GENERAL CLARIFICATION TEXT REGARDING
PROCESSING PERSONAL DATA

As Bc Fiber Optik San. Ve Tic. A.Ş. (“BC Fiber”), we have prepared this clarification text in order to inform you, our Visitors, Online Visitors, Customers, Potential Customers, Supplier Employees, and Supplier Authorities regarding the processing, storage and transfer of your personal data within the framework of the activities arising from the Law on the Protection of Personal Data No.6698 ("LPPD")  and the relevant legislation and legal regulations.

1) What Are Your Categories of Personal Data We Process and For What Purposes Do We Process Them?
Your personal information may be processed by Bc Fiber Optik San. Ve Tic. A.Ş in accordance with the following principles stipulated in article 4.2 of the LPPD, within the scope of our ongoing business relations with our business partners (it is possible for a person to be included in more than one category) for the purposes stated below:  

(i) Processing in accordance with the law and the rules of fairness,
(ii) Keeping them accurate and up-to-date when necessary,
(iii) Processing for specific, clear, and legitimate purposes,
(iv) Being limited, proportional and expedient to purpose of data processing,
(v) Retaining Personal Data for the Period Required for the Purpose stipulated in the Legislation or for the Purpose for Which They were Processed

A) Our Visitors
Identity information of our visitors (e.g.:name, surname), physical location security information (e.g. camera recordings) will be processed for the following purposes;

ensuring physical space security.

B) Our Online Visitors
Transaction security information of our online visitors using our website (eg. your IP address information), marketing information (e.g. shopping history information, cookie records) and (if you let us know*) identification information, contact information (e.g. your email address) will be processed for the following purposes;

a) Conducting activities in compliance with legislation,
b) Execution of information security processes,
c) Tracking of requests / complaints,
d) Conducting communication activities,
e) Providing information to authorized persons, institutions and organizations,
f) Ensuring you to access our website via the internet.

C) Our Customers
Identity information, contact information, customer transaction information (e.g. order information), physical place security information, financial information (e.g. balance sheet information), legal transaction information, marketing information (eg, shopping history information) of our natural person customers or legal entity customers' officials and/or employees will be processed for the following purposes;

▬ Conducting activities in compliance with legislation,
▬ Conducting financial and accounting works,
▬ Execution / supervision of business activities,
▬ Execution of logistics activities,
▬ Execution of goods / services after sales support services,
▬ Execution of goods / service sales processes,
▬ Execution of marketing analysis activities,
▬ Execution of contract processes,
▬ Providing information to authorized persons, institutions and organizations,
▬ Ensuring physical place security,
▬ resolution of legal disputes,
▬ Execution of storage and archive activities,
▬ Execution of risk management processes,
▬ Execution of loyalty processes to company/products/services,
▬ Conducting communication activities.

D) Our Potential Customers                            
Identity information, contact information, customer transaction information, physical place security information, marketing information of the officials and/or employees of our real person customers or legal entity customers will be processed for the following purposes;

a) Managing goods/service sales processes,
b) Execution of contract processes,
c) Ensuring physical place security,
d) Execution of marketing analysis activities,

E) Our Supplier Employee
Identity information, contact information, physical place security information, professional experience information of our supplier employees (eg, on-the-job training information) will be processed for the following purposes;

▬ Conducting communication activities,
▬ Execution / supervision of business activities,
▬ Ensuring physical place security,
▬ Execution of supply chain management processes,
▬ Execution of logistics activities,
▬ Conducting activities in compliance with legislation,
▬ Conducting occupational health / safety activities.

F) Our Supplier Official
Identity information, contact information, physical place security information, customer transaction information, financial information, marketing information, legal transaction information of our real person suppliers or legal entity supplier officials will be processed for the following purposes;

Execution / supervision of business activities,
Execution of goods/service purchase processes,
Conducting financial and accounting works,
Execution of contract processes,
Execution of investment processes,
Ensuring physical place security,
Following up and conducting legal affairs.

