PRIVACY POLICY
Update Date: 20.04.2025

 

1. INTRODUCTION
At TABANLI MAKİNA SANAYİ VE TİCARET LİMİTED ŞİRKETİ, located at İsabey Mah. İsmetiye Cad. No:153/3, 16290, Yıldırım/Bursa (hereinafter referred to as the “COMPANY”), we show utmost sensitivity regarding the security of your personal data. Your personal data is processed and stored by us in accordance with the Law on the Protection of Personal Data No. 6698 (“LPPD”).
By using or visiting the COMPANY’s website (“Website”) and any mobile applications that may be implemented in the future (“Mobile Application”), or any online platforms or physical premises under the control of the COMPANY (collectively referred to as the “Platform”), and by submitting a membership application, you confirm that you have read, understood, and accepted this Privacy Policy (“Policy”).
If any provision contained in the Policy is amended, the updated version of the Policy will be published on the Platforms, including the date of the change. For a period of 30 (thirty) days following such change, we will inform you of the update on the Website via a reasonable and prominently noticeable link.

 

2. INFORMATION AS DATA CONTROLLER
As the COMPANY, in our capacity as the data controller in accordance with the Law on the Protection of Personal Data No. 6698 (“LPPD”) and within the scope of applicable legislation, your personal data will be recorded, stored, updated, disclosed to third parties where permitted by law, transferred, categorized, and processed using methods in compliance with the conditions and principles set forth under the LPPD, within the framework outlined on this page.

 

3. METHODS OF PERSONAL DATA PROCESSING
The personal data you share with the COMPANY may be processed by us either fully or partially, through automatic means or non-automatic methods provided that they are part of a data recording system, by means of collection, recording, storage, alteration, rearrangement—essentially by being subject to any kind of operation performed on the data. Under the scope of the LPPD, any operation performed on the data is considered “processing of personal data.”

 

4. TYPES OF PERSONAL DATA THAT MAY BE PROCESSED
The COMPANY collects specific personal data in the following cases: when purchasing products and/or services from the COMPANY, placing order requests, creating orders, requesting information regarding products and services, visiting COMPANY locations, fairs and similar promotional stands or liaison offices, becoming a member of any Platform owned by the COMPANY, performing transactions through these Platforms, participating in events through these Platforms, obtaining information, subscribing to newsletters, or engaging in commercial transactions. This also includes data related to your participation in such activities and data obtained from third-party platforms through which you interact with the COMPANY. Additionally, some data about your device and your interactions with or time spent on specific sections of the Platform is collected automatically.
To better understand the data we collect, please refer to the examples below:

 

Customer Data: Within the framework of the relevant provisions of the Turkish Commercial Code No. 6102, the Turkish Code of Obligations No. 6098, the Turkish Civil Code No. 4721, and other
applicable legislation, we collect and store the following data from individuals who purchase products and/or services from the COMPANY, place order requests, create orders, and/or request information regarding products or services: full name, national ID number, gender, date of birth, residential address, phone number, email address, educational background, professional details, company information, company executive information, executive title, and other data deemed necessary within the scope of the COMPANY’s commercial activities.

 

Shared Content: You may interact with others and share content publicly, including posting comments on social media or web pages related to the COMPANY’s activities, asking or answering questions, sending messages to COMPANY accounts, COMPANY executives or employees, customers, suppliers, sponsors, organizers, or business partners, or posting photos and other works you upload. Such shared content may be visible to others depending on where it is published.
User and Visitor Data: When you register for or participate in Platforms or any COMPANY activities, or when you purchase products and/or services from the COMPANY, we collect specific data, including your interaction with the COMPANY and additional information needed to fulfill services offered.

 

Payment Data: We collect data related to payments made via the Platforms (your name-surname, information related to the payment service you used, your address). Certain billing and payment data such as your name-surname, national ID number, credit card information, billing address, and postal code must be provided directly to our payment processing partners. For security reasons, the COMPANY does not collect or store full credit card numbers or sensitive cardholder data such as card verification values.

 

Business Partner Data: If you are a COMPANY customer, executive, employee, consultant, business partner, sponsor, or supplier, we may collect and store personal data related to your payment account. For security purposes, the COMPANY does not collect or store sensitive bank account details. The collection, use, and disclosure of your payment and billing information is subject to this Policy and the terms of your payment account provider.

