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Privacy Policy

IFA LSL MODA EĞİTİMİ VE DANIŞMANLIK LİMİTED ŞİRKETİ

PRIVACY POLICY

PREFACE

As IFA LSL MODA EĞİTİMİ VE DANIŞMANLIK LİMİTED ŞİRKETİ, within the scope of the Law on the Protection of Personal Data, we attach importance to the protection of your personal data and/or personal data of special nature. We are sensitive about keeping all your personal data and/or special quality personal data transmitted to our company through various means. In this context, Turkish Constitution and especially the Law on the Protection of Personal Data No. 6698. As IFA LSL MODA EĞİTİMİ VE DANIŞMANLIK LİMİTED ŞİRKETİ, we have taken the necessary technical and administrative measures in order to comply with the Constitution and other legislation provisions. We would like to emphasize that we will protect your rights that are guaranteed by the laws. In this context, you can safely share your personal data with IFA LSL MODA EĞİTİMİ VE DANIŞMANLIK LİMİTED ŞİRKETİ, and convey your suggestions, complaints and hesitations to us.

We share with you our Privacy Policy, which has been put into effect within the body of IFA LSL MODA EĞİTİMİ VE DANIŞMANLIK LİMİTED ŞİRKETİ, which is especially important for the protection of your personal data..

IFA LSL MODA EĞİTİMİ VE DANIŞMANLIK LİMİTED ŞİRKETİ

 1.DEFINITIONS

Data Controller It means IFA LSL MODA EĞİTİMİ VE DANIŞMANLIK LİMİTED ŞİRKETİ, which determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.
Data Owner- Related Person It refers to the real person whose personal data is processed.

   

Company

 IFA LSL MODA EĞİTİMİ VE DANIŞMANLIK LİMİTED ŞİRKETİ is meant in accordance with this policy.
Law It is expressed as “Law on Protection of Personal Data No. 6698”.
Personal Data Any information relating to the natural person that makes the identity specific or identifiable is expressed.

 

Sensitive Personal Data

 Data on race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, clothing, membership in associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data are of special nature means personal data.
Authority Personal Data Protection Authority is meant.
Policy

This is referred to as the “Privacy Policy”.
Processing of Personal Data Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or using personal data in whole or in part by automatic or non-automatic means provided that it is a part of any data recording system. It refers to all kinds of operations performed on data, such as blocking.
Explicit Consent Consent on a particular subject, based on information and expressed with free will, is expressed.
Suppression It means making personal data inaccessible and unusable for the relevant users in any way.
Deletion It means making personal data inaccessible and unusable for the relevant users in any way.
Anonymization It means that personal data cannot be associated with an identified or identifiable natural person under any circumstances, even if it is matched with other data.
Annihilation It refers to the deletion, destruction or anonymization of personal data.
Data Personal data and special categories of personal data are expressed together.

2. PURPOSE OF THE PRIVACY POLICY

Protecting personal data and complying with the law is our basic principle. Personal data and/or sensitive personal data we receive from you in all our works as IFA LSL FASHION EDUCATION AND CONSULTING LIMITED COMPANY (hereinafter referred to as “IFA LSL” or “Company”) are kept confidential and not shared with third parties. In this context, our company has always shown the necessary sensitivity regarding the protection of personal data and/or sensitive personal data. Again, in accordance with the Law on Protection of Personal Data No. 6698 (hereinafter referred to as “Law” or “KVKK”), our in-house regulations have been re-made; technical and administrative measures were taken. In the ongoing process, as IFA LSL, we accept, declare and undertake to comply with all obligations brought by the law.

  1. SCOPE OF PRIVACY POLICY

This Privacy Policy has been prepared in accordance with the Law on the Protection of Personal Data No. 6698.

Your personal data and/or sensitive personal data are processed with your consent or within the scope of compliance with the law. Your data is used to increase our quality such as;

– Ensuring company security,

– To provide you with a complete service,

– To carry out our commercial activities,

– Quick resolution of your problems,

– It is used to increase our quality.

Some personal data and/or special quality personal data from you are depersonalized and anonymized in accordance with the procedures stipulated by the Law. The data used for statistical purposes are currently not included in the regulation of the Law and the scope of our policy. As IFA LSL, we have the right to change this policy in order to protect personal data within the scope of compliance with the Law.

The privacy policy aims to protect the data obtained by any means of real and legal persons, customers, employees and all other persons with whom IFA LSL is a solution partner. In this context, it includes various regulations in order to achieve the intended target.