2) What are the Collection Methods of Your Personal Data?
Your personal data specified in the above categories are collected automatically or non-automatically through physical means such as order forms, contracts, visitor forms, or information systems and electronic devices (e.g. telecommunication infrastructure, computers and telephones), third parties (e.g. KKB and Findeks), our website and other documents declared by the person concerned. 

3) What is the Legal Reason for Collecting Your Personal Data?
Your personal data are processed by Bc Fiber Optik San. Ve Tic. A.Ş in accordance with the following principles stipulated in article 5 of the LPPD for realization of the purposes described above: 

(i) Clearly stipulated by the laws,
(ii) Provided that it is directly related to drawing up or performing a contract, it is required to process personal data of the parties of the contract,
(iii) If it is required for the data controller to fulfill his/her legal obligation,
(iv) Data processing is mandatory for the establishment, exercise or protection of a right,
(v) Provided that it does not harm the fundamental rights and freedoms of the relevant person, it is an obligation to process data for legitimate interests of the data controller.

4) Do We Transfer Your Personal Data to a Third Party?      
a) Personal data of our visitors may be shared with law enforcement and judicial authorities, upon request, in order to resolve legal disputes and in accordance with the relevant legislation.
b) Personal data of our online visitors may be shared with judicial authorities and authorized public institutions and organizations, when requested, for the purpose of resolving legal disputes and in accordance with the relevant legislation.
c) Personal data of our customers are transferred to authorized public institutions and organizations in order to provide information to authorized persons, institutions and organizations to carry out the activities in accordance with the legislation, within the scope stipulated by the regulations, to follow-up and execution of legal affairs; and also transferred to our group companies, IT companies, suppliers, cargo companies, insurance companies, banks and our financial advisors to the extent necessary in order to conduct/audit business activities, carry out risk management processes, and perform our services properly. In addition, the said personal data may be transferred to the law firm and judicial authorities from which we receive services so that they can be used as evidence in legal disputes that may arise in the future.
d) Personal data of our potential customers may be transferred to the law firm and judicial authorities from which we receive services in order to be used as evidence in future legal disputes.
e) Personal data of our supplier employee are transferred to authorized public institutions and organizations within the scope stipulated by the regulations, for the purposes of carrying out activities in accordance with the legislation, following and executing legal affairs, informing authorized persons, institutions and organizations, conducting / auditing business activities and as necessary, transferred to group companies, IT companies, suppliers, cargo companies, banks and our financial advisors for the proper performance of the service. In addition, the said personal data may be transferred to the law firm and judicial authorities from which we receive services so that they can be used as evidence in legal disputes that may arise in the future.

Personal data of our supplier officer are transferred to authorized public institutions and organizations within the scope stipulated by the regulations, for the purposes of carrying out activities in accordance with the legislation, following and executing legal affairs, informing authorized persons, institutions and organizations, conducting / auditing business activities and as necessary, transferred to group companies, IT companies, suppliers, cargo companies, banks and our financial advisors for the proper performance of the service. In addition, the said personal data may be transferred to the law firm and judicial authorities from which we receive services so that they can be used as evidence in legal disputes that may arise in the future.

5) How Can You Exercise Your Rights Regarding Your Personal Data?
You can send your requests within the scope of Article 11 of the LPPD, which regulates the rights of the relevant persons, to us through the "Form for Application to Data Controller" prepared for your convenience on the website https://www.bcfiber.com/ of Bc Fiber Optik San. Ve Tic. A.Ş. in accordance with the "Communiqué on the Procedures and Principles of Application to Data Controller".     

Data Controller: Bc Fiber Optik San. Ve Tic. A.Ş.
Address: Halil Rıfat Paşa Mah. Yüzer Havuz Sokak Erpa Tic. Merkezi A Blok Kat 11 No:1588 Şişli/İstanbul
E-Mail: kvkk@bcfiber.com