Privacy and Security Policy
Privacy and Security Policy
Last update: 05.06.2022
Information and Privacy Statement on Personal Data Protection Act (“Privacy Statement”)
The subject of this "Privacy Statement" is the collection, use, sharing, preservation and protection of your personal data with third parties within the scope of the Personal Data Protection Act No. 6698. It consists of explanations regarding issues related to the processing of personal data and your rights in relation to these issues.
When you visit www.exporgin.com, when you become a member to act as a buyer or when you apply for a rights holder protection program, we process your identity information, contact information, transaction security information, customer transaction information, marketing information and financial information To the extent necessary for payments. When you contact our information and call center, we may process your data consisting of call center records. In general, you may use this data for purposes such as ensuring the execution of Site and Membership related transactions, mediating your relationship with a buyer and carrying out our activities on the Site in accordance with the legislation (in the full and detailed scope of purposes, please refer to the “Privacy Statement - Full Text” below.
We may share your personal data with service providers from whom we receive support in carrying out these activities, for a limited purpose.
To exercise your rights under the law, you may contact us using the methods available at https://www.exporgin.com/gdpr.
For information on how we process your personal data, our processing purposes, the legal reason for the processing, the purposes for transfer and recipient groups, please see the “Privacy Statement - Full Text” section below.
Privacy Statement - Full Text
This privacy statement, regardless of how you access and use it, including what you do via mobile devices, is provided by Porgin Digital Technologies Tic. A.Ş website. ("www.exporgin.com") (collectively, the "Services / Our Services").
This privacy statement is subject to change at any time. In this case, the Privacy Statement will become effective by posting it on our website, and we will also announce the changes to you.
1.1 Data Monitor
Tour CB21 16 Place de l'Iris LADEFENSE 92400 France, “EXPORGIN EUROPE SAS". It is the “data controller” address in accordance with the law within the scope of the provision of services.
2. Your personal data we obtain
When you use your personal data as a member or non-member of our services, when you create an account, fill out a form on our site, update or add information to your account information, when you buy or sell products or services, or participate in dispute resolution, and in connection with our services . We collect, process and store this information when you contact us or other users or visit our site. The personal data we collect, including from other sources, is listed below.
2.1 The personal data that you share with us for the purpose of using our Services is as follows:
a. If you are a Buying Member on the Site or have performed a Transaction without being a Member;
- Your name, surname and date of birth, your identification information which consists of your identification number and your gender;
- your contact information which consists of phone number, email address, address information and delivery address information;
- Goods delivery information, your customer transaction information, which consists of the content of messages in the My Messages section;
- Your marketing information consists of your shopping history information;
- Visual and audio recordings consisting of call center recordings;
- Your financial information consisting of the first 6 and last 4 digits of your credit card, and bank account information related to purchases/sales and returns;
b. If you have applied to the Brand Protection Program;
- Name, surname, phone number, e-mail address, address information, bank account information if necessary, information on the trademark and patent registration document
2.2 Personal data we collect automatically when you use our Services or create an account:
We collect the following information in order to ensure that we comply with Law No. 5651 Regulating Internet Broadcasts and combating crimes committed through such programmes;
- Your transaction security information, which consists of computer and connection information such as your IP address, traffic data, and web history information.
2.3 Cookies and Personal Information We Collect Using Web Beacons:
Technologies, cookies, web beacons, etc. are used, for advertising and marketing purposes, to track your shopping experience and manage the operation of the Site, so that we can provide you with a better, faster and safer experience when you visit our Site or when interacting with our Services and Apps.
2.4 Personal data we obtain when you log in to the Site with your other accounts:
We may allow you to use the social networking site to link your account with your social media account, or we may allow you to become a member of the site using your Google account. When you become a member in this way, the relevant social networking site may provide us with automatic access to your personal data required for membership. The relevant site shows you what will automatically access your data during membership. You have the right to make changes with respect to your personal data that we can access through the privacy settings on the relevant social media site. You can manage these changes from other related websites.
3. Our legal basis for processing your personal data and our purposes for processing
We process your personal data that we collect for different purposes based on different legal reasons. Below is information about how and on what legal basis we process your personal data.
