Privacy and Personal Data Protection Policy
Protection of your personal information and providing security during your payments are very important for us. During membership registration (either via Facebook connect or directly entering your information) we will collect information about our members and we will not share or sell this information to third parties for any commercial purpose outside of our field of operation.
Membership information can be shared for official purposes upon written request.
What does this policy cover?
We, snpgermany.com ('we', 'us' or 'our' being interpreted accordingly) take your privacy seriously. Please read this privacy policy ('Privacy Policy') carefully as it contains important information on how and why we collect, store, use and share personal information relating to you from which you can be identified ('Personal Data').
This Privacy Policy also explains your rights in relation to your Personal Data and how to contact us or supervisory authorities in the event you have a complaint.
Our Legal Obligations Regarding Your Personal Data
We will collect and process your Personal Data in accordance with applicable laws that regulate data protection and privacy. This includes, without limitation, the EU General Data Protection Regulation (2016/679) ('GDPR') and the Turkish Personal Data Protection Law no. 6698 (''TPDPL') together with other applicable Turkey and EU laws that regulate the collection, processing and privacy of your Personal Data (together, 'Data Protection Law'). We are responsible as 'controller' of your Personal Data for the purposes of Data Protection Law.
What Personal Data will we collect?
We may collect and use the following Personal Data about you:
- Your name-surname, contact details (including your email address and telephone number)
- Details of your contact history with us (including call and records of messages by text or messaging services)
- Testimonials or comments you have provided about our services.
and other Personal Data that you may provide to us from time to time, including during recorded calls.
Please note that we do not collect and process any data what is known as 'sensitive' data about you, for example, information regarding your health or ethnic origin.
If you choose not to provide the Personal Data we request, it may delay or prevent us from responding to a request or query, or providing our services to you.
How your Personal Data is collected?
We collect most Personal Data directly from you during your relationship and communications with us, via you uploading your data to the www.snpgermany.com website or through telephone (our calls may be recorded), email, text, messaging service or in person. However, we may also collect information directly from third parties e.g.Facebook, Google etc. depending on your login permission preferences.
How and why we may process your Personal Data?
We may use your Personal Data in the following ways where you have given your consent, for us to create profile and details to the snpgermany.com database (you will also be asked to consent to having your information submitted to the system):
- To provide our services to you, including preparing and delivering your orders, maintaining any related task about your purchases (shipping, billing, customer services etc.), and keeping you updated on the progress of your processes
- To enable to assess and improve our customer service and to make our services more valuable to you (including tailoring our website and our group companies' websites when you log on to make enrich your personal online experience)
- To answer your questions and enquiries
- To use your information on an anonymous basis to monitor compliance with our equal service policy
- To conduct market researches, customer analysis, purchase sensitivity analysis, churn analysis or to build our recommendation systems etc.
- To record the results of our research and our relationship and communications with you
- Where you have given your consent, for us to publish testimonials and comments about our services
- To provide you with direct marketing communications about what we are doing as well as our services, reports, offers and client events and general information about the automotive sector which we think might be of interest to you by post or phone. If required under applicable law, where we contact you by SMS, email, social media and/or any other electronic communication channels for direct marketing purposes, this will be subject to you providing your express consent. You can object or withdraw your consent to receiving direct marketing from us at any time, by contacting us using the email address: [email protected]
From time to time we may seek your consent to process, use or disclose your information for another purpose not listed above.
The lawful grounds on which we collect and process your Personal Data
We process your Personal Data for the above purposes relying on one or more of the following lawful grounds:
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests or those of a third party;
- Where you have given consent; or
- To comply with our legal and regulatory obligations.
- A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. Our legitimate interests include continuing to operate our e-commerce business, the administration and maintenance of records, management of client and customer relationships, improvement of our services, and marketing our services.
Who we share your Personal Data with
We may need to disclose your Personal Data where you have given your consent to certain third party organisations who processing Personal Data only in accordance with our instructions under contract (called 'data processors') such as companies and/or organisations that act as our service providers or marketing advisers, or otherwise assist us in delivering the services that you have requested e.g. cloud storage providers, IT service providers.
We only allow our data processors to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on data processors to ensure they can only use your Personal Data to provide services to us and to you.
