Privacy Policy

 

We greatly appreciate your interest in our company. Data protection is of paramount importance to the management of ILVEA IC VE DIS TICARET LDT. STI. The use of the ILVEA IC VE DIS TICARET LDT. STI. website is possible without any indication of personal data; however, if a data subject wants to use special services via our website, processing of personal data could become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

 

The processing of personal data, such as the name, address, email address, or telephone number of a data subject, shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to ILVEA IC VE DIS TICARET LDT. STI. By means of this data protection declaration, our company would like to inform the public of the nature, scope, and purpose of the personal data we collect, use, and process. Furthermore, data subjects are informed, by means of this data protection declaration, of the rights to which they are entitled.

 

As the controller, ILVEA IC VE DIS TICARET LDT. STI. has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g., by telephone.

 

1. Definitions

 

The data protection declaration of ILVEA IC VE DIS TICARET LDT. STI. is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our data protection declaration should be legible and understandable to the public, as well as to our customers and business partners. To ensure this, we would like to first explain the terminology used.

 

In this data protection declaration, we use, inter alia, the following terms:

 

 a) Personal data

Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 

b) Data subject

Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymization

Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

 

h) Processor

Processor is a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

 

i) Recipient

Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall follow the applicable data protection rules according to the purposes of the processing.

j) Third party

Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.

k) Consent

Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

 

2. Name and Address of the Data Controller

 

The data controller within the meaning of the General Data Protection Regulation, other data protection laws applicable in the member states of the European Union, and other provisions related to data protection is:

 

ILVEA IC VE DIS TICARET LDT. STI.

HACI ISA MAH. 75. YIL CUMHURIYET CAD. NO: 5/2

35430 Urla – IZMIR

TURKEY

 

VAT ID: NL826803039B01

Email: hello@ilvea.de

Website: www.ilvea.de

 

 

3. Cookies

 

The ILVEA IC VE DIS TICARET LDT. STI. website uses cookies. Cookies are text files that are stored and saved on a computer system via an internet browser.

 

Many websites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which websites and servers can be assigned to the specific internet browser in which the cookie was stored. This allows visited websites and servers to differentiate the individual browser of the data subject from other internet browsers that contain other cookies. A specific internet browser can be recognized and identified via the unique cookie ID.

 

By using cookies, ILVEA IC VE DIS TICARET LDT. STI. can provide users of this website with more user-friendly services that would not be possible without the cookie setting.

 

With a cookie, the information and offers on our website can be optimized with the user in mind. As mentioned above, cookies allow us to recognize the users of our website. The purpose of this recognition is to make it easier for users to utilize our website. The website user that uses cookies, e.g. does not have to enter access data each time the website is accessed because this is taken over by the website, and the cookie is thus stored on the user’s computer system. Another example is the cookie of a shopping cart in an online shop. The online store remembers the articles that a customer has placed in the virtual shopping cart via a cookie.

 

The data subject can, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an internet browser or other software programs. This is possible in all popular internet browsers. If the data subject deactivates the setting of cookies in the internet browser used, not all functions of our website may be entirely usable.

 

4. Collection of General Data and Information

 

The ILVEA IC VE DIS TICARET LDT. STI. website collects a series of general data and information with each call-up of the website by a data subject or an automated system. This general data and information are stored in the server log files. Collected may be (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrers), (4) the sub-websites, (5) the date and time of access to the Internet site, (6) an Internet protocol address (IP address), (7) the Internet service provider of the accessing system, and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.

 

When using these general data and information, ILVEA IC VE DIS TICARET LDT. STI. does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the content of our website correctly, (2) optimize the content of our website as well as its advertisement, (3) ensure the long-term viability of our information technology systems and website technology, and (4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, ILVEA IC VE DIS TICARET LDT. STI. analyzes anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our enterprise, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

 

5. Subscription to Our Newsletter

 

On the ILVEA IC VE DIS TICARET LDT. STI. website, users are provided with the option to subscribe to our company’s newsletter. The personal data transmitted to the data controller when ordering the newsletter is determined by the input mask used for this purpose.