3.1 We process your personal data for the following purposes, based on the legal reason for entering into the contract and fulfilling the rights and obligations arising from the contract in accordance with Section 5 (2) (C) of the Act:
- To prevent, detect, reduce and investigate activities that constitute fraud or fraud, or that create security breaches, suspicious or illegal,
- To send invoices to vendors,
- To notify you of your account, to troubleshoot your account, to resolve disputes, or to provide other services (other than marketing activities) that may be required within the scope of customer service activities, in order to ensure customer satisfaction and to respond to customer requests, identity verification/charges and refund fees. For this purpose, we may contact you by email, telephone, webpush or SMS. When communicating with you by phone, we may use methods such as automatic dialing, pre-recorded call or SMS to ensure effectiveness. In this context, we would like to remind you that SMS and other data transfer charges may apply.
- To ensure the fulfillment of your membership transactions, to act as an intermediary in the fulfillment of your shopping transactions and to keep shopping records
- To be able to carry out the Brand Protection Program in order to identify the right holders in case of dispute and to examine the requests.
3.2 We process your personal data for the following purposes, based on the legal reason which is clearly stated as stipulated in the laws in accordance with Article 5 (2) (a) and (ç), which are necessary to fulfill our legal obligations:
- To be able to fulfill the requests of official institutions regarding the activities that take place on the site
- To be able to control the product pages (lists) on the Site
- To be able to conduct transactions related to membership and shopping operations in accordance with the law
- To be able to manage your requests within the scope of consumer legislation and carry out our activities in accordance with current legislation
- To be able to keep logs, IP and traffic logs in order to monitor the security of transactions on the site
3.3 We process your personal data for the following purposes, based on the legal reason why it is necessary to protect and establish the right in accordance with Section 5 (2) (e) of the Act:
- To resolve disputes in the event of any dispute relating to your use of the Site
- To be able to carry out the Brand Protection Program in order to identify the right holders in case of dispute and to examine the requests
3.4 We process your personal data for the following purposes, based on the legal reason required by our legitimate interests, provided that this does not prejudice your fundamental rights and freedoms in accordance with Section 5 (2) (f) of the Act:
- Customizing, measuring and improving our Site and Services for you
- Prevent, detect, reduce and investigate activities that constitute fraud, fraud, breach of security, or which may be suspicious or illegal,
- To resolve any disputes arising from the content on the site,
- To maintain records of purchases,
- To be able to carry out customer service activities (responding to orders, quality control, etc.),
- To measure the performance of our email marketing campaigns, using statistical methods such as email open and click rates,
- To monitor and improve the security of our website and mobile applications,
- To be able to carry out the Brand Protection Program in order to identify the right holders in case of dispute and to examine the requests.
3.5 We may also use your personal data if you have given your express consent. Activities we can carry out in this regard include:
- To contact you by e-mail, phone, SMS or post to offer coupons, discounts and special promotions, to know your opinions through the survey, taking into account your communication preferences.
- To provide marketing and promotional offers based on your communication preferences, with targeted marketing.
In cases where you have given express consent, you may withdraw your consent at any time. For this purpose, you can call us, send an email to firstname.lastname@example.org or follow the directions in the "Contact Us and Claims"
4. Sharing of personal data
We share your personal data with the following people for the following purposes:
4.1 Your personal data may be shared with the parties from whom we receive support services such as call center service, email/SMS sending service and server hosting service for the following purposes.
- It may be shared with the company from which we receive support in order to host, backup and receive email service from our servers.
- It may be shared with our service providers, who provide us with the systems on which we keep records of membership transactions and which may be located offshore. Your personal data that we process when you become a member of the Site or perform transactions from the Site is not transferred directly abroad and is hosted on our servers located in Turkey.
- It may be shared with companies we work with to receive customer support services, SMS and email sending services.
- Prevent, detect, reduce and investigate potentially illegal transactions, violation of our User Agreement, fraudulent transactions or security breaches, member and reward programs, personalized advertising services, and payment transaction services with our service providers to assist us in other matters of business operations.
