İHKİB (Istanbul Apparel Exporters’ Association), with its address at Yenibosna Merkez Mahallesi, Sanayi Cad. No:3 Dış Ticaret Kompleksi B Blok P.K.34197 Bahçelievler / İSTANBUL (“İHKİB” or “We”) respect your privacy, whether you are a İTKİB client, one of our client’s clients or users, or simply an individual visiting our website, and we are committed to protecting your privacy through our compliance with this policy. The use of personal information collected through our services shall be limited to the purpose of providing the service for which our clients have engaged İTKİB. Our servers are at this time located in the Turkey (Istanbul) & Germany (Frankfurt) and operated by Sirius Interactive (sirius.com.tr). This policy describes our practices in connection with information that we collect through our websites (collectively, our “Websites”), through our platform (collectively, our “Platform”), as well as through email messages that we send to you (collectively, including the Websites and the Platform, our “Services”).
This policy also applies to information about you that we collect or receive:
It does not apply to information collected by:
2. DATA COLLECTION – GENERAL REMARKS
The data collection plays an important role in the İTKİB event planning. İTKİB and event managers can collect personal data about the people who attend their events and they – as well as İTKİB - can customize the event experience, as well as future products and Services. In this context our Clients as event planners are data controllers, since they collect and control the personal data of their Clients, in this case, event attendees. As data controllers, event planners must be in compliance with GDPR and they are responsible for taking steps to ensure the personal data you hold is accurate and up to date. Furthermore, the event planners should have implemented measures to maintain accuracy and taken reasonable steps to erase or rectify any inaccurate personal data. İTKİB processes the data owned by the event planner and you.
İTKİB as a data controller and a data processor
EU and Republic of Turkey data protection law makes a distinction between organizations that process Personal Data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”). If you have a question or complaint about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.
İTKİB may act as either a data controller or a data processor in respect of your Personal Data, depending on the circumstances. In most cases, we are the data processors, and the event organizer is the data controller.
For example, if you use your account with us to create events as an event organizers, İTKİB will be a data controller in respect of the Personal Data that you provide as part of your account. We will also be a data controller of the Personal Data that we have obtained about the use of the Applications or Properties, which could relate to Organizers or Attendees. We use this to conduct research and analysis to help better understand and serve Users of the Services as well as to improve our platform and provide you with more targeted recommendations about features we think may be of interest to you.
However, if you are imported as an Attendee, we will process your Personal Data to help administer that event on behalf of the Organizer (for example, sending confirmation, promotional and feedback emails, processing payments, etc.) and to help the Organizer target, and understand the success of, their event and event planning (for example, providing event reports, using analytics to gain insights into the effectiveness, etc.). In these circumstances, we merely provides the “tools” for Organizers; we do not decide what Personal Data to request on questionnaire forms, nor is it responsible for the continued accuracy any Personal Data provided. Any questions that you may have relating to your Personal Data and your rights under data protection law should therefore be directed to the Organizer as the data controller, not to İTKİB.
At this time İTKİB uses Cloud Services from Google, AWS, DigitalOcean. In terms of data protection, cloud computing means the processing of personal data on behalf of the İTKİB as cloud user through the cloud provider. The GDPR (Article 28) requires that the cloud user only chooses cloud providers that provide reasonable guarantees for proper technical and organizational measures. Google complies with data processing and security conditions and act for us as a processor of personal data under the GDPR. Google provides its clients with updated contract terms in accordance with the new requirements of the GDPR.
4. İTKİB PLATFORM
Our İTKİB Platform allows any Client that uses it (our Clients and İTKİB itself) to build event sites and manage events. This can include collecting contact information and other demographic information from Visitors or Clients who are participating in events. İTKİB provides the Platform to our Clients to manage their events or to find events, and we use it to run our Services.
5. USE BY OUR CLIENTS
6. PUBLIC FORUMS
İTKİB offers publicly accessible message boards and community forums. Please keep in mind that if you directly disclose any information through such public message boards or forums, this information may be collected and used by others. İTKİB will correct or delete any information you have posted on the Platform if you so request.
7. LOG FILES
İTKİB may collect demographic information, such as your ZIP code, age, gender, preferences, interests and favorites using log files. There may also be information about your computer hardware and software that is automatically collected by us. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by İTKİB for the operation of the Platform, to maintain its quality and to provide general statistics regarding use of the Platform. For these purposes, İTKİB may link this automatically-collected data to personal information such as name, email address, address, and phone number.
8. INFORMATION WE COLLECT AND HOW WE COLLECT IT
İTKİB, and our Clients that use our Platform to organize and manage events or to provide other services, may collect several types of information from and about End-Users, including:
We collect this information:
The information we collect through our Services may include:
9. HOW WE USE INFORMATION
We may use information that we collect or that is provided to us, including Personal Information, for any of the following purposes:
We may also use contact information of Clients and Visitors to contact them via email, telephone or direct mail about products and services that may be of interest to them, if contact information was provided for that purpose. Where required, we will seek and obtain recipients’ express authorization before we send marketing emails. If you do not want us to use your information in this way, please adjust your email preferences on the profile page.
10. THIRD PARTY SERVICES
11. COOKIES AND SIMILAR TECHNOLOGIES
12. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
13. ACCESSING AND CORRECTING YOUR INFORMATION
Upon request, İTKİB will provide you with information about whether we hold any of your Personal Information. If you are a registered user of one of our Services, you can review, request deletion, and change your Personal Information by logging into the Services and visiting your account profile page. For example:
14. CROSS-BORDER TRANSFERS (OTHER THAN TO THE E.U. OR REPUBLİC OF TURKEY)
Although Services are controlled and operated by us from Republic of Turkey, by using the Services you consent to the transfer of information to countries outside of your country of residence, which may have different data protection rules than those of your country, if we need such third country contractors to fulfil our contractual duties.
15. DATA SECURITY
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.
16. INFORMATION COLLECTED ON BEHALF OF OUR CLIENTS
İTKİB collects information under the direction of its clients and has no direct relationship with the End-User individuals whose Personal Information it processes. If you are an End-User of one of our Clients and would no longer like to be contacted by one of our Clients that use our Service, please contact the Client that you interact with directly. We may transfer Personal Information to companies that help us provide our Service. Transfers to subsequent third parties are covered by the service agreements with our Clients. Please note that Clients may have their own / additional Terms and Services, which you have to comply with.
An individual who seeks access, or who seeks to correct, amend, or delete inaccurate Personal Information should direct his query to İTKİB’s Client (i.e., the data controller). If requested to remove Personal Information we will respond within a reasonable timeframe.
We will retain Personal Information we process on behalf of our Clients for as long as needed to provide services to our Client. İTKİB will retain this Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
18. CONTACT INFORMATION
You have at any time the right to revoke your consent to the use of your personal data. Your request for information, deletion, correction, or data transfer, unless this is a disproportionate effort, shall be addressed to us immediately. We will be happy assisting you with your query.
If you believe that the processing of your personal data by us violates the applicable data protection law or your data protection claims have been violated in another way, it is possible to complain to the competent supervisory authority. In Republic of Turkey, the data protection authority is responsible for this.