 

ILVEA IC VE DIS TICARET LDT. STI. regularly informs its customers and business partners about the company’s offers through a newsletter. In general, the newsletter of our company can only be received by the data subject if (1) the data subject has a valid email address and (2) the data subject registers for the newsletter dispatch. For legal reasons, a confirmation email is sent to the email address first entered by a data subject for the newsletter dispatch, using the double opt-in procedure. This confirmation email is used to verify whether the owner of the email address, as the data subject, has authorized the receipt of the newsletter.

 

When registering for the newsletter, we also store the IP address assigned by the Internet service provider (ISP) to the data subject’s computer system at the time of registration, as well as the date and time of registration. The collection of this data is necessary in order to trace any potential misuse of a data subject’s email address at a later time and serves the legal protection of the data controller.

 

The personal data collected as part of a newsletter registration will only be used for sending our newsletter. Furthermore, subscribers to the newsletter may be informed by email if this is necessary for the operation of the newsletter service or for registration purposes, as might be the case in the event of changes to the newsletter offering or changes in technical circumstances. The personal data collected within the framework of the newsletter service will not be passed on to third parties. Subscription to our newsletter can be canceled by the data subject at any time. The consent to the storage of personal data, which the data subject has given us for sending the newsletter, can be revoked at any time. There is a corresponding link in each newsletter for the purpose of revoking consent. Furthermore, it is also possible to unsubscribe from the newsletter at any time directly on the data controller’s website or to communicate this to the data controller in another way.

 

6. Newsletter Tracking

 

The newsletters of ILVEA IC VE DIS TICARET LDT. STI. contain so-called tracking pixels. A tracking pixel is a miniature graphic embedded in such emails that are sent in HTML format to enable log file recording and log file analysis. This allows a statistical evaluation of the success or failure of online marketing campaigns. By means of the embedded tracking pixel, ILVEA IC VE DIS TICARET LDT. STI. can recognize whether and when an email was opened by a data subject and which links in the email were clicked on by the data subject.

 

Such personal data collected via the tracking pixels contained in the newsletters is stored and analysed by the data controller to optimize the newsletter dispatch and to better tailor the content of future newsletters to the interests of the data subject. This personal data will not be passed on to third parties. Data subjects are at all times entitled to revoke their separate declaration of consent via the double opt-in procedure. After a revocation, this personal data will be deleted by the data controller. Unsubscribing from the newsletter is automatically interpreted as a revocation by ILVEA IC VE DIS TICARET LDT. STI.

 

7. Contact Options via the Website

 

The website of ILVEA IC VE DIS TICARET LDT. STI., in compliance with legal regulations, provides information that enables quick electronic contact with our company and direct communication with us, including a general electronic mail (email) address. If an individual contacts the data controller via email or through a contact form on the website, the personal data transmitted by the individual will be automatically stored. Such personal data voluntarily provided by an individual to the data controller will be stored for the purposes of processing or communicating with the individual. There is no sharing of this personal data with third parties.

 

8. Routine Deletion and Blocking of Personal Data

 

The data controller processes and stores personal data of the data subject only for the period necessary to achieve the purpose of storage or as required by the European legislator or another competent legislator in laws or regulations to which the data controller is subject. When the purpose of storage no longer applies or when a storage period prescribed by the European legislator or another relevant legislator expires, the personal data will be routinely blocked or deleted in accordance with legal regulations.