BASIC PRINCIPLES OF PROCESSING PERSONAL DATA AND/OR SPECIAL QUALITY PERSONAL DATA

Our basic principles regarding the processing of personal data and/or special categories of personal data are as follows. In this context, these principles will apply to the data that IFA LSL processes based on express consent or within the scope of compliance with the Law.-

Compliance with the Law: IFA LSL questions the source and legality of the personal data and/or sensitive personal data received from natural and legal persons and collected through various means. In this context, it is important for IFA LSL to obtain the data in accordance with the law.

-Compliance with the Rules of Integrity: IFA LSL questions the source of personal data and/or personal data of special nature that it collects from natural and legal persons and collected through various means. In this context, it is important for IFA LSL to obtain data within the framework of honesty rules.

-Limited, Measured and Connected to the Purpose for which they are Processed: IFA LSL uses personal data obtained from various ways and/or special quality personal data in accordance with the purpose for which they are processed, limited for the purpose of processing, measured and to the extent required by the performance of the service.

 – Accuracy of Personal Data and/or Special Quality Personal Data: IFA LSL attaches importance to the fact that the personal data received from natural and legal persons and collected through various means and/or sensitive personal data do not contain false information and are accurate. However, IFA LSL is not obliged to investigate the accuracy of the personal data and/or sensitive personal data declared by its customers or the real and legal persons it is in contact with. Because this is not possible legally and in line with our working principles.

-Updating When Necessary: If there is a change in the personal data obtained in various ways and/or in the personal data of special nature, IFA LSL attaches importance to the communication of the said change to the company and updating the data in case of such changes.

-Processing for Specific and Legitimate Purposes: IFA LSL processes personal data and/or sensitive personal data without the express consent of the data owner or within the framework of exceptions stipulated by law. The purpose of processing each data is specific and personal data processing is not carried out for any illegitimate purpose.

-Preservation for as Long as Required for the Purpose of Processing and/or Envisioned by the Law: IFA LSL stores the personal data and/or sensitive personal data it obtains for the periods stipulated in the relevant laws and/or required for the purpose for which they are processed. When the said purposes are over, it anonymizes, destroys or deletes the data.

  1. DELETING, DESTROYING AND ANNOUNCEMENT OF PERSONAL DATA

Your personal data and/or sensitive personal data will be deleted, destroyed or anonymized when the statute of limitations and storage periods stipulated in the Law expires, the judicial processes are completed or other relevant requirements are terminated. The deletion, destruction and anonymization processes are carried out at the request of the relevant data owner or by IFA LSL ex officio (spontaneously).

  1. PRINCIPLE OF STINGINESS

The principle of stinginess, also known as the principle of maximum savings. Personal data and/or special quality personal data received through various means are transferred to our company’s system. In accordance with the said principle, the data is processed into the system as much as necessary.

The data to be collected by IFA LSL are determined in accordance with the purpose and vary. In this context, data are collected in accordance with the purpose and data that are not parallel to the purpose are not collected. Redundant data other than its purpose is not recorded in the company system, deleted, destroyed or anonymized. However, these data can be used for statistical purposes.

  1. DATA PRIVACY AND SECURITY

As IFA LSL, we attach importance to the confidentiality of your personal data and/or sensitive personal data. In this context, your personal data and/or personal data of special nature that reach our Company by any means are confidential. IFA LSL respects the confidentiality of the data in question at every stage of its commercial activity. In this context, this company’s privacy policy is fully complied with.

Necessary technical and administrative measures are taken to ensure that personal data and/or sensitive personal data collected through various means do not fall into the hands of unauthorized persons, that the rights of the data owner are not harmed, that they are not victims, and that the data is protected. In addition, data protection is requested from third parties with whom we share personal data and/or sensitive personal data in accordance with the law, when necessary. Again, our software programs are updated and constantly renewed. In order to provide a high level of protection, technological requirements are fulfilled and compliance with standards is ensured.

  1. CURRENTITY OF DATA

The principle of timeliness is essential in IFA LSL. Because personal data obtained in various ways and/or special quality personal data can be updated when necessary or upon request. Necessary measures for updating are also taken by IFA LSL.

  1. ACCURACY OF DATA

The principle of accuracy of declared personal data and/or sensitive personal data has been adopted by IFA LSL. IFA LSL is not obliged to investigate the accuracy of personal data and/or sensitive personal data declared by its customers or natural and legal persons with whom it is in contact. Because this is not possible legally and in line with our working principles. In this context, transactions are carried out on the basis that the declared data is correct.

