CUSTOMER PERSONAL DATA PROCESSING DISCLOSURE STATEMENT
Protection of personal data is an important matter for Asos Capital. Acting as the data controller, Asos Capital complies with the principles and obligations set forth under the Law on the Protection of Personal Data No. 6698 (“KVKK”).
This Disclosure Statement has been prepared to inform the relevant persons (“User”) whose personal data are processed through the website www.asoscapital.com.
DATA CATEGORIES AND SAMPLE DATA TYPES
The personal data processed by Asos Capital are listed in the tables below.
Member Customer Personal Data
| Data Category | Content |
|---|---|
| Identity Information | Name, surname, date of birth, gender, Turkish ID number |
| Contact Information | Mobile phone number, e-mail address, address, postal code, landline phone |
| Payment Information | Tax office, invoice information, payment method information |
| Membership Information | Membership information, membership ID number, password |
| Customer Transaction Information | Purchased product(s), order details including purchase amount and purchase date, commercial communication consent, campaigns/competitions benefited from, coupons used |
| Transaction Security Information | IP address, user transaction records |
| Marketing Information | Marketing SMS, e-mail messages or call center calls sent based on the commercial electronic communication consent given by the relevant person, cookie records, targeting information, evaluations showing habits and preferences |
| Visual and Audio Data | Call center conversation records, photos added to the product review section |
| Legal Transaction Information | Service start and end time, type of service received, membership agreement approved, other legal texts and contracts enabling the use of services provided by Asos Capital |
| Request and Complaint Information | Records related to complaints and/or requests submitted by the relevant person regarding a purchased product or service through the Site, Mobile Application, social media accounts or call center, and the processes carried out for the evaluation or management of these requests |
Guest Customer (Users Shopping Without Membership) Personal Data
| Data Category | Content |
|---|---|
| Identity Information | Name, surname, date of birth, Turkish ID number |
| Contact Information | Mobile phone number, e-mail address, address, postal code, landline phone |
| Payment Information | Tax office, invoice information, payment method information |
| Guest Customer Transaction Information | Purchased product(s), purchase amount, purchase date, call center conversation records, commercial communication consent, campaigns benefited from, order information |
| Transaction Security Information | IP address |
| Marketing Information | Marketing SMS, e-mail messages or call center calls sent based on the commercial electronic communication consent given by the relevant person, cookie records, targeting information, evaluations showing habits and preferences |
| Visual and Audio Data | Call center conversation records, photos added to the product review section |
| Legal Transaction Information | Service start and end time, type of service received, other legal texts and contracts enabling the use of services provided by Asos Capital |
| Request and Complaint Information | Records related to complaints and/or requests submitted by the relevant person regarding a purchased product or service through the Site, Mobile Application, social media accounts or call center, and the processes carried out for the evaluation or management of these requests |
PURPOSES OF PROCESSING PERSONAL DATA AND LEGAL GROUNDS
Article 5 of the KVKK regulates the legal grounds for processing personal data. The table below indicates for which purposes and on which legal grounds personal data are processed by Asos Capital.
