Personal Data Policy
This Privacy Notice has been prepared by INSPECTO TEKNOLOJİ DANIŞMANLIK VE TİC.LTD.ŞTİ (“Data Controller”) in accordance with Article 10 of the Turkish Personal Data Protection Law No. 6698 (“KVKK”) and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform, in order to inform you about how your personal data is processed within the scope of online sales and after-sales support services carried out through the website www.ellagenix.com.
1. IDENTITY OF THE DATA CONTROLLER
Your personal data is processed by INSPECTO TEKNOLOJİ DANIŞMANLIK VE TİC.LTD.ŞTİ, acting as the data controller, within the framework of the provisions of the KVKK:
Trade Name: INSPECTO TEKNOLOJİ DANIŞMANLIK VE TİC.LTD.ŞTİ
Address: Barbaros Mah. Çiğdem Sokak No:1/19 Kat:4 Ağaoğlu My Office Ataşehir/İstanbul, Türkiye
Tax Office / No: Kozyatağı Tax Office / 4651095464
Website: www.ellagenix.com
Email:
Registered Electronic Mail (KEP):
Phone:
2. METHODS OF COLLECTING PERSONAL DATA
Your personal data is collected by INSPECTO TEKNOLOJİ DANIŞMANLIK VE TİC.LTD.ŞTİ through fully or partially automated means, or by non-automated means provided that they form part of a data recording system, via the following channels:
- Membership, order, payment and return transactions carried out through the website www.ellagenix.com
- Requests submitted through call center, email and customer service channels
- Cookies and similar tracking technologies used on the website
- Delivery information obtained through integrations with cargo and logistics companies
- Integrations with payment institutions and banking systems
- Complaint and request platforms and social media channels
3. PERSONAL DATA CATEGORIES, PROCESSING PURPOSES AND LEGAL BASES
Within the scope of online sales and after-sales support services, your personal data is processed for the following purposes based on the legal grounds for processing specified in Article 5 of the KVKK:
| DATA CATEGORY | EXAMPLES | PROCESSING PURPOSES | LEGAL BASIS (KVKK Art. 5) |
|---|---|---|---|
| • Identity Data • Contact Data • Customer Transaction Data • Transaction Security Data |
• Full name, Turkish ID number • Address, email, phone • Order/invoice/payment information • Contract, privacy notice records • Log and consent records |
• Issuing invoices • Processing withdrawal, return and cancellation requests • Keeping and storing distance sales contract and pre-contract information form records • Providing information/documents to authorized institutions • Archiving activities |
• KVKK Art. 5/2(a) Explicitly provided for by law |
| • Identity Data • Contact Data • Customer Transaction Data • Legal Transaction Data • Request/Complaint Data • Transaction Security Data |
• Full name • Email, phone, delivery address • Order, product, payment, invoice information • Contract, pre-contract information form, privacy notice records • Request content • Log records |
• Receiving, confirming and managing orders • Processing payments and ensuring payment security • Managing delivery and shipping processes • After-sales support and return processes • Customer service and complaint management • Concluding distance sales contracts • Conducting information security processes |
• KVKK Art. 5/2(c) Necessary for the establishment or performance of a contract |
| • Identity Data • Contact Data • Customer Transaction Data • Legal Transaction Data • Transaction Security Data |
• Full name, Turkish ID number • Email, phone • Invoice, payment, order information • Contract and pre-contract information form records • Log records |
• Issuing e-invoices / e-archive invoices • Fulfilling obligations under tax legislation • Fulfilling obligations under consumer protection legislation • Making mandatory notifications • Archiving activities |
• KVKK Art. 5/2(ç) Necessary for compliance with a legal obligation |
| • Identity Data • Contact Data • Customer Transaction Data • Request/Complaint Data • Transaction Security Data |
• Full name • Email, phone, address • Order, payment information • Request and complaint content • Suspicious transaction information • Log records |
• Conducting legal and advisory processes • Detecting and preventing suspicious transactions • Monitoring customer satisfaction • Audit and reporting activities • Measuring sales performance |
• KVKK Art. 5/2(e) Necessary for the establishment, exercise or protection of a right • KVKK Art. 5/2(f) Necessary for the legitimate interests of the data controller |
| • Marketing and Cookies • Location Data |
• Shopping preferences, browsing history • Cookie data, session information • Delivery address (GPS if mobile permission is granted) |
• Sending campaigns, discounts and new product announcements • Personalized content and advertisements • Behavioral analysis and remarketing • Auto-filling order address (location) |