  1. PURPOSE OF PROCESSING PERSONAL DATA AND/OR SPECIAL QUALITY PERSONAL DATA

The processing of personal data and/or sensitive personal data is carried out in line with the purposes in the Clarification Texts of IFA LSL. The aforementioned Clarification Texts may vary according to the personal data processed and/or special quality personal data. Parallel to the difference in the Clarification Texts, the purposes of processing personal data and/or special quality personal data may also vary.

  1. PROCESSING PERSONAL DATA AND/OR SPECIAL QUALITY PERSONAL DATA FOR ADVERTISING PURPOSES

Electronic messages sent for advertising purposes must be approved by the recipient. In this context, e-mails for advertising purposes can only be sent to people with prior consent. The subject in question is also clearly regulated in the “Law on the Regulation of Electronic Commerce” and the “Regulation on Commercial Communication and Commercial Electronic Messages”.

IFA LSL complies with the above-mentioned legislation while sending commercial electronic messages for advertising purposes. Obtaining approval in accordance with the legislation and the details of the approval are also respected. said consent; It can be received in physical environment by all kinds of electronic communication tools or in written form. The basis for the approval is the presence of a positive declaration of will of the recipient of the commercial electronic message that they accept the sending of the commercial electronic message, the presence of the electronic communication address and name-surname.

It includes all commercial electronic messages sent to electronic communication addresses in order to increase the recognition of the contents such as approval from the buyer, marketing, promoting the company’s goods and services, promoting its business, ensuring its recognition, celebration, wish and congratulation etc.

Apart from all these, before sending electronic commercial messages, individuals are informed that their data can be processed and their express consent is obtained when necessary and while sending this commercial message, the provisions of the Law on Protection of Personal Data No. 6698 are complied.

  1. COLLECTION AND PROCESSING OF PERSONAL DATA AND/OR SPECIAL QUALIFIED PERSONAL DATA WITHIN THE CONTRACT RELATIONSHIP

If a contractual relationship is established with customers or prospective customers, personal data collected pursuant to the contract may be processed by IFA LSL without express consent. In the case of processing sensitive personal data, data can be processed based on express consent or legal reasons within the scope of Article 6 of the Law. The said data is used within the framework of the performance of the goods and / or services, the execution of the contract, the execution of the commercial activity. This data can be updated at any time by contacting customers. 

  1. PERSONAL DATA AND/OR SPECIAL DATA PROCESSED THROUGH AUTOMATIC SYSTEMS

Data obtained from information obtained through automated systems without the explicit consent of individuals cannot be used against individuals. IFA LSL complies with the provisions of the relevant legislation in personal data and/or special quality personal data processed through automated systems. 

  1. PERSONAL DATA AND/OR SPECIAL QUALITY PERSONAL DATA OF THE EMPLOYEES OF IFA LSL MODA EĞİTİMİ VE DANIŞMANLIK LİMİTED ŞİRKETİ
  • PROCESSING WITHIN THE FRAMEWORK OF LEGAL OBLIGATIONS:

Personal Data of Employees may be processed by IFA LSL without obtaining the explicit consent of the data controller, in order to have an express provision in the relevant Law on data processing or to fulfill the legal obligation of the data controller.

  • PROCESSING PERSONAL DATA IN ACCORDANCE WITH THE EMPLOYMENT CONTRACT AND WORK RELATIONSHIP:

The personal data of the employees can be processed without the express consent of the employees, within the framework of proportionality, as much as necessary in order to ensure the business relationship between the company and the employees. IFA LSL is committed to the protection and confidentiality of employee data under all circumstances and to take the necessary measures in this regard.

  • PROCESSING PERSONAL DATA IN ACCORDANCE WITH THE EMPLOYMENT CONTRACT AND WORK RELATIONSHIP:

The personal data of the employees can be processed without the express consent of the employees, within the framework of proportionality, as much as necessary in order to ensure the business relationship between the company and the employees. IFA LSL is committed to the protection and confidentiality of employee data under all circumstances and to take the necessary measures in this regard.

  • PERSONAL DATA PROCESSED THROUGH AUTOMATIC SYSTEMS:

Some personal data of employees can be processed in automatic systems. The said data is used in the performance evaluation of the employees, keeping the statistical data, promotions and scoring for the company. Employees have the right to object to unfavorable results. The appeal must be made in accordance with internal company rules and procedures. The objection in question is evaluated within the company.