 

Data About Other Accounts: If your user accounts related to COMPANY Platforms are linked to another account, we may obtain certain information from your social media or other online accounts. If you log into the Platforms via Facebook or another third-party platform or service, we will ask your permission to access specific information associated with that account. Depending on the platform or service, we may collect your name, profile photo, account ID, login email address, location, the physical location of your access devices, gender, date of birth, and your friend or contact list. These platforms and services provide us this information via their APIs. The information we receive depends on your privacy settings or the information the platform or service chooses to provide us.

 

Surveys, Promotions, and Contests: We may invite you to complete a survey or participate in a promotion (such as a contest or giveaway) via the Platforms or a third-party platform. If you choose to participate, we collect and store the data you provide as part of your participation, such as your name, national ID number, address, email address, birth date, or phone number. Unless otherwise stated in the official rules of the promotion or another privacy policy, such data is subject to the terms of this Policy. The data collected will be used to manage the promotion or survey, including notifying winners and distributing prizes. You may be required to permit the publication of some of your data (e.g., on a winners’ list) to claim a prize. If a third-party platform is used to manage a survey or promotion, that party’s privacy policy will apply.

 

Communication and Support: If you contact us for support or to report a problem or concern (regardless of whether you have an account), we collect and store communication information such as your messages, name, email address, location, operating system, IP address, and any other information you provide or that we collect through automated means (as outlined below). We use this data to respond to you in accordance with this Policy and to resolve your concern through investigation and reply.

 

5. PURPOSES OF PERSONAL DATA PROCESSING
The personal data you share may be processed in accordance with secondary regulations related to the LPPD for the following purposes:
• To fulfill the services we offer to you and the services offered within the scope of activities carried out in cooperation with our business partners, and to facilitate the execution of such services;
• To communicate with you and to manage our promotional and awareness activities;
• To provide information to public prosecutors, courts, and relevant public officials in cases concerning public security or legal disputes, upon request and as required by legislation;
• To provide you with a broad range of opportunities or to share such opportunities with individuals or institutions capable of providing them, within the legal framework.

 

6. METHODS OF COLLECTING PERSONAL DATA
Your personal data may be collected through the following means:
• From forms on the Website, Mobile Applications, or other Platforms, including: name-surname, national ID number, gender, date of birth, residential address, phone number, email address, educational background, professional details, company information, authorized person details, and title information; also from data such as user preferences on login-required pages, IP logs of actions performed, browser-generated cookie data, browsing time and details, and location data;
• Through verbal, written, or electronic means via our channels such as events and consultation activities, paper forms, business cards, and digital environments;
• From individuals who share their personal data with the COMPANY in order to establish a relationship, apply for user registration on COMPANY platforms, submit job applications, submit proposals, or for other similar purposes, either in physical or virtual environments, face-to-face or remotely, verbally, in writing, or electronically;
• Additionally, from publicly available sources and third-party platforms, including data obtained through indirect channels such as websites, blogs, contests, surveys, games, campaigns, and similar (micro) websites and social media platforms (Facebook, Twitter, Google, Instagram, Snapchat, etc.), including shared profile and data that is made publicly available; from email newsletter open and click data; from public databases; and from open profile information on social media platforms.

 

7. TRANSFER OF PERSONAL DATA
The COMPANY may transfer your personal data, within the legal framework and for the purposes and operational fields specified in this Policy, in order to: provide benefits and opportunities completely and on time; inform users of the COMPANY’s Platforms about the specific and limited opportunities provided to them; properly fulfill the requirements of the services provided to members, non-member beneficiaries, and other stakeholders; improve the services and activities provided; and ultimately act in favor of the individuals using the Platforms.

 

Personal data may also be transferred in order to:

 

• Fulfill the obligation to record identity, address, and other necessary information of the transaction owner;
• Comply with information retention, reporting, and disclosure obligations stipulated by legislation and authorities;
• Provide information to official institutions and relevant public officials, primarily judicial authorities, in matters related to public security or legal disputes, upon request and as required by law;
• Offer users a broad range of opportunities or share such opportunities with individuals or institutions who may provide them.

