Information Note Pertaining to the
Protection of Personal Data
This document has been issued within the framework of Article 10 of Law No. 6698 on the Protection of Personal Data (“Law”) by LUCEO LLC (“LUCEO”) as “Data Controller” in order to fulfill its obligation to provide information regarding the processing of your personal data (your name, address, phone number, email address, and any other personally identifiable information) (“Personal Data”), which are submitted to and/or collected by LUCEO pursuant to the law, and your rights thereof. In this manner, LUCEO is able to process and preserve your Personal Data in accordance with the Law.
LUCEO will process your Personal Data within the framework of laws and pursuant to mandatory/necessary/beneficial transactions for the following purposes: when needed by LUCEO to procure products and/or services; when needed to provide contractual services for LUCEO customers; to record identification, address, taxpayer number and other information in order to identify the owner and the addressee of any business and transaction to be conducted within the scope such services; and too issue information and documents that will form the basis of jobs and transactions to be carried out on paper or in electronic medium.
Personal Data is collected by LUCEO in order to provide products and/or services for the customers of LUCEO; and/or provided that it remains within the scope of establishing and performing contractual and non-contractual commercial relations with LUCEO for any reason, in verbal, written or electronic form and by means of various tools and channels in accordance with the legal purposes stated above and in order for LUCEO to be able to fulfill its obligations under the agreements and laws fully and accurately. Personal Data collected for these legal reasons may also be processed and transferred by LUCEO in accordance with the basic principles stipulated by the Law, within the scope of the Personal Data processing requirements and objectives set out in Articles 5 and 6 of the Law, and for the purposes set out in this text.
LUCEO will collect Personal Data only for specific, clear and legal purposes, and retain them only for the periods required for the purposes of processing the Personal Data described in the relevant section above. LUCEO will not process Personal Data in a manner that defies the purposes of collection stipulated by the Law and set out herein, and in the event that the purposes of data processing are no longer valid, it will delete or destroy or anonymize the data upon the related individual’s request or at its own discretion, reserving the conditions that mandate retaining the data legally.
LUCEO may transfer Personal Data in order to perform the data processing purposes stated above for LUCEO's legal compliance, judicial, financial, tax, etc. audit obligations to the following parties: business partners, Clients, suppliers and manufacturers, direct or indirect domestic/foreign affiliates, LUCEO officials, LUCEO internal departments, shareholders, internal and external auditors and contracted independent audit firms, legal counsel, third parties (including cloud computing service providers who may have servers in various countries) from which it procures or intends to procure various consultancy, support or services, legally authorized institutions and organizations and private persons within the framework of Personal Data collection terms and purposes stipulated in Articles 8 and 9 of the Law; process such data within the country or abroad; and also share such Personal Data via various channels.
Pursuant to Article 11 of the Law, Data Subjects are entitled to apply to LUCEO in order to
- Learn whether or not their personal data have been processed,
- Request information as to processing if their data have been processed;
- Learn the purpose of processing of their personal data and whether such data are used in accordance with their purpose;
- Know the third parties to whom personal data have been transferred within the country or abroad;
- Request rectification in case their personal data have been processed incompletely or inaccurately;
- Request deletion or destruction of their personal data within the framework of the conditions set forth under articles of “Deletion, Destruction, and Anonymization of Personal Data”;
- Request that the transactions carried out pursuant to their requests as per (d) and (e) are notified to third parties to whom personal data have been transferred;
- Object to any result that arises to their detriment by means of analysis of personal data exclusively through automated systems;
- Request compensation for the damages in case they incur damages due to unlawful processing of personal data.