We may also disclose your Personal Data to third parties who make their own determination as to how they process your Personal Data and for what purpose(s) (called 'data controllers') e.g. if we submit your e-mail address or phone number to a client, they will become a data controller in respect of this personal data.
We may disclose and exchange information with regulatory or law enforcement agencies if we are required by law to disclose it in connection with the detection of crime, the collection of taxes or duties, in order to comply with any applicable law or order of a court of competent jurisdiction, or in connection with legal proceedings.
We may also need to share some Personal Data with third parties in the event of a sale, merger, liquidation, receivership or transfer of all or substantially all of the assets of our company provided that the third party agrees to adhere to the terms of this Privacy Policy. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
In all cases we always aim to ensure that your Personal Data is only used by third parties for lawful purposes and in compliance applicable Data Protection Law.
International transfers
The Personal Data that we collect may be accessible by our other group companies, clients, and the third parties located outside of the European Economic Area (the 'EEA'). Accordingly, your Personal Data will be sent to or be capable of being accessed from outside the EEA in a territory whose laws are not considered to meet the standards for protection of Personal Data as are set out in Data Protection Law.
When we transfer your Personal Data outside the EEA, we will do so only under a contract or another appropriate mechanism which is authorised under Data Protection Law. This is to make sure that your Personal Data is safeguarded in accordance with the same legal standards that apply to us in the EU.
How do you find out what information we hold? Can you amend, modify or request this information be deleted, and can you unsubscribe from our services?
In accordance with your legal rights under Data Protection Law, you have a 'subject access request' right under which can request information about the Personal Data that we hold about you, what we use that Personal Data for and who it may be disclosed to as well as certain other information. Usually we will have a month to respond to such a subject access request, but we may, in case of complex requests, require a further two months to respond.
We reserve the right to verify your identity if you make a subject access request. We may also require further information to locate the specific information you seek before we can respond in full and apply certain legal exemptions when responding to your request. We may charge for administrative time in dealing with any manifestly unreasonable or excessive requests for access.
Under Data Protection Law you also have the following rights, which are exercisable by making a request to us in writing:
- To be provided with a copy of your Personal Data;
- To require us to correct Personal Data that we hold about you which is inaccurate or incomplete;
- To require us to erase your Personal Data without undue delay if we no longer need to hold or process it;
- To object to our use of your Personal Data for direct marketing (you may request to unsubscribe from job alerts and marketing material at any time. If you wish to contact us with respect to the above matters please email us as : [email protected];
- To object and/or to restrict the use of your Personal Data for purpose other than those set out above unless we have an overriding legitimate reason for continuing to use it; or
- To object to any automated processing (if applicable) that we carry out in relation to your Personal Data;
- In certain circumstances, to require us to transfer Personal Data to another party where the Personal Data is being processed by automated means.
All of these requests may be forwarded on to a third party provider who is involved in the processing of your Personal Data on our behalf.
If you would like to exercise any of the rights set out above, please contact us at : [email protected]
If you make a request and are not satisfied with our response, or believe that we are illegally processing your Personal Data, you have the right to complain to the personal data protection authority and organisation in Turkey and other authorities in EU.
How long will we hold your information for?
We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Please inform us of any changes to your Personal Data to ensure that it is up to date and we will update or erase the details we hold accordingly.
Sending us information over the internet
We employ appropriate technical and organisational security measures to protect your Personal Data from being accessed by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. However, the nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet.
How we collect and aggregate information about visitors to our websites
We also collect information about visitors use our website in order to improve our services. We do not use information gained in this way in a way that any individual can be identified, and only use it to understand our users better, and to determine aggregate trends, most popular pages, etc, for all the website’s users. We may share this kind of aggregate data with selected third parties to assist with these purposes. We may also undertake marketing profiling to help us identify services or jobs which may be of interest to you.
Cookies
If You decide at any time that you no longer wish to accept Cookies from Our Site or Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the site or all functionality of the service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below. To find out more about the cookies stored on your device, and to manage or delete them, please visit www.aboutcookies.org or www.allaboutcookies.org
Change to our Privacy Policy
Any changes to this Privacy Policy will be posted on this website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any time we decide to use Personal Data in a manner significantly different from that stated in this Privacy Policy, or otherwise disclosed to you at the time it was collected, we will notify you by email.
Contact
If you have any queries regarding this Privacy Policy or wish to make a further request relating to how we use your Personal Data as described above, please contact: [email protected]
