Personal Data Protection Law (KVKK)

As Light Motion and Technology, we attach great importance to the privacy and security of your personal data.

In this context, it is among our priorities to process and store, in compliance with the Personal Data Protection Law No. 6698 (“KVKK”), all kinds of personal data belonging to all persons associated with Light Motion and Technology, including our customers and business contacts who benefit from our products and services. With our status as a "Data Controller" under the KVKK and with the awareness of this responsibility, we would like to inform you as follows about the purposes for which your personal data is processed, the methods and reasons for collecting your data, your rights regarding the processing of your personal data, and the application procedures and principles that constitute the method of exercising these rights.

a. What is Personal Data? Which Personal Data Do We Collect?

Personal data refers to all kinds of information that can be associated with you (“Personal Data”), primarily personal information regarding your identity (name, surname, T.R. identity number, etc.), as well as address and telephone information, vehicle and license plate information, family status information, IP address, and bank account information; and a special type of this, Special Categories of Personal Data, refers to sensitive personal data (“Special Categories of Personal Data”) such as data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and attire, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as your biometric and genetic data. The explanations we make on this page regarding your Personal Data also cover your Special Categories of Personal Data.

In this context, as Light Motion and Technology, where necessary and in compliance with the KVKK, we collect Personal Data belonging to our customers, business contacts, employees, job candidates, platform (our internet / mobile sites and applications) users, visitors, and the representatives and employees of institutions with which we have business relationships such as subcontractors and similar parties. We can detail the Personal Data we collect as follows:

  • Identity Data: These are data relating to a person's identity, such as name, surname, T.R. identity number, and identity card photocopy, which we collect from our customers, business contacts, employees, job candidates, platform (our internet / mobile sites and applications) users, visitors, and the representatives and employees of institutions with which we have business relationships such as subcontractors and similar parties.
  • Contact Data: These are data that enable communication with a person, such as telephone number, address, e-mail address, and IP address, which we collect from our customers, business contacts, employees, job candidates, platform (our internet / mobile sites and applications) users, visitors, and the representatives and employees of institutions with which we have business relationships such as subcontractors and similar parties.
  • Data Regarding Family Members: These are data regarding the family members and relatives of the relevant person, which we collect from our employees, job candidates, and the representatives and employees of institutions with which we have business relationships such as subcontractors and similar parties, pursuant to the relevant legislation and/or in order to protect the legal and other interests of our Company or the relevant person.
  • Financial Data: These are data such as wages, salary information, and bank account information, which we collect from our employees, job candidates, customers, business contacts, and the representatives and employees of institutions with which we have business relationships such as subcontractors and similar parties, according to the legal relationship our Company has established with the relevant data subject.
  • Personnel Data: These are all kinds of personal data that form the basis for the personal rights of natural persons who are in an employment relationship with our Company, which we collect from our employees, job candidates, and the employees of institutions with which we have business relationships such as subcontractors and similar parties.
  • Physical Premises Security Data: These are personal data such as security and camera recordings taken upon entry to the physical premises and during the stay within the premises, collected from our customers, business contacts, employees, job candidates, visitors, and the representatives and employees of institutions with which we have business relationships such as subcontractors and similar parties.
  • Communication and Complaint Management Data: These are personal data obtained from our customers, business contacts, platform (our internet / mobile sites and applications) users, visitors, and the representatives and employees of institutions with which we have business relationships such as subcontractors and similar parties, during the processes of receiving and evaluating all kinds of requests or complaints directed to our Company.
  • Special Categories of Personal Data: These are data specified in Article 6 of the KVKK, such as health data, biometric data (audio and video recordings), religion, and membership of associations or trade unions, which we collect from our customers, business contacts, employees, job candidates, visitors, and the representatives and employees of institutions with which we have business relationships such as subcontractors and similar parties.
  • Other Data: These are data processed for technical operational security, purchasing information, cookies, and data collected by automatic means and through other instruments, which we collect from our customers, business contacts, employees, job candidates, platform (our internet / mobile sites and applications) users, and the representatives and employees of institutions with which we have business relationships such as subcontractors and similar parties.

b. By Which Methods and Legal Grounds Do We Collect / Process Your Personal Data?

We collect your Personal Data by automatic or non-automatic means, in audio, verbal, written, or electronic form, through the main purposes and methods set out below and through other channels that may be added to these in the future.

We collect your Personal Data through our internet and mobile platforms (our internet / mobile sites and applications), through our social media accounts operated on behalf of Light Motion and Technology on various social media channels, through our call center managed by Light Motion and Technology, through e-mail, short messages (“SMS”) or multimedia messages (“MMS”) and other communication methods, through the Agreements we sign with you personally or with your company of which you are an authorized representative within the scope of Light Motion and Technology sales and marketing activities, through commercial offers presented, printed and electronic forms, business cards and other documents provided by you within the scope of customer visits we make, through third parties such as Light Motion and Technology group companies, business contacts, dealers and sales channels, manufacturer companies or companies from which it procures services/products, and through various channels including sources such as the Trade Registry, in verbal, written or electronic form, by various methods that are wholly or partially automatic or non-automatic as part of any data recording system.