 

In this context, your personal data may be transferred under the conditions and purposes outlined in Articles 8 and 9 of the LPPD to:

• Business partners, supplier companies, banks, financial institutions, the Risk Center of the Banks Association of Turkey (TBB), and other real or legal persons, for the provision, promotion, and development of services;
• Authorized authorities who may determine your location in emergency situations;
• Lawyers, auditors, consultants, and other third parties from whom services are received;
• Your authorized representatives and agents;
• Regulatory and supervisory authorities, courts, enforcement offices, and other official institutions, as well as other public institutions and organizations authorized to request your personal data;
• Legal entities who are in any kind of relationship with the COMPANY and have access to your phone number;
• Banks or similar financial institutions, during banking or financial transactions made via your mobile lines, for transaction and information security and identity verification purposes (e.g., SIM card changes, the phone number connected to mobile internet);
• Business partners, sponsors, and event organizers responsible for the execution of events and organizations.
Your personal data, collected through any of the aforementioned methods, may be transferred abroad—either to be processed in Turkey or stored after being processed outside of Turkey—provided that such countries (as accredited by the Personal Data Protection Board) have adequate levels of data protection and the transfer is made in compliance with the LPPD and for contract-related purposes.

 

8. STORAGE AND PROTECTION OF PERSONAL DATA
The COMPANY takes appropriate and reasonable technical and organizational measures to prevent the loss, misuse, or alteration of your personal data.
In accordance with Article 12 of the LPPD, the COMPANY is obligated to prevent unlawful processing of personal data, to block unauthorized access to such data, and to ensure their safe retention in the systems and databases where they are stored.
Given the inherent risks of internet-based data transmission, the COMPANY cannot guarantee the security of data transmitted over the internet, despite taking all reasonable precautions. However, the COMPANY will take all necessary technical and organizational measures under ordinary circumstances to ensure the security of such data.
If it is discovered that personal data has been unlawfully obtained by others, the situation will be promptly reported to the Personal Data Protection Board in writing, in accordance with legal regulations.

 

9. KEEPING PERSONAL DATA UP-TO-DATE
Pursuant to Article 4 of the LPPD, the COMPANY has the obligation to keep your personal data accurate and up-to-date. Within this scope, individuals who share their personal data with the COMPANY must provide accurate and current information or update their data in a timely manner via the Platform used, so that the COMPANY can fulfill its obligations under applicable legislation.
In cases where personal data is not verified and/or not updated, the processes by which users benefit from the services and opportunities provided on the Platforms may be temporarily or permanently suspended by the COMPANY.

 

10. RIGHTS OF THE PERSONAL DATA SUBJECT
Pursuant to Article 11 of the LPPD, as the personal data subject, your rights are as follows:
a) To learn whether your personal data is being processed or not; if so, to request information regarding such processing,
b) To learn the purpose of processing your personal data and whether it is being used in accordance with that purpose,
c) To know the third parties to whom your personal data is transferred domestically or abroad,
d) To request correction if your personal data has been processed incompletely or incorrectly,
e) To request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the LPPD,
f) To request that the operations carried out pursuant to subparagraphs (d) and (e) be notified to third parties to whom your personal data has been transferred,
g) To object to any outcome that is unfavorable to you as a result of your personal data being analyzed exclusively by automated systems,
h) To demand compensation in case you incur damage due to your personal data being processed in violation of the LPPD.

 

11. APPLICATION
The COMPANY is the data controller within the scope of the LPPD. Once the legal infrastructure is established, the designated data controller representative will be announced on the Platform where this document is published. Personal data subjects may submit their questions, opinions, or requests via e-mail to info@tabanli.com or by post or in person to the authorized representative of the COMPANY located at İsabey Mah. İsmetiye Cad. No:153/3, 16290, Yıldırım/Bursa.
Requests must be submitted using the Application Form, which can be obtained via info@tabanli.com or through the Platforms. The COMPANY may respond to such requests, either affirmatively or negatively, in writing or digitally within thirty (30) days, provided that it includes a justification. In principle, the required procedures regarding such requests shall be free of charge. However, if the procedure incurs a cost, the COMPANY reserves the right to request a fee. Such fees shall be determined in accordance with the tariff set by the Personal Data Protection Board pursuant to Article 13 of the Law on the Protection of Personal Data.
By sharing your personal data on the Website, Mobile Applications, or other Platforms, you declare that you accept the terms herein regarding the processing, method of processing, transfer, sale, and other related matters regarding your personal data; that you will apply to the COMPANY before exercising your legal rights; and that you accept these conditions with your express consent as defined in the LPPD as “consent that is related to a specific subject, based on information, and expressed with free will.”

