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PROTİM HEARING PRIVACY AND PERSONAL DATA PROTECTION POLICY
Effective Date: [01.01.2025]
1. INTRODUCTION AND DATA CONTROLLER IDENTITY
This Privacy and Personal Data Protection Policy ("Policy") explains the procedures and principles regarding the processing of personal data by PROTİME İŞİTME CİHAZLARI SANAYİ VE TİCARET ANONİM ŞİRKETİ ("PROTİM HEARING" or the "Company") as the data controller, for our valued users ("Data Subject" or "User") who visit, become members of, and benefit from the services offered on our website www.protimisitme.com ("Site").
Our Company pays utmost attention to the security of your personal data and conducts all data processing activities in accordance with the Law on the Protection of Personal Data No. 6698 ("KVKK").
Data Controller: Betül Ergin
MERSIS Number: 0733041488900018
Address: Dervişpaşa Mah. Atatürk Cad. No: 53/D Merkez/Afyonkarahisar
Phone: 0272 214 69 69
Email: aserdarballi@hotmail.com
2. PROCESSED PERSONAL DATA, PURPOSES AND LEGAL GROUNDS
Your personal data may be processed in accordance with the purposes and legal bases specified below in connection with your use of the Site and our services.
2.1. Identity and Contact Information
Data Category: Name, surname, Turkish ID number, phone number, email address, delivery and billing addresses.
Purposes of Processing:
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To carry out and manage membership transactions.
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To process and deliver orders.
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To manage post-sale support, service, and return procedures.
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To perform billing and accounting operations.
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To contact you regarding your order.
Legal Basis: Directly related to the establishment or execution of a contract (KVKK Art. 5/2-c), and necessary for fulfilling the data controller's legal obligations (KVKK Art. 5/2-ç).
2.2. Special Categories of Personal Data (Health Data)
Data Category: Audiogram (hearing test result), doctor’s prescription, required for the sale and identification of the appropriate hearing aid.
Purposes of Processing:
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To determine and provide the most suitable medical hearing device for your hearing loss.
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To fulfill obligations under relevant medical device regulations.
Legal Basis: These data are processed only based on explicit consent or legal obligation due to their sensitive nature (KVKK Art. 6/2). Separate explicit consent will be obtained during the order process.
2.3. Customer Transaction and Financial Data
Data Category: Order information, purchase history, payment details, masked bank/credit card information (processed via secure payment provider).
Purposes of Processing:
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To manage financial transactions and payments.
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To fulfill the requirements of the Distance Sales Agreement.
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To process refunds in case of returns.
Legal Basis: Directly related to the establishment or execution of a contract (KVKK Art. 5/2-c).
2.4. Marketing and Cookie Data
Data Category: Shopping preferences, cookie records, campaign participation, IP address.
Purposes of Processing:
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To personalize and enhance your site experience.
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To conduct market analysis and segmentation.
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To inform you about promotions and campaigns based on your interests (with consent).
Legal Basis: Legitimate interests of the data controller (KVKK Art. 5/2-f) and explicit consent of the Data Subject (KVKK Art. 5/1). Separate consent will be obtained for commercial electronic messages.
3. TRANSFER OF PERSONAL DATA
Your personal data may be shared with third parties within Turkey and, with adequate safeguards, abroad, in accordance with KVKK Articles 8 and 9 for the purposes stated above:
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Suppliers and Partners: For product supply or service delivery (e.g., product importer).
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Shipping and Logistics Companies: For order delivery.
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Payment Service Providers: For secure payment transactions.
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IT Service Providers: For hosting, maintenance, and security of the website.
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Authorized Public Institutions: Based on legal requests and obligations (e.g., court orders, tax audits).
4. RIGHTS OF THE DATA SUBJECT (USER) (KVKK Article 11)
Every person whose personal data is processed has the following rights under Article 11 of the KVKK:
a) To learn whether personal data is being processed,
b) To request information if personal data has been processed,
c) To learn the purpose of processing and whether it is used appropriately,
d) To know the third parties to whom personal data is transferred domestically or abroad,
e) To request correction of incomplete or inaccurate data,
f) To request deletion or destruction under the conditions specified in KVKK Article 7,
g) To request notification of transactions made pursuant to (d) and (e) to third parties,
h) To object to a result against them arising from automated data processing,
i) To request compensation if they suffer damages due to illegal processing.
To exercise these rights, please send your request in writing or via email to [kvkk@protimisitme.com]. Your request will be processed free of charge within 30 (thirty) days, depending on its nature.
5. DATA SECURITY
PROTİM HEARING takes all necessary technical and administrative measures to prevent unlawful processing and access, and to ensure the secure storage of your personal data. These include use of SSL (Secure Sockets Layer) certification, secure databases, access control, and regular security audits.
6. COOKIE POLICY
We use cookies on our site to enhance user experience. Please review our “Cookie Policy” for detailed information.
7. CHANGES TO THE POLICY
PROTİM HEARING reserves the right to amend this Policy in accordance with legal regulations and internal policies. The updated Policy shall take effect once published on the Site. Users will be informed of changes via email or through the Site.