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CORPORATE GENERAL INFORMATION NOTICE ON THE PROCESSING OF PERSONAL DATA

Reform Spor Sistemleri Sanayi Ve Ticaret Anonim Şirketi (“Reform Spor Sistemleri”) has prepared this information notice to inform our Visitors, Online Visitors, Customers, Potential Customers, Supplier Employees, and Supplier Representatives regarding the processing, storage, and transfer of your personal data within the scope of our activities arising from the Law on the Protection of Personal Data No. 6698 (“KVKK”) and relevant legislation and legal regulations.

1) What Categories of Personal Data Do We Process and For What Purposes?

Your personal data may be processed by Reform Spor Sistemleri Sanayi Ve Ticaret Anonim Şirketi in accordance with Article 4.2 of KVKK, which requires that data be:

  • Processed lawfully and fairly,
  • Accurate and kept up to date where necessary,
  • Processed for specified, explicit, and legitimate purposes,
  • Relevant, limited and proportionate to the purposes for which they are processed,
  • Stored for the period laid down by relevant legislation or the period required for the purpose for which the personal data are processed.

Your data may be processed in line with the following purposes, as part of the ongoing business relationships established with our business partners (a person may fall into multiple categories).

A.  Our Visitors

The identity information (e.g. name, surname) and physical space security information (e.g. camera recordings) of our visitors;

  1. To create and track visitor records,
  2. To ensure physical space security.

B.  Our Online Visitors

The transaction security information (e.g. your IP address), marketing information (e.g. browsing history, cookie records), and, if provided by you, identity and contact information (e.g. your email address);

  1. To carry out activities in compliance with legislation,
  2. To manage information security processes,
  3. To track requests/complaints,
  4. To conduct communication activities,
  5. To provide information to authorized persons, institutions, and organizations,
  6. To enable your access to our website via the internet.

C.  Our Customers

The identity information, contact information, customer transaction information (e.g. order details), physical space security information, financial information (e.g. balance sheets), legal transaction information, and marketing information (e.g. purchase history) of real person customers or authorized persons and/or employees of legal entity customers;

  1. To conduct activities in accordance with legislation,
  2. To carry out financial and accounting affairs,
  3. To manage and audit business operations,
  4. To manage logistics operations,
  5. To provide after-sales support services,
  6. To carry out product/service sales processes,
  7. To conduct marketing analysis,
  8. To manage contract processes,
  9. To provide information to authorized persons, institutions, and organizations,
  10. To ensure physical space security,
  11. To resolve legal disputes,
  12. To manage archiving and storage activities,
  13. To manage risk processes,
  14. To ensure loyalty to company/products/services,
  15. To carry out communication activities.

D.  Our Potential Customers

The identity information, contact information, customer transaction information, physical space security information, marketing information of real person customers or authorized persons and/or employees of legal entity customers;

The identity information, contact information, physical space security information, customer transaction information, financial information, marketing information, and legal transaction information of our real person suppliers or authorized representatives of legal entity suppliers;

  1. to carry out/manage business operations,
  2. to manage procurement processes for goods/services,
  3. to manage financial and accounting operations,
  4. to manage contract processes,
  5. to manage investment processes,
  6. to ensure physical space security,
  7. to monitor and conduct legal affairs.

2) What Are the Methods of Collecting Your Personal Data?

Your personal data specified in the categories above are collected by physical means such as order forms, contracts, and visitor forms, or by automated or non-automated means through information systems and electronic devices (e.g., telecommunications infrastructure, computers, and phones), third parties (e.g., KKB and Findeks), our website, and other documents declared by the data subject.

3) What Is the Legal Basis for Collecting Your Personal Data?

Your personal data are processed by Reform Spor Sistemleri Sanayi Ve Ticaret Anonim Şirketi based on the legal grounds stated in Article 5 of the KVKK to achieve the purposes outlined above:

  • Explicitly provided for by law,
  • Necessary for the establishment or performance of a contract,
  • Necessary for the data controller to fulfill its legal obligation,
  • Necessary for the establishment, exercise, or protection of a right,
  • Necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

4) Do We Transfer Your Personal Data to Third Parties?

  1. Visitor personal data may be shared with law enforcement and judicial authorities if required by relevant legislation and for the resolution of legal disputes.
  2. Online visitor personal data may be shared with judicial authorities and competent public institutions if required by relevant legislation and for the resolution of legal disputes.
  3. Customer personal data may be transferred to competent public institutions, group companies, IT companies, suppliers, cargo companies, insurance companies, banks, and our financial advisor as necessary for compliance with legal regulations, execution of legal affairs, business operations, risk management, and service delivery. These data may also be shared with our legal advisors and judicial authorities in case of future legal disputes.
  4. Potential customer personal data may be shared with our legal advisors and judicial authorities for use as evidence in future legal disputes.
  5. Supplier employee personal data may be transferred to competent public institutions, group companies, IT companies, suppliers, cargo companies, banks, and our financial advisor for purposes such as compliance with legal regulations, execution of legal affairs, business operations, and service delivery. These data may also be shared with our legal advisors and judicial authorities in case of future legal disputes.
  6. Supplier representative personal data may be transferred to competent public institutions, group companies, IT companies, suppliers, cargo companies, banks, and our financial advisor for purposes such as compliance with legal regulations, execution of legal affairs, business operations, and service delivery. These data may also be shared with our legal advisors and judicial authorities in case of future legal disputes.

5) Do We Transfer Your Personal Data Abroad?

As Reform Spor Sistemleri Sanayi Ve Ticaret Anonim Şirketi, we do not transfer your personal data abroad.

6) How Can You Exercise Your Rights Regarding Your Personal Data?

You may submit your requests within the scope of Article 11 of the KVKK regarding your rights to Reform Spor Sistemleri Sanayi Ve Ticaret Anonim Şirketi using the “Data Subject Application Form” prepared for your convenience, available at https://reformsports.com/ in accordance with the “Communiqué on the Procedures and Principles of Application to the Data Controller.”

Data Controller: Reform Spor Sistemleri Sanayi Ve Ticaret Anonim Şirketi
Address: Mahmutbey Mahallesi 2475. Sokak No: 4-6/21 Bağcılar İstanbul
Email: [email protected]

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