Processes in Which Customer Personal Data Are Processed
| Processed Personal Data | Purpose of Processing | Legal Ground |
|---|---|---|
| Identity, Contact, Payment, Membership, Customer Transaction, Transaction Security, Marketing, Visual/Audio, Legal Transaction, Request/Complaint Information | Fulfillment of obligations arising from the laws to which Asos Capital is subject (e.g., contacting customers regarding legal notifications and information) | Explicitly stipulated by law (KVKK Art. 5/2-a) |
| Identity, Contact, Payment, Membership, Customer Transaction, Transaction Security, Legal Transaction Information | Verification of member information; execution of membership processes. Receiving and managing orders, tracking order status, processing payments related to orders, issuing invoices, and managing delivery processes | Processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the establishment or performance of a contract (KVKK Art. 5/2-c) |
| Identity, Contact, Payment, Membership, Customer Transaction, Transaction Security, Visual and Audio Data | Conducting sales and after-sales support processes | Necessary for the establishment or performance of a contract (KVKK Art. 5/2-c) |
| Identity, Contact, Payment, Membership, Customer Transaction, Transaction Security, Marketing, Visual/Audio, Legal Transaction, Request/Complaint Information | Fulfillment of our legal obligations when authorized institutions request information from our Company or when notification to such institutions is required; fulfillment of obligations arising from e-commerce and consumer legislation | Processing is mandatory for the data controller to fulfill its legal obligations (KVKK Art. 5/2-ç) |
| Same Data Groups | Protection and exercise of our rights in case of possible disputes or violations of terms of use; conducting legal processes; detection of suspicious/fraudulent transactions | Processing is necessary for the establishment, exercise or protection of a right (KVKK Art. 5/2-e) |
| Membership, Contact, Customer Transaction, Marketing Information | Understanding how users use the Site/Mobile Application; improving user experience and platform content | Processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person (KVKK Art. 5/2-f) |
| Identity, Contact Information | Contacting you about campaigns, opportunities and solutions if you have given explicit consent | Explicit consent of the relevant person (KVKK Art. 5/1) |
METHODS OF OBTAINING PERSONAL DATA
Asos Capital obtains personal data through electronic channels such as the Website, call center and e-mail via fully or partially automated methods. In certain cases, data may also be obtained through non-automated methods in physical environments, provided that they are part of a data recording system (for example, if you send us documents by post).
TO WHOM AND FOR WHAT PURPOSE PERSONAL DATA MAY BE TRANSFERRED
Asos Capital transfers personal data only for the purposes stated in this Disclosure Statement and in accordance with Articles 8 and 9 of the KVKK.
Authorized Persons, Institutions and Organizations: Sharing information within the framework of legal obligations (KVKK Art. 5/2-a, 5/2-ç)
Partner Sellers and Cargo Companies (working with Asos Capital): Order delivery and order management (KVKK Art. 5/2-c)
Service Providers, Business Partners, Suppliers: Compliance with company policies, auditing, reporting, and technical infrastructure support (KVKK Art. 5/2-c, 5/2-f)
If Member Customers or Guest Customers contact Asos Capital through the corporate WhatsApp line, personal data may be transferred abroad since the WhatsApp platform is a service provided from abroad. If Member or Guest Customers do not wish their personal data to be transferred abroad via WhatsApp, they may use other communication channels offered by Asos Capital.
RIGHTS OF THE DATA SUBJECT
Pursuant to Article 11 of the KVKK, regarding the processing of your personal data, you have the right to:
Learn whether your personal data are processed
Request information if they have been processed
Learn the purpose of processing and whether they are used in accordance with their purpose
Know the third parties to whom they are transferred
Request correction if they are incomplete or incorrect
Request deletion
Object to processing
Request compensation for damages
To exercise your rights regarding your personal data, you may access your account through the “My Account” section on the Asos Capital website or mobile site and perform necessary actions such as modification, update and/or deletion.
You may also exercise your rights by submitting your application through the methods specified in the Application Form available on the website or mobile application of the electronic commerce platforms operated by Asos Capital.
By sending your request using the e-mail address registered in our systems to info@creafinans.com
By sending your request in writing together with documents verifying your identity to LEVENT MAH. BEYAZKARANFİL SOK. NO:45 BEŞİKTAŞ / İSTANBUL
By using other methods specified in the Communiqué on the Procedures and Principles of Application to the Data Controller
a. Use of Cookies
Cookies are used on the website www.asoscapital.com by Asos Capital. The Cookie Policy includes information about the cookies used on our website, their purposes and the duration for which they remain active. For detailed information about our cookie usage, please review the Cookie Policy.
b. Changes to the Disclosure Statement
Asos Capital may amend this Disclosure Statement at any time. These changes become effective immediately upon publication of the updated Disclosure Statement. Necessary notifications will be provided to inform you about such changes.