 

9. Rights of the Data Subject

a) Right to Confirmation

Every data subject has the right granted by the European legislator to request confirmation from the data controller as to whether personal data concerning them is being processed. If a data subject wishes to exercise this right of confirmation, they can contact our Data Protection Officer or another employee of the data controller at any time.

b) Right to Information

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain, at any time, free information from the data controller about the personal data stored about them and to receive a copy of this information. Furthermore, the European legislator has granted the data subject the right to receive information about the following:

– The purposes of the processing

– The categories of personal data being processed

– The recipients or categories of recipients to whom the personal data has been or will be disclosed, particularly recipients in third countries or international organizations

– Where possible, the planned duration for which the personal data will be stored, or, if not possible, the criteria for determining this duration

– The existence of the right to rectification or erasure of personal data concerning them or to restriction of processing by the data controller, as well as the right to object to such processing

– The right to lodge a complaint with a supervisory authority

– If the personal data is not collected from the data subject: all available information about the source of the data

– The existence of automated decision-making, including profiling, in accordance with Article 22(1) and (4) of the GDPR, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

c) Right to Rectification

Every data subject affected by the processing of personal data has the right, as granted by the European legislator, to request the immediate correction of inaccurate personal data concerning them. Furthermore, the data subject has the right to request the completion of incomplete personal data, considering the purposes of the processing, by means of a supplementary statement.

If a data subject wishes to exercise this right of rectification, they can contact our Data Protection Officer or another employee of the data controller at any time.

d) Right to Erasure (Right to be Forgotten)

Every data subject affected by the processing of personal data has the right, as granted by the European legislator, to demand from the data controller the immediate erasure of personal data concerning them, if one of the following reasons applies and the processing is not necessary:

– The personal data is no longer needed for the purposes for which it was collected or otherwise processed.

– The data subject withdraws consent on which the processing is based according to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, and there is no other legal ground for the processing.

– The data subject objects to the processing pursuant to Article 21(1) GDPR, and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) GDPR.

– The personal data has been unlawfully processed.

– The erasure of personal data is necessary to comply with a legal obligation under Union or Member State law to which the data controller is subject.

– The personal data has been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

 

If one of the reasons applies, and a data subject wishes to request the erasure of personal data stored by ILVEA IC VE DIS TICARET LDT. STI., they can contact our Data Protection Officer or another employee of the data controller at any time. The Data Protection Officer of ILVEA IC VE DIS TICARET LDT. STI. or another employee will ensure that the erasure request is complied with promptly.

 

Where personal data has been made public by ILVEA IC VE DIS TICARET LDT. STI., and our company is obliged to erase personal data as the data controller pursuant to Article 17(1) GDPR, ILVEA IC VE DIS TICARET LDT. STI., considering available technology and the cost of implementation, will take reasonable steps, including technical measures, to inform other data controllers processing the published personal data that the data subject has requested erasure by such data controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. The Data Protection Officer of ILVEA IC VE DIS TICARET LDT. STI. or another employee will arrange the necessary in individual cases.

e) Right to Restriction of Processing

Every data subject affected by the processing of personal data has the right, as granted by the European legislator, to request the data controller to restrict processing under the following conditions:

– The accuracy of the personal data is contested by the data subject for a period enabling the data controller to verify the accuracy of the personal data.

– The processing is unlawful, and the data subject opposes the erasure of the personal data and requests instead the restriction of their use.

– The data controller no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise, or defence of legal claims.

– The data subject has objected to processing pursuant to Article 21(1) GDPR, pending the verification whether the legitimate grounds of the data controller override those of the data subject.

 

f) Right to Data Portability

Every data subject affected by the processing of personal data has the right, as granted by the European legislator, to receive the personal data concerning them, which was provided to a data controller, in a structured, commonly used, and machine-readable format. They also have the right to transmit this data to another data controller without hindrance from the data controller to which the personal data was provided, where the processing is based on consent pursuant to Article 6(1)(a) GDPR or Article 9(2)(a) GDPR, or on a contract pursuant to Article 6(1)(b) GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.

 

Furthermore, in exercising their right to data portability pursuant to Article 20(1) GDPR, the data subject has the right to have personal data transmitted directly from one data controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.