 

TABANLI MAKİNA SANAYİ VE TİCARET LİMİTED ŞİRKETİ
İsabey Mah. İsmetiye Cad. No:153/3, 16290, Yıldırım/Bursa
info@tabanli.com
+90 224 371 4020

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DISCLOSURE STATEMENT
Update Date: 20.04.2025

The company titled TABANLI MAKİNA SANAYİ VE TİCARET LİMİTED ŞİRKETİ, located at İsabey Mah. İsmetiye Cad. No:153/3, 16290, Yıldırım/Bursa (hereinafter referred to as the “COMPANY”), provides below the basic information regarding the protection of your personal data that is transferred to or obtained by our Company.

 

The detailed explanations below are presented to the attention of individuals who use our website and/or mobile applications, especially members, business partners, employees, consultants, individuals who visit our communication and promotion points such as fairs and attend similar events, and individuals who visit our service locations or connect to our network, in order to fulfill the disclosure obligation arising from Article 10 of the Law on the Protection of Personal Data No. 6698 (“LPPD”).

The COMPANY reserves the right to update this Disclosure Statement, which has been prepared in accordance with the provisions of the applicable legislation and duly published, at any time within the framework of changes that may be made in the applicable legislation. In such cases, changes and updates regarding the Disclosure Statement will also be specified on our websites and mobile applications. In addition, it will also be shared with you via e-mail.

 

Personal data shared with the COMPANY is under the supervision and control of the COMPANY. The COMPANY, as the data controller, assumes responsibility to establish the necessary organization and to take and implement technical measures to ensure the protection of information confidentiality and integrity in accordance with the provisions of the applicable legislation. We would like to inform you that we are aware of our obligations in this regard and we have periodic penetration tests carried out in compliance with national and international technical standards on data privacy, and that we continuously update our data processing policies accordingly.

 

1. LEGAL BASIS FOR THE COLLECTION OF PERSONAL DATA
As the COMPANY, we carry out activities in accordance with the provisions of the applicable legislation regarding the processing of personal data. Primarily, we act in compliance with the provisions of the LPPD, which sets out the general principles regarding the protection of personal data, as well as the provisions of the Turkish Penal Code No. 5237, which prescribes criminal sanctions in some cases for the protection of personal data, and other applicable legislative provisions that are applicable to the COMPANY’s business operations.

 

2. METHOD OF COLLECTING PERSONAL DATA
When you contact us through any channel (including but not limited to our website (“Website”), mobile applications that may be implemented in the future (“Mobile Application”), and any kind of online platform or physical location under the control of the COMPANY (hereinafter referred to as the “Platform”), when you purchase services or products from the COMPANY, when you request to participate in our events and promotional activities, or when you visit our Platforms, the personal data you provide is processed by the relevant departments of the COMPANY with your consent and in accordance with legal regulations, within the scope of this Disclosure Statement and the Privacy Policy available on our Website.

 

3. AREAS WHERE PERSONAL DATA IS USED
The sharing of personal data obtained by the COMPANY in accordance with the applicable legislation with third parties is carried out either with the consent of the personal data subjects in accordance with the legislative provisions or within the scope of exceptions provided in the applicable legislation.
Personal data is not shared with third parties in a manner contrary to the applicable legislative provisions, except in cases required for the performance of services or business processes.
However, due to our legal obligations and limited to these, personal data is shared with courts and other public institutions. In addition, to fulfill our commitments, to conduct more efficient analysis related to the services provided, to perform statistical studies, and to conduct quality control of the Platforms, personal data may be transferred to third parties we have agreements with. In such cases, the transferred personal data is anonymized.
During the transfer of data to third parties, necessary technical and legal measures are taken to prevent rights violations. However, the COMPANY is not responsible for any violations that occur in the risk area under the responsibility of the third party receiving the data due to their data protection policies.
Your personal data may be shared with the COMPANY’s administrators, direct/indirect domestic/international suppliers, business partners, supporters, individuals supporting projects carried out on the Platforms, program partner institutions and organizations with whom we collaborate to carry out our activities, domestic/international persons and institutions from whom we receive data storage services in the cloud environment, domestic/international organizations we cooperate with for the sending of commercial electronic messages regardless of their connection to Platform activities, the Interbank Card Center, contracted banks, and various agencies and survey companies located domestically and abroad for various promotional and awareness activities, and other domestic/international third parties and relevant business partners.

