Clarification Text concerning the Protection of Personal Data by virtue of the Law No. 6698 on Protection of Personal Data

This Clarification Text has been drawn up by virtue of Article 10 of the Law No. 6698 on Protection of Personal Data.
We, Leal Gümrük Müşavirliği Ltd. Şti. (“Leal Customs”, “Company”), were founded and currently do business in compliance with the Turkish legislations, and process your personal data in accordance with such legislations and within the scope detailed herebelow as the data controller.

Purpose of Processing Personal Data

Your personal data can be processed by our company for purposes and reasons set out herebelow: We may store your ID details as well as your credentials such as name, surname, place and date of birth needed to have your personal data registered within the scope of business facilities carried out together with you, and your contact details for the purpose of correspondences and communications required to be conducted with you during business facilities and in case of necessity; show your financial information as an evidence in a probable legal and statutory process as well as for being able to fulfil our legal liabilities in terms of accountancy, and also for being able to meet requirements of competent authorities if needed; and process your visual data for providing the security of your workplace; your electronic data (information processing) for the purpose of ensuring the reliability in legal terms and also facilitating your trust toward us; and your customer details for providing solid solutions with recommendations, requests or complaints from you within such business facilities and for using the same for marketing activities.

Your personal data is stored for a maximum period, and in any case, for a prescription period stipulated under legislations or required to be applied for the purpose of which such data may be processed, as well as for the purpose of fulfilling our legal liabilities, in particular, arising from customs regulations, and also for the purpose of complying with our contractual obligations, and for legitimate interests of our Company, and for providing the legal and commercial safety of persons who are in a business relationship with our Company, establishing communications, identifying and implementing business-related strategies, conducting communicative operations, meeting demands of juridical, administrative and judicial units and also execution offices, assessing the customer satisfaction and service quality, establishing communications for celebrations and greetings, making contact with relevant persons in emergencies, and for confidentiality, safety (security) and assessment (evaluation) purposes.

Method and Legal Reason of the Collection of Personal Data

We collect and store your personal data which we ask you to share or which you directly prefer sharing with us for the purpose of fulfilling provisions of the Customs Law and also our other legal liabilities in force, and also for the purpose of complying with our contractual obligations, and for legitimate interests of our Company and for other purposes and reasons we have detailed herebelow, by way of discussions/interviews/meetings between all of service units of our Company and you; all of verbal, written or electronic applications to our Company, third parties and organizations with which we are in a business relationship; meetings, our call centres, applications received through websites, SMS channels, social media, other companies from which assistance services are received, and real and/or legal entities with whom any legal or contractual processes are conducted, and by PTT (Turkish Post Telephone and Telegram Institution), Social Insurance Institution and similar methods or automatic or non-automatic methods, provided that such collection and storage is limited to legal terms.

The data collection carried out by Leal Customs relies on the fact that it is obligatory for us to be able to fulfil our legal liabilities as per Paragraph 2 of Article 5 of the Law on Protection of Personal Data; it is obligatory for our legitimate interests, provided that it does not violate our fundamental rights and freedoms; it is expressly stipulated under laws; and it is necessary for the processing of personal data belonging to parties of the contract, provided that it directly relates to the formation/conclusion or performance of a contract. Your data that falls into the category of sensitive personal data can be processed if you give express consent or can be handled in line with other exclusions stipulated under the Law.

Parties to which Personal Data is Transferred and Purpose of Such Transfers

Your personal data can be transferred to governmental authorities to which such data is legally obliged to be transferred to the extent allowed and required under other provisions of legislations so that our Company can fulfil its legal liabilities as per laws, and in particular, for the purpose of ensuring your security, in accordance with Articles 8 and 9 of the Law No. 6698 within the framework of statutory limitations.

Moreover, we can transfer your personal data to companies, manufacturers (producers), intermediary service providers, and warehouse, shipping, cargo and similar logistic service providers with which we receive or provide services for the performance of the contract to which we are a party; security camera records and entry-exit control data obtained for the provision of the in-company security and safety, and to the building management and judicial and administrative units, and your sensitive and other personal data to our lawyers, companies from which we receive legal assistance, and governmental judicial authorities, and domestic companies with which we are affiliated as part of our Company’s administration and our Company Policies and which have a project-based business partnership, where necessary, so that we can fulfil our legal liabilities; by complying with provisions mandated under Articles 8 and 9 of the Law No. 6698 as well as rules of the law and equity, and the principle of proportionality; where it will be subject to exclusions specified in Sub-paragraph 3 of Paragraph 2 and/or 6 of Article 5 of the Law on Protection of Personal Data, provided that the data security is guaranteed under confidentiality contracts in terms of provisions respecting the data transfer, and further provided that we will obtain your express consent where necessary.

Your Rights

You can submit your applications in writing to our head office at Cevizli Mah. Bağdat Cad. No: 515 K: 5 Maltepe/Istanbul by using your registered electronic mail (REM) address, secure electronic signature, mobile signature or electronic mail address that you have notified to us earlier and we keep in our records, provided that your rights stipulated under Article 11 of the Law are acknowledged and your identity is confirmed for your requests. When you file an application, all of your assessments shall be in accordance with relevant provisions stipulated under the Law on Protection of Personal Data, and Leal Customs may ask you to provide certain information for confirmation purposes to see whether the applicant is the right person; the entire data which may be required within this scope shall be asked only for the purpose of determining the real data holder and sharing the application results with the right person. Applications must be filed to Data Controllers in Turkish as per the Communiqué on the Principles and Procedures with regard to Applications to Data Controllers, and if your application is to be replied in writing, then this shall be free of charge for up to ten pages; but an extra payment shall be incurred for an amount of 1 Turkish Lira per page exceeding ten pages.

Contact Details

Title: Leal Gümrük Müşavirliği Ltd. Şti
Central Registration System Number:0608002428300014
Website Link: https://www.leal.com.tr/eng/head-office-istanbul/
Address: Cevizli Mah. Bağdat Cad. No:515 K:5 Maltepe/Istanbul