- In the event of a subpoena, court order, or decision similar in substance, or if we believe in good faith it is necessary to prevent potential physical harm or financial loss or to report suspected illegal activity, we will share Personal Data with third parties involved in legal proceedings. We can also share it with your office.
4.2 Your personal data may be shared with law enforcement authorities, official and legal authorities for the following purposes.
- We may share it to comply with legal requirements, to protect our user agreement, to evaluate and respond to claims that any content violates the rights of others, or to protect anyone's rights or safety.
- Data may also be shared with law enforcement, public authorities or authorized third parties in response to a verified request regarding criminal investigation, suspected illegal activities and other activities that may expose us, you or any of our other users to legal liability. In this context we will share information, such as name, city, zip code, phone number, email address, user ID history, IP address, fraud complaints, shopping history and listing history, which we believe is only relevant to the relevant investigation or investigation and that legal authorities expressly request from us.
- In cases we deem necessary, in order to prevent or stop the investigation of transactions that raise suspicion of fraud, fraud, infringement of intellectual or industrial rights, confidentiality or other illegal transactions, provided that the necessary obligations and agreements with the participating program (Rightholders) are accepted within Scope of the Hak Sahiplerini Koroma Programı. We may share relevant users information (city, zip code, phone number, email address, user ID record, IP address).
- We would also like to remind you that we are obligated to share your personal data with the specified authorities (courts, prosecutors' offices, law enforcement offices) in accordance with current legal regulations, in particular Law No. 5651 on the regulation of broadcasts made on the Internet and combating crimes committed through these broadcasts and Law No. 6563 on the regulation of broadcasts on the Internet Electronic trade .
4.3 Your personal data may be shared for the following purposes with other Site users whom you have directly authorized to use our Services.
When you transact with other users you have authorized on our Site, your name, identity information, email address, telephone number, merchandise delivery address and billing address, which are necessary for EXPORGIN SAS to deliver relevant Products to you and for billing and customs clearance of Products you buy/sell from our Site when necessary In accordance with our role as an intermediary service provider, we may share information that EXPORGIN SAS may request with the other relevant user. In such cases, we transfer the information you submit to us via our Platform to other Users only for the above purposes and to a limited extent. All other users of your information are not permitted to use this information for non-transactional purposes, such as contacting you for marketing purposes, without your express consent. Users who receive your information will also be considered data monitoring, including at the stage of product delivery, and will be obligated to act in accordance with the law.
Contacting users with unsolicited or threatening messages constitutes a violation of our User Agreement.
5. Actions we take to ensure the security of your personal data
We protect your information by taking appropriate technical and administrative security measures to minimize risks such as loss of personal data, misuse, unauthorized access, and unauthorized transfer. Some of the procedures we use include new generation security layers, firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. If you suspect that your account has been misused, please contact us by following the explanations in the “Contact Us and Your Rights” section below. We recommend that you use numbers, uppercase and lowercase letters and unique characters in your password and not use it on any other site. You should not share your password with other people. If you share your password with others, you will be responsible for all actions and transactions that others perform from your account. We would like to remind you that losing control of your password may result in loss of control over your personal data.
6. Other important privacy information
Your choices regarding the use of your personal data
You can choose from your (My) page to contact you or notify you of marketing;
You can control the ways we will contact you regarding your account or your buying or selling activities in [My Account > My Information/Settings]. At the same time, you can check the communication preference settings between members from My Account > My Information / Settings > Blocking Service.
If you do not wish to receive marketing communications from us, you may opt out of marketing communications via the link in the email you have received and via SMS, or change your communication preferences at My Account > My Information / Settings > My Information, or you may specify your communication preferences by contacting us directly.
When you sign in to your account, your account remains open for a certain period of time. If you are using a public or shared computer, we recommend that you do not leave your account open after logging in. You will be able to view your account, access your account, and take actions related to your account, without any other permission, as long as you are logged in. Other users of the computer/browsers you are logged into will also be able to perform these operations as long as you are still logged in. Transactions and account activities that you or other users of such computers/browsers may conduct include, but are not limited to, the following:
- Complete shopping or add products to the cart,
- View order information,
- View my page,
- To view and edit 'Favorites' or 'What I've Watched',
- View profile page,
- Sending messages between members,
- Give feedback
- Engaging in after-sales activities such as canceling orders, requests for returns, or placing orders.