 

4. PURPOSES OF PROCESSING PERSONAL DATA
Your personal data obtained by the COMPANY may be processed for the following purposes:
• To verify and confirm the identity information of individuals who register on the Platforms under the control of the COMPANY, including the website and/or mobile applications, and to keep updated the information of individuals who place or request orders;
• To record address and other necessary contact information of individuals who cooperate, act as project partners, make or receive donations and support, participate in events, or engage in transactions under any contract with the COMPANY;
• To contact individuals who use or visit the Platforms regarding the conditions, current status, and updates of any agreement, written or oral, and to provide them with necessary information;
• To organize all records and documents that may be the basis for processing either electronically (internet/mobile, etc.) or on paper;
• To fulfill obligations undertaken by the COMPANY or arising from the nature of the business in accordance with the provisions of the applicable legislation;
• To provide information to public officials in cases related to public safety upon request from relevant institutions and in accordance with the legislation;
• To provide a better experience for our administrators, board and commission or committee members, business partners, employees, consultants, users and visitors of the Platforms;
• To determine the needs of individuals using and/or visiting the Platforms, to identify main focus points, and to evaluate areas of interest;
• To inform supporters or individuals in need who use the Platform about services and support details available on the Platforms, and to communicate campaigns;
• To maximize the ability to meet the needs of individuals using the Platform and increase satisfaction levels;
• To identify supporters and those in need, to conduct social environment analyses, to use such anonymized analyses in various marketing and advertising activities, and to conduct surveys electronically and/or physically through contracted organizations;
• To provide suggestions regarding our services through our contracted institutions and solution partners and to inform relevant individuals;
• To evaluate complaints and suggestions from Platform users regarding our services;
• To fulfill our legal obligations and exercise our rights arising from the applicable legislation;
• To prevent any kind of unlawful activity, especially fraud.

 

5. RIGHTS OF PERSONAL DATA SUBJECTS
Pursuant to Article 11 of the LPPD, we would like to remind you that you have the following rights:
a) To learn whether your personal data is being processed or not; if it has been processed, to request information regarding it,
b) To learn the purpose of processing your personal data and whether it is being used in accordance with that purpose,
c) To know the third parties to whom your personal data is transferred domestically or abroad,
d) If your personal data has been processed incompletely or incorrectly, to request its correction,
e) To request the deletion or destruction of your personal data within the framework of the conditions stipulated in Article 7 of the LPPD,
f) To request notification of the operations performed in accordance with subparagraphs (d) and (e) to third parties to whom your personal data has been transferred,
g) To object to the occurrence of a result against yourself due to your personal data being analyzed exclusively through automated systems,
h) To request the compensation of the damage in case you incur a loss due to your personal data being processed in violation of the LPPD.

 

6. CONSENT
If you share your personal data by contacting the COMPANY in any way, you are deemed to have consented, in accordance with the explanations above and within the scope of the Privacy Policy and the LPPD, to the collection, processing, updating, periodic checking, storage in a database and retention of your personal data by the COMPANY, and to the sharing of your personal data with the institutions and organizations specified in Article 4, and to its retention and storage by these entities as well.

 

7. APPLICATION
Personal data subjects may submit their questions, opinions, or requests via e-mail to info@tabanli.com or by post or in person to the authorized representative of the COMPANY located at İsabey Mah. İsmetiye Cad. No:153/3, 16290, Yıldırım/Bursa. Applications must be made using the Application Form that can be obtained from the COMPANY via its e-mail address or through the Platforms.
This notification has been prepared in order to fulfill the disclosure obligation pursuant to Article 10 of the LPPD.

 

TABANLI MAKİNA SANAYİ VE TİCARET LİMİTED ŞİRKETİ
İsabey Mah. İsmetiye Cad. No:153/3, 16290, Yıldırım/Bursa
info@tabanli.com
+90 224 371 4020