• KVKK Art. 5/1 Explicit consent (within the scope of commercial electronic message consent) Address information may still be entered manually even if explicit consent is not given. |
4. TRANSFER OF PERSONAL DATA
Your personal data may be shared with the following recipient groups within the framework of Articles 8 and 9 of the KVKK, for the specified purposes and on the stated legal bases:
| RECIPIENT GROUP | PURPOSE OF TRANSFER | DATA CATEGORY | LEGAL BASIS |
|---|---|---|---|
| Cargo and Logistics Companies | Managing delivery processes | Identity, Contact, Customer transaction | KVKK Art. 5/2(c) — Performance of contract |
| Payment Institutions and Banks | Processing payments, refunds and exchanges; Monitoring and preventing suspicious transactions | Identity, Customer transaction | KVKK Art. 5/2(ç) — Legal obligation; KVKK Art. 5/2(f) — Legitimate interest |
| E-Invoice / E-Archive Service Providers | Fulfilling invoice issuance obligations | Identity, Contact, Customer transaction, Legal transaction | KVKK Art. 5/2(ç) — Legal obligation |
| Infrastructure and IT Service Providers | Website operation, payment infrastructure, data hosting and security services | Identity, Contact, Customer transaction, Transaction security | KVKK Art. 5/2(f) — Legitimate interest |
| Legal Advisors and Mediators | Managing disputes; Establishing and protecting rights | Identity, Contact, Customer transaction, Legal transaction | KVKK Art. 5/2(e) — Establishment of a right; KVKK Art. 5/2(f) — Legitimate interest |
| Financial Advisors and Independent Auditors | Auditing financial statements; Approving tax returns | Identity, Contact, Legal transaction, Customer transaction | KVKK Art. 5/2(ç) — Legal obligation; KVKK Art. 5/2(f) — Legitimate interest |
| Authorized Public Institutions and Organizations | Legal obligations under tax, consumer and customs legislation; Court and prosecution requests | Identity, Contact, Customer transaction, Legal transaction | KVKK Art. 5/2(ç) — Legal obligation; KVKK Art. 5/2(e) — Establishment of a right |
Your personal data may be transferred abroad within the current transfer regime set out in Article 9 of the KVKK, provided that an adequacy decision has been issued by the Personal Data Protection Board or appropriate safeguards announced by the Board (standard contract, binding corporate rules, etc.) have been established by the parties.
5. YOUR RIGHTS AS A DATA SUBJECT
You may submit your requests regarding your rights under Article 11 of Law No. 6698 to INSPECTO TEKNOLOJİ DANIŞMANLIK VE TİC.LTD.ŞTİ through the following methods in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. Your applications will be finalized within 30 (thirty) days at the latest, depending on the nature of the request, after your identity has been verified.
| APPLICATION METHOD | ADDRESS / DESCRIPTION |
|---|---|
| Written / Mail | Barbaros Mah. Çiğdem Sokak No:1/19 Kat:4 Ağaoğlu My Office Ataşehir/İstanbul, Türkiye (with wet signature and a copy of identity document) |
| ______________________________ (must be sent from your registered email address in the system and identity verification is required) | |
| KEP | ______________________________ (Registered Electronic Mail) |
If your application is rejected, deemed insufficient, or not answered within the required period, you retain the right to lodge a complaint with the Personal Data Protection Authority (KVKK).
6. COMMERCIAL ELECTRONIC MESSAGES (ETK) AND EXPLICIT CONSENT
Pursuant to Law No. 6563 on the Regulation of Electronic Commerce, commercial electronic messages containing marketing content such as campaigns, discounts, new product announcements and promotions (email, SMS, push notifications, etc.) are sent only with your prior, explicit and freely given consent under the Commercial Electronic Message (ETK) approval.
7. COOKIES
The website www.ellagenix.com uses cookie technology to improve user experience, measure site performance, ensure security and carry out marketing activities.
• Strictly Necessary Cookies: Required for the basic functionality of the website; used without seeking your consent.
• Analytics / Performance Cookies: Used to measure visitor behavior; activated with your consent.
• Marketing / Targeting Cookies: Used to deliver personalized advertisements; activated only with your ETK and cookie consent.
You may disable cookies through your browser settings; however, some features of the website may not function properly in that case. For detailed information, please review our Cookie Policy.
8. UPDATES TO THIS PRIVACY NOTICE
This Privacy Notice may be updated in line with changes in applicable legislation, decisions of the Personal Data Protection Board, or changes that may arise in the business activities of INSPECTO TEKNOLOJİ DANIŞMANLIK VE TİC.LTD.ŞTİ. The updated text becomes effective as of the date it is published at www.ellagenix.com.