in writing and in accordance with the legal regulation.
The Company stores Personal Data for the period specified in this legislation, if stipulated in the legislation. If a period of time is not regulated in the legislation on how long personal data should be kept, Personal Data is processed for a reasonable period of time that requires processing in accordance with the practices and customs of the Company's commercial life, depending on the activity carried out by the Company while processing that data, and then deleted, destroyed or anonymized.
If the purpose of processing personal data has ended and the retention periods determined by the relevant legislation and the Company have come to an end; personal data may only be stored for the purpose of constituting evidence in possible legal disputes or for the assertion or defense of the relevant right related to personal data. In the establishment of the periods here, the retention periods are determined based on the statute of limitations for the assertion of the right in question and the examples in the requests previously addressed to the Company on the same issues despite the expiration of the statute of limitations. In this case, the stored personal data is not accessed for any other purpose and access to the relevant personal data is provided only when it is required to be used in the relevant legal dispute. After the aforementioned period expires, personal data are deleted, destroyed or anonymized.
Detailed regulations regarding the Company's techniques regarding the storage, deletion, destruction and anonymization of Personal Data are included in the Company's Personal Data Retention and Destruction Policy.
ARTICLE 12 - KEEPING PERSONAL DATA UP-TO-DATE AND ACCURATE
Pursuant to Article 4 of the KVKK, the Company has the obligation to keep your personal data accurate and up-to-date. In this context, in order for the Company to fulfill its obligations arising from the legislation in force, our members are required to share their accurate and up-to-date data or update them via the website / mobile application.
ARTICLE 13 - RIGHTS OF THE PERSONAL DATA OWNER
The rights of the personal data owner pursuant to Article 11 of the KVKK are as follows:
- To learn whether your personal data is being processed or not,
- To request information if your personal data has been processe
- To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
- To know the third parties to whom your personal data is transferred domestically or abroad,
- To request correction of your personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal personal data is transferred,
- To request the deletion or destruction of personal data and to notify the third parties to whom the personal data has been transferred to, in the event that the reasons requiring the processing of the data disappear, although data has been processed in accordance with the provisions of the law and other relevant laws.
- To object to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
- To request the compensation of the damage in case of loss due to unlawful processing of personal data.
ARTICLE 14 - CONTACT AND APPLICATION METHOD
The Data Controller Representative to be appointed by the Company will be announced in the Data Controllers Registry and on the website where this document is available when the legal infrastructure is provided.
Personal Data Subjects may direct their questions, opinions or requests to the e-mail address [email protected].
The Company may give a positive/negative response to the requests in written or digital media, provided that it is justified and responded within 30 days. It is essential that the necessary procedures regarding the requests are free of charge. However, if the transactions require a cost, the Company reserves the right to charge a fee. These fees are determined by the Personal Data Protection Board over the tariff determined in accordance with Article 13 of the Personal Data Protection Law.
By sharing your personal data on our website, applications and other channels, you declare that you agree to Our Personal Data Policy and the processing methods in our policy; conditions on the transfer and sale of data and other related matters; use of shared data on the website, applications and social media channels; making notifications and recommendations; and data may be shared with third parties in a commercial sense, provided that it is for the benefit of the members and that you will apply to the Company before exercising your legal rights, and that you accept with an explicit consent, which is defined in the KVKK as a consent of great importance, regarding a specific subject, based on information and expressed with free will.
MİCHEL SAĞ MÜCEVHERAT SANAYİ VE TİCARET LİMİTED ŞİRKETİ
Adres : Alemdar Mahallesi Çatalçeşme Sokak Bateş Han No 40/101 Fatih/ISTANBUL
Customer Service: 0850 888 60 86
Headquarters: 0212 528 79 57
Whatsapp Line: 0546 454 02 60
E-mail: [email protected]
Kep Address: [email protected]