If you attempt to change your password or user ID, update other account information, or perform account activities other than those listed above, you will be asked to enter your password.
You can end your session by logging out or clearing your cookies. If your browser's privacy settings are properly enabled, your session may also be terminated simply by closing your browser. If you are using a public or shared computer, when you terminate your use of our Services, you must sign out or clear cookies by following the instructions in the Help file of your Internet browser to protect your account and personal information.
Control and Correction of Your Personal Data
We take appropriate measures, including the following, to ensure that the personal data we collect is accurate and up-to-date, so that you can access it, and correct it when necessary.
- If your personal data changes or is inaccurate, please update it without delay.
- In order to exercise your rights set forth in Article 11 of the Law regarding your personal data, you can reach us by following the explanations in the "Contact Us and Your Rights" section below or by following the directions at https://www.exporgin.com/kvkk.
What happens when you share your personal data on the site?
Other users can access the information you share at www.exporgin.com. For example, other users can see your purchases, products you sell, ratings/comments from EXPORGIN SAS, reviews about products.
Your user profile is public. Your user account is linked to all of your Exbergin activities. Notifications sent to other Users regarding suspicious activity and notification violations on the Site refer to the User's account and specific products. Therefore, if you associate your name with your user account, the people you reveal your name to will be able to personally identify your Exporgin activities.
To ensure your privacy is protected, we allow other users limited access to your name, surname, address, email and telephone, but only if necessary to conduct your transactions.
You may not share the personal data of others (other person's delivery address, information about another card holder you use for transactions, and similar information) with us only if the prior express consent of the said persons has been obtained. You must also inform such persons of how their personal data is collected, used, shared and maintained in accordance with our Privacy Statement.
How should you use the information you get from Exporgin?
When you conduct a transaction with other Users, we provide you with the other Username, account number, email address, contact information, address/shipping and billing information so that you can complete the transaction. You must inform other Users of your privacy practices and respect their privacy. In any case, you must allow Users to Others delete themselves from your database and give them the opportunity to review the information you have collected about them.
You may use personal data that you have access to only for purposes related to Exorgin transactions or for other services provided through Exorgin such as shipping, fraud complaints and member communication, or for other purposes expressly agreed by the users to whom the information belongs. different in violation of our User Agreement.
Spam or threatening messages, unsolicited emails and SMS texts
We do not tolerate misuse of our services. Even if users purchase products from you, you are not allowed to add them to their email or mailing list, contact them for commercial purposes or send them an SMS without their express consent. Sending spam or threatening email and SMS is against our User Agreement. You may report spam or fake emails and SMS senders related to Exporgin by contacting Customer Service.
Third Party Privacy Practices
This privacy statement relates solely to our use of the personal data we collect from you. If you share your personal data with others or are directed to third-party websites, their privacy data and practices will apply.
If you share your personal data with third parties, we cannot guarantee the confidentiality and security of your personal data, and we recommend that you evaluate the privacy and security policies of the person with whom you share it before taking any action and sharing your personal data. This also applies if the third parties with whom you share your personal data are bidders, buyers on our site
7. Contact us and your rights
in connection with the data we collect, your data in accordance with Section 11 of the Act;
- Learn whether it is being processed or not,
- Request information about it, if it has been processed,
- Recognize the purpose of the processing and whether it is used in accordance with its purpose,
- If it is shared with third parties in the country or abroad, knowing who they are,
- Request its correction in case of incomplete or incorrect processing,
- Request the deletion or destruction of your processed data, in the event that the reasons requiring processing disappear,
- If your data has been deleted or corrected at your request, and a request to notify the transactions to the third parties to whom the personal data has been transferred,
- Object to the appearance of a result against you in cases where it is analyzed exclusively through automated systems,
- You are entitled to claim damages in the event that you suffer damage due to unlawful processing.
You may exercise these rights in accordance with the Statement of Application Procedures and Principles to the Data Controller. When you want to use your rights with us; You can access it through; email@example.com .