We process your Personal Data, which we collect in line with the above methods, based on one or several of the legal grounds specified below:

  • The existence of your explicit consent,
  • The provisions of laws and regulations in force in the Republic of Türkiye permitting the processing,
  • It being mandatory for the protection of the life or physical integrity of yourself or another person, while you are unable to give your consent due to actual impossibility,
  • It being necessary for the performance of the agreement we have concluded with you or your company,
  • The processing of your Personal Data being necessary for the fulfillment of our legal obligations,
  • Your Personal Data having been made public by you,
  • It being necessary for the establishment or protection of our legal or contractual rights as Light Motion and Technology,
  • The processing of your Personal Data being necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms.

As Light Motion and Technology, we retain all Personal Data we process in accordance with the periods mandated by the KVKK and other legislation, and in any case, as long as the above legitimate purposes do not cease to exist, by taking all necessary administrative and technical measures.

c. For What Purpose Do We Process Your Personal Data?

We process your collected Personal Data, according to its nature, for the following general purposes:

  1. Fulfilling the requirements of the agreements concluded by Light Motion and Technology, providing the offered products and services, carrying out their production, sales, delivery and installation processes, developing the products and services and carrying out the necessary work and assessments to enable you to benefit from them, and carrying out after-sales maintenance and repair operations
  2. Following up and fulfilling the obligations arising from consumer legislation and responding to consumer applications
  3. Following up and evaluating the requests and complaints of relevant persons such as customers and consumers and providing support services, consumer satisfaction management, and within this scope, conducting planning, statistics and satisfaction surveys
  4. Conducting quality assessment and improvement work in order to provide better and more reliable products and services and to ensure sustainability, and auditing suppliers, subcontractors and similar parties with whom we have business relationships
  5. Carrying out advertising and marketing activities for the products and services offered by Light Motion and Technology, providing information on matters such as promotion, campaigns, offers, events and similar subjects and new products and services, and carrying out corporate communication activities
  6. Carrying out marketing and CRM (Customer Relationship Management) work
  7. Corporate communication and, within this scope, organizing other events and invitations and providing information about them, and carrying out market research work
  8. Improving the digital platforms we make available to our customers, consumers and business contacts, and, in order to provide platform users with an efficient and personalized experience, producing statistics such as the number, type, frequency of visits, behaviors and geographical locations of users, presenting personalized content, campaigns and advertisements according to the interests and needs of platform (internet and mobile site and application) users, and using cookies for this purpose
  9. Ensuring the legal and commercial security of persons who are in a business relationship with Light Motion and Technology (such as planning the administrative operations for communication carried out by our Company, ensuring the physical security and supervision of the Company's locations, business partner/customer/supplier (representative or employee) evaluation and audit processes, and the legal compliance process.)
  10. Exercising legal rights and, after the termination of the legal relationship, using information regarding transaction history as evidence in the event of a dispute
  11. Determining and implementing Light Motion and Technology's commercial, legal and business strategies
  12. Carrying out Light Motion and Technology's human resources and accounting/finance policies
  13. Planning, auditing and carrying out information security processes
  14. Compliance with domestic and international legislation, providing the information requested by public institutions and organizations, and fulfilling reporting obligations.

d. Transfer of Personal Data And Processing of Personal Data by Third Parties

The Company may transfer personal data to a third natural or legal person in compliance with the KVKK regulations. In this case, the Company ensures that the third parties to which it transfers also comply with this Policy. In this context, the necessary protective provisions are added to the agreements concluded with the third party.

  • Transfer of personal data to third parties located in Türkiye; Personal Data may be transferred by the Company to third parties located in Türkiye, in the exceptional cases specified in Article 5.2 and Article 6.3 of the KVKK without seeking explicit consent, or in other cases by obtaining the explicit consent of the Relevant Person (KVKK Article 5.1 and Article 6.2).
  • Transfer of personal data to third parties located abroad; Personal Data may be transferred by the Company to third parties located abroad, in the exceptional cases specified in Article 5.2 and Article 6.3 of the KVKK without seeking explicit consent, or in other cases by obtaining the explicit consent of the Relevant Person (KVKK Article 5.1 and Article 6.2). However, in respect of the foreign country to which it will be transferred, one of the following conditions must be met.
  • The foreign country to which the personal data is transferred having the status of a country deemed to have adequate protection by the Board
  • In the event that the foreign country to which the transfer will take place is not included in the Board's list of safe countries, provided that the Company and the Data Controllers in the relevant country undertake in writing that adequate protection will be ensured and obtain permission from the Board

e. Your Rights and Application Procedure

e.1. Your Rights Regarding Your Personal Data

We would like to state that you have the following rights regarding the data being processed within Light Motion and Technology and its affiliates:

  1. To learn whether your Personal Data is being processed,
  2. To request information if your Personal Data is being processed,
  3. To learn the purpose of processing your Personal Data and whether your personal data is being used in accordance with its purpose,
  4. To learn the third parties to whom the data is transferred domestically or abroad, if any, and which data has been transferred,
  5. To request the correction of the processed Personal Data in the event that it is incomplete or inaccurate,
  6. To request that, in the event your personal data is corrected, deleted or destroyed, these operations be notified to the third parties to whom your Personal Data has been transferred,
  7. To request the deletion or destruction of your processed Personal Data in the event that the reasons requiring the processing of your Personal Data cease to exist or your Personal Data loses its currency,
  8. To object to the emergence of a result against you by means of the analysis of your processed Personal Data exclusively through automated systems,
  9. To have the right to request the compensation of the damage in the event that you suffer damage due to the unlawful processing of your Personal Data.

e.2. Application

You may submit your requests regarding your Personal Data by filling out the application form linked below:

  1. By delivering it to the information office at our company address listed in the Data Controller Identity Information field, or by sending a notice to the same address via a Notary,
  2. It may be made via registered electronic mail.

Light Motion and Technology will conclude the requests directed to it free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. In the event that a cost arises due to the fulfillment of your requests, we may charge you only the fees set out in the tariff determined by the Personal Data Protection Board.

As a result of the requests directed to Light Motion and Technology, we may accept the requests or reject them by explaining the reason, and we may transmit this response to the requesting person in writing or in an electronic environment. In the event that the request is accepted, as Light Motion and Technology we are obliged to fulfill the requirement of the request immediately.

e.3. Complaint

In the event that the requests you have directed to Light Motion and Technology are rejected by Light Motion and Technology, that you are not satisfied with the response given by Light Motion and Technology, or that no response is given, you may file a complaint with the Personal Data Protection Board within 30 (thirty) days from the date the response is notified to you, and in the event that no response is given, within 30 days from the end of the 30 (thirty) day period.

f. Data Controller Identity Information

The expression Light Motion and Technology used in this text has been prepared for the affiliate of Light Motion and Technology established in Türkiye whose information is provided below, and is addressed to the relevant persons of the data for which the company specified below is the data controller:

 

Address: Southern Industrial ZoneYuzhen, bul. "Kuklensko Shose" 9ж, 4004 Plovdiv, Bulgaristan

Telephone: +359 89 5159543

E-Mail: hasan.korkut@isikelektromekanik.com

Application Form Under the KVKK

Personal data subjects defined as relevant persons under the Personal Data Protection Law No. 6698 (“PDP Law”) (hereinafter referred to as the “Applicant”) are granted the right to make certain requests regarding the processing of their personal data under Article 11 of the PDP Law. Pursuant to the first paragraph of Article 13 of the PDP Law; applications to be made to our Company, as the data controller, regarding these rights must be submitted to us in person, in written Turkish, and by the following methods determined by the Personal Data Protection Board (“Board”).

Below, information is provided on how written applications will be delivered to us.

Pursuant to the Communiqué on the Procedures and Principles of Application to the Data Controller (Official Gazette dated 10/03/2018 and numbered 30356), the following information is required to be included in applications.

Information to be Completed During the Application:

  • Name, surname and, if the application is written, signature,
  • T.R. identity number for citizens of the Republic of Türkiye; nationality, passport number, or identity number, if any, for foreigners,
  • Place of residence or workplace address for the purpose of notification,
  • Electronic mail address, telephone and fax number for notification, if any,
  • Subject of the request

In addition, information and documents relating to the subject are attached to the application.

If you wish to make an application regarding your personal data, the application form below must be filled out completely. This application form has been drawn up so that, by determining your relationship with our Company and identifying in full the personal data, if any, processed by our Company, your relevant application can be answered accurately and within the statutory period. In order to eliminate the legal risks that may arise from unlawful and improper data sharing and, in particular, to ensure the security of your personal data, our Company reserves the right to request additional documents and information (a copy of an identity card or driver's license, etc.) for the purpose of identity and authority verification. In the event that the information relating to your requests submitted within the scope of the form is inaccurate or not up to date, or that an unauthorized application is made, our Company does not accept any liability for requests arising from such inaccurate information or unauthorized application.

Applications submitted to us will be answered free of charge in writing within thirty days at the latest from the date your request reaches us, depending on the nature of the request, pursuant to the second paragraph of Article 13 of the PDP Law.