 

To exercise the right to data portability, the data subject can contact the Data Protection Officer appointed by ILVEA IC VE DIS TICARET LDT. STI. or another employee at any time.

g) Right to Object

Every data subject affected by the processing of personal data has the right, as granted by the European legislator, to object, on grounds relating to their situation, at any time, to the processing of personal data concerning them, which is based on Article 6(1)(e) or (f) GDPR, including profiling based on those provisions.

 

ILVEA IC VE DIS TICARET LDT. STI. will no longer process personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise, or defence of legal claims.

 

If ILVEA IC VE DIS TICARET LDT. STI. processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning them for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to ILVEA IC VE DIS TICARET LDT. STI.’s processing for direct marketing purposes, ILVEA IC VE DIS TICARET LDT. STI. will no longer process the personal data for these purposes.

 

In addition, the data subject has the right, on grounds relating to their situation, to object to the processing of personal data concerning them by ILVEA IC VE DIS TICARET LDT. STI. for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) GDPR, unless the processing is necessary for the performance of a task carried out in the public interest.

 

To exercise the right to object, the data subject can directly contact the Data Protection Officer of ILVEA IC VE DIS TICARET LDT. STI. or another employee. The data subject is also free to exercise their right to object in connection with the use of information society services, notwithstanding Directive 2002/58/EC, by automated means using technical specifications.

 

h) Automated Individual Decision-Making, Including Profiling

Every data subject affected by the processing of personal data has the right, as granted by the European legislator, not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them, except where the decision (1) is necessary for entering into or performing a contract between the data subject and the data controller, (2) is authorized by Union or Member State law to which the data controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is based on the data subject’s explicit consent.

 

If the decision (1) is necessary for entering into or performing a contract between the data subject and the data controller or (2) is based on the data subject’s explicit consent, ILVEA IC VE DIS TICARET LDT. STI. shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the data controller, to express their point of view, and to contest the decision.

 

To exercise rights related to automated decisions, the data subject can contact the Data Protection Officer or another employee responsible for processing at any time.

i) Right to Withdraw Consent for Data Processing

Every data subject affected by the processing of personal data has the right, as granted by the European legislator, to withdraw their consent to the processing of personal data at any time.

 

To exercise the right to withdraw consent, the data subject can contact the Data Protection Officer or another employee responsible for processing at any time.

 

10. Legal Basis for Processing

Art. 6(1)(a) GDPR serves as the legal basis for processing operations where we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is a party, as is the case, for example, when processing operations are necessary for the supply of goods or the provision of other services or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to such processing operations that are necessary for carrying out pre-contractual measures, for example, in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and their name, age, health insurance data, or other vital information would have to be passed on to a doctor, hospital, or other third parties. Then the processing would be based on Art. 6(1)(d) GDPR. Finally, processing operations could be based on Art. 6(1)(f) GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the data controller (Recital 47 Sentence 2 GDPR).

 

11. Legitimate Interests in Processing Pursued by the Controller or a Third Party

If the processing of personal data is based on Article 6(1)(f) GDPR, our legitimate interest is conducting our business for the well-being of all our employees and shareholders.

 

12. Duration for Which the Personal Data Will Be Stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.

 

13. Legal or Contractual Requirement to Provide Personal Data; Necessity for the Conclusion of a Contract; Obligation of the Data Subject to Provide the Personal Data; Possible Consequences of Failure to Provide Such Data

We clarify that the provision of personal data is partly required by law (e.g., tax regulations) or can also result from contractual provisions (e.g., information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with them. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact our Data Protection Officer. Our Data Protection Officer clarifies to the data subject whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data, and the consequences of non-provision of the personal data.

 

14. Existence of Automated Decision-Making

 

As a responsible company, we do not use automatic decision-making or profiling.

 

This privacy policy has been generated by the privacy policy generator of DGD Deutsche Gesellschaft für Datenschutz GmbH, which acts as the Data Protection Officer in cooperation with the data protection lawyers of the law firm WILDE BEUGER SOLMECKE | Rechtsanwälte.