  • PROCESSING PERSONAL DATA FOR EMPLOYEES’ BENEFIT:

Personal data of employees can be processed by IFA LSL without obtaining explicit consent within the framework of the relationship provided by the employment contract for transactions related to the benefit of the employee. Again, in disputes regarding the business relationship with IFA LSL, the Company may process personal data of employees.

  • INTERNAL TELECOMMUNICATION, INTERNET AND COMMUNICATION:

In order to facilitate the performance of the work, IFA LSL can allocate computers, telephones, cars, applications, software and e-mail to the internal employees. IFA LSL can control and audit the personal data on the vehicles it has allocated. But at this point, IFA LSL also fulfills the necessary Clarification Obligation.

The employee, on the other hand, cannot use the vehicles allocated to him for private purposes. It is obligatory to use it only for the purpose of ensuring the performance of the work. Again, the employee accepts, declares and undertakes that from the beginning of the working relationship with IFA LSL, the vehicles allocated will not contain any data or information other than the work and the necessity of the work.

  1. TRANSFER OF PERSONAL DATA AND/OR SPECIAL QUALITY PERSONAL DATA IN DOMESTIC AND ABROAD

IFA LSL can transfer data within the country and abroad in accordance with the conditions stipulated in the Personal Data Protection Law and within the framework of the principles determined by the Board, within the scope of compliance with the law or with the express consent of the person concerned.

IFA LSL complies with Articles 8 and 9 of Law No. 6698 when transferring personal data and/or sensitive personal data.

  1. SUPERVISION AND PROCESS SECURITY

Necessary technical and administrative measures are taken to ensure that personal data and/or sensitive personal data collected through various means do not fall into the hands of unauthorized persons, that the rights of the data owner are not harmed, that they are not victims, and that the data is protected. In addition, data protection is requested from companies with which we share personal data and/or sensitive personal data within the framework of compliance with the law. Again, our software programs are updated, constantly renewed and developed. In order to provide a high level of protection, all technological requirements are fulfilled and compliance with standards is ensured. In parallel with all these, IFA LSL carries out all necessary internal and external audits for the protection of personal data and/or sensitive personal data. 

  1. NOTIFICATION OF DATA VIOLATIONS

In the event of any data breach, IFA LSL takes immediate action to take action to remedy the breaches reported to it. It takes the necessary measures to minimize the harm of the person concerned. You can apply for notification of violations according to the procedures specified on our company’s website. In addition, if personal data and/or sensitive personal data are obtained from outside by unauthorized third parties, the company notifies the Personal Data Protection Authority directly.

  1. RIGHTS OF THE DATA OWNER RELATED PERSON REQUESTING INFORMATION

The rights of the data owner are stipulated in Article 11 of the Law on the Protection of Personal Data No. 6698. IFA LSL accepts that, pursuant to the law, the data subject has the right to be informed before data processing and to obtain his explicit consent when necessary, to request information about, update, delete, destroy and anonymize the data of the data subject after the data is processed.

 

Related persons regarding their data through the “Information Request Form pursuant to the Law on Protection of Personal Data No. 6698” have the rights of;

a) Learning whether personal data is processed or not,

b) If personal data has been processed, requesting information about it,

c) Learning the purpose of processing personal data and whether they are used in accordance with its purpose,

ç) To know the third parties to whom personal data is transferred in the country or abroad,

d) Requesting correction of personal data in case of incomplete or incorrect processing,

e) Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the law titled “Deletion, destruction or anonymization of personal data”,

f) Requesting notification to third parties to whom personal data has been transferred, that the incomplete or incorrectly processed data has been corrected or that the data has been deleted or destroyed upon the request of the person concerned,

g) Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

h) Requesting the compensation of the damage in case of damage due to the illegal processing of personal data

Information requests made on behalf of someone else will not be answered by the company. If it is determined by IFA LSL that the application made on behalf of another person in the information request is made; all kinds of lawsuits and claims of IFA LSL are reserved. Requests of the person concerned will be answered as soon as possible and no later than thirty days from the date they are received by IFA LSL. If IFA LSL deems it necessary, it will be able to request other information and documents from the applicant.

19.UPDATE

Changes to this Privacy Policy are listed and shown in the table below.

 

Policy Update Date

 

Changes
   

 

IFA LSL MODA EĞİTİMİ VE DANIŞMANLIK LİMİTED ŞİRKETİ