PERSONAL DATA PROTECTION POLICY

Lunera Home Personal Data Protection Policy

General Information on the Personal Data Protection Law

Law No. 6698 on the Protection of Personal Data (hereinafter referred to as the “KVKK”) was adopted on March 24, 2016, and published in the Official Gazette No. 29677 dated April 7, 2016. Certain provisions of the KVKK entered into force on the date of publication, while the remaining provisions entered into force on October 7, 2016.

Information Provided in Our Capacity as Data Controller

Pursuant to Law No. 6698 on the Protection of Personal Data and in our capacity as the Data Controller, your personal data may, within the framework described on this page, be recorded, stored, updated, disclosed and/or transferred to third parties where permitted by applicable legislation, classified, and otherwise processed in the manners specified under the KVKK.

How Your Personal Data May Be Processed

Pursuant to Law No. 6698 on the Protection of Personal Data, the personal data you share with our Company may be processed by us, either wholly or partially, by automatic means or by non-automatic means provided that such processing forms part of a data recording system.

Such processing may include the collection, recording, storage, alteration, reorganization and any other operation performed on personal data. Within the scope of the KVKK, any operation performed on personal data is considered “processing of personal data.”

Purposes and Legal Grounds for Processing Your Personal Data

The personal data you share with us may be processed for the following purposes:

To fulfill the requirements of the services we provide to our customers in accordance with contractual and technological requirements and to improve the products and services we offer;

To record identity, address and other necessary information required to identify the relevant party within the scope of Law No. 6563 on the Regulation of Electronic Commerce, Law No. 6502 on Consumer Protection, the Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce published in the Official Gazette No. 29457 dated August 26, 2015, the Regulation on Distance Contracts published in the Official Gazette No. 29188 dated November 27, 2014, and other applicable legislation;

To prepare all records and documents that form the basis of transactions in relation to payment systems, electronic agreements or paper-based transactions required in the fields of banking and electronic payments, and to comply with record-keeping, reporting and information obligations imposed by applicable legislation and other competent authorities;

To provide information to public prosecutors’ offices, courts and relevant public officials upon request and where required by law in matters concerning public safety and legal disputes.

Your personal data will be processed in accordance with Law No. 6698 on the Protection of Personal Data and the relevant secondary legislation.

Third Parties or Organizations to Whom Your Personal Data May Be Transferred

For the purposes specified above, the personal data you share with our Company may be transferred to suppliers, shipping and delivery companies, persons and organizations involved in the provision of our services, business partners from whom we receive services and/or with whom we cooperate in order to carry out our activities or who act as Data Processors, organizations located in Türkiye or abroad, and other third parties.

How Your Personal Data Is Collected

Your personal data may be collected and processed through the following channels:

Through forms available on our Company’s website and mobile applications, including information such as your first name, surname, Turkish Republic identification number, address, telephone number, business or personal email address; preferences on pages accessed using a username and password; IP records relating to transactions performed; cookie data collected by your browser; browsing duration and details; and location data;

Verbally, in writing or electronically through our sales and marketing department employees, branches, suppliers, other sales channels, paper forms, business cards, digital marketing channels and call centers;

From individuals who share their personal data for purposes such as establishing a commercial relationship with our Company, applying for a job or submitting an offer, including through business cards, résumés (CVs), proposals and other means, whether in physical or virtual environments, face-to-face or remotely, verbally, in writing or electronically;

Additionally, through data obtained indirectly from various channels, including websites, blogs, competitions, surveys, games, campaign-related or similar (micro) websites and social media; newsletter reading or click activity; publicly available databases; and publicly shared profiles and data on social media platforms.

Personal Data Obtained Before the KVKK Entered into Force

Personal data lawfully obtained prior to April 7, 2016, the effective date of the KVKK, through membership registrations, electronic communication permissions, purchases of products/services or other means, is also processed and retained in accordance with the terms and conditions set out in this document.

Transfer of Your Personal Data Abroad

Your personal data collected through any of the methods specified above may, provided that such transfers remain within the scope of the KVKK and are consistent with contractual purposes, be transferred to service providers located abroad for processing in Türkiye or for processing and storage outside Türkiye, subject to the applicable requirements regarding the protection and international transfer of personal data.

Storage and Protection of Personal Data

Your personal data will be stored confidentially in the databases and systems maintained by our Company in accordance with Article 12 of the KVKK and will not be shared with third parties except where required by law or as specified in this document.

Pursuant to Article 12 of the KVKK, our Company is responsible for taking appropriate technical and physical security measures, including access management measures, to prevent the unlawful processing of personal data and unauthorized access to the systems and databases in which your personal data is stored.

If it is discovered that personal data has been unlawfully obtained by third parties, the relevant situation will be reported without delay and in accordance with applicable legislation to the Personal Data Protection Board.

Keeping Personal Data Accurate and Up to Date

Pursuant to Article 4 of the KVKK, our Company is required to ensure that your personal data is accurate and up to date where necessary.

Accordingly, in order for our Company to fulfill its obligations arising from applicable legislation, our customers are required to provide accurate and up-to-date information or update their information through the website/mobile application.

Rights of the Personal Data Subject Under Law No. 6698

Article 11 of Law No. 6698 on the Protection of Personal Data entered into force on October 7, 2016. Pursuant to this Article, Personal Data Subjects have the right to apply to our Company, as the Data Controller, and:

  • Learn whether their personal data is being processed;
  • Request information if their personal data has been processed;
  • Learn the purpose of processing their personal data and whether such data is being used in accordance with its intended purpose;
  • Know the third parties to whom their personal data has been transferred, whether within Türkiye or abroad;
  • Request the correction of personal data if it has been processed incompletely or inaccurately;
  • Request the deletion or destruction of personal data within the framework of the conditions stipulated under Article 7 of the KVKK;
  • Request that third parties to whom personal data has been transferred be notified of any correction, deletion or destruction of such data;
  • Object to any outcome that is detrimental to the individual as a result of the analysis of processed data exclusively through automated systems;
  • Request compensation for damages suffered as a result of the unlawful processing of personal data.

Personal Data Subjects may submit their questions, comments or requests through any of the following communication channels:

Email: info@lunerahomee.com
Phone: +90 553 172 18 39