The protection of personal data is a core priority for OPUS KİMYA A.Ş. (the "Company"), operating under the INEA brand, located at Esentepe Mah. Ali Kaya Sk. No:1/B Polat Plaza B Blok K:11, 34394 Şişli / Istanbul / Türkiye. We process personal data in accordance with the following principles:

●        Lawfulness and fairness;

●        Accuracy and, where necessary, currency;

●        Processing for specified, explicit and legitimate purposes;

●        Relevance, limitation and proportionality to the purposes of processing;

●        Retention only for the period required by applicable law or the purposes of processing, under appropriate security safeguards.

This notice is provided to inform you about the protection of your personal data and to fulfil our disclosure obligation as Data Controller under Article 10 of Law No. 6698 on the Protection of Personal Data ("the Law").

Personal Data Processed

i. Identity Data: First name, last name, national ID / tax ID number

ii. Contact Data: Phone number, billing/contact address, e-mail address

iii. Customer Transaction Data: Order history, complaint/request records, call centre records, etc.

iv. Financial Data: Payment and collection details, card information, transaction reference numbers, invoice details, tax details, bank account details, order amount, campaign and discount information, and current account records.

v. Processing Security Data: IP address, cookie ID, log records, device and browser information relating to your use of the website.

The Company does not process any special categories of personal data belonging to you.

Purposes of Processing

●        Carrying out sales and payment collection,

●        Preparing all records, documents and invoices relating to transactions,

●        Measuring and improving customer satisfaction and support quality, managing customer relations, after-sales services and after-sales processes, and evaluating complaints/issues,

●        Carrying out communication activities,

●        Carrying out logistics activities,

●        Carrying out accounting processes,

●        Carrying out risk management processes,

●        Carrying out and improving operational activities,

●        Conducting internal evaluation within the Company,

●        Carrying out security, operations, reporting and statistical activities,

●        Carrying out marketing activities,

●        Providing information to public authorities in matters relating to public security,

●        Fulfilling legal obligations and exercising rights arising from applicable legislation.

●        Carrying out targeted digital advertising activities (including, where your explicit consent has been obtained, the creation of Custom Audience lists on advertising platforms such as Meta and Google),

Sending commercial electronic communications and other marketing activities are carried out only where you have given your explicit consent. You may withdraw this consent at any time by using the "unsubscribe" link included in our marketing e-mails, or by e-mailing kvkk@opus.com.tr.

Legal Basis for Processing and Method of Collection

Your personal data is processed on the basis of the following legal grounds set out in Article 5 of the Law:

a) Expressly provided for by law;

b) Necessary for the establishment or performance of a contract, provided it is directly related to the personal data of the parties to that contract;

c) Necessary for compliance with a legal obligation to which the Data Controller is subject;

d) Necessary for the establishment, exercise or protection of a right;

e) Necessary for the legitimate interests of the Data Controller, provided this does not harm your fundamental rights and freedoms.

Where explicit consent is required (in particular for marketing activities and cross-border data transfers), your data is processed on the basis of your explicit consent.

Your personal data is collected through (i) our website; (ii) e-mail and other communication channels; (iii) customer forms and calls; (iv) sales and support processes; and (v) business partners and dealers, whether verbally, in writing or electronically, using automated or non-automated methods.

You can find detailed information about the cookies used on our website in our Cookie Policy.

Transfer of Personal Data

Your personal data may be transferred, to the extent limited and proportionate to the purposes set out under "Purposes of Processing" above and in accordance with Article 8 of the Law, to administrative and official authorities, independent audit firms, tax advisors and other external professional advisors, logistics companies, audit/consultancy firms, organisations we work with for the delivery of commercial electronic communications, affiliate partners, suppliers, financial institutions, similar business partners, and domestic third parties from whom we procure services.

Transfer of Personal Data Abroad

Under Article 9 of the Law, your personal data may be transferred abroad in the following order of priority: (i) where the Turkish Personal Data Protection Board (the "Board") has issued an adequacy decision regarding the destination country, sector or international organisation; (ii) in the absence of an adequacy decision, where a Board-approved Standard Contract has been signed or other appropriate safeguards are in place; or (iii) in limited cases where such safeguards cannot be provided, on the basis of your explicit consent, given after you have been informed of the possible risks of the transfer.

On this basis, data obtained through the analytics and marketing tools used on our website (such as Google Analytics and Meta Pixel) may be transferred abroad, as the servers of these service providers are located outside Türkiye. In addition, where you have given your explicit consent, your contact details may be transferred abroad for the purpose of creating Custom Audience lists on advertising platforms such as Meta and Google, for targeted advertising purposes. You may withdraw this consent at any time by e-mailing kvkk@opus.com.tr.

"In addition, under the "Shopify Network Intelligence" feature offered by Shopify, our e-commerce infrastructure provider, customer data belonging to our store may be processed by Shopify together with data obtained from other stores, for the purposes of improving products, targeting advertisements, and providing personalisation services. Within the scope of this processing, your data is not visible to any other store; it is used solely for the purpose of improving Shopify's own services." 

Your Rights under the Law on the Protection of Personal Data

Under Article 11 of the Law, as a data subject you have the right to:

a) Learn whether your personal data is being processed;

b) Request information if your personal data has been processed;

c) Learn the purpose of processing and whether your data is used in accordance with that purpose;

d) Know the third parties, in Türkiye or abroad, to whom your personal data is transferred;

e) Request the rectification of incomplete or inaccurate personal data;

f) Request the erasure or destruction of your personal data where the legal grounds for processing no longer apply;

g) Request that the actions taken under (e) and (f) above be notified to the third parties to whom your personal data has been transferred;

h) Object to the emergence of a result to your detriment through the exclusively automated analysis of your processed data;

i) Claim compensation for damages arising from the unlawful processing of your personal data.

You may submit your requests under the Law: (i) in writing; (ii) through a notary public; (iii) via our registered electronic mail (KEP) address; (iv) via the e-mail address registered in our system, by writing to kvkk@opus.com.tr; or (v) using a secure electronic signature.

Your application will be concluded within 30 days at the latest. You may be asked to provide information or documents to verify your identity when submitting your request.

Retention Periods for Personal Data

Your personal data is retained for as long as required by the purpose of processing and the periods stipulated under applicable legislation. Accordingly:

●        Invoicing, accounting and tax records: 10 years (pursuant to the Tax Procedure Law)

●        Order and customer transaction data: 3 years (pursuant to consumer protection legislation)

●        Communication and marketing data: until consent is withdrawn, or a maximum of 3 years

●        Cookie and website usage (analytics) data: retention periods vary depending on the type of cookie used and are set out in detail in our Cookie Policy

Once the retention period has expired or the purpose of processing no longer applies, personal data is deleted, destroyed or anonymised in accordance with the Company's Personal Data Retention and Destruction Policy.

 

DATA SUBJECT APPLICATION FORM

GENERAL INFORMATION

Under Article 11 of Law No. 6698 on the Protection of Personal Data ("the Law"), a data subject ("Applicant") is granted the right to submit requests regarding the processing of their personal data.

Under Article 13(1) of the Law, applications regarding these rights must be submitted to the Company, as Data Controller, in writing or through the methods determined by the Personal Data Protection Board ("the Board").

Accordingly, applications made "in writing" may be submitted to the Company by printing this form and delivering it in person; through a notary public; via the e-mail address registered in our system; or, signed with a "secure electronic signature" as defined under Law No. 5070 on Electronic Signatures, sent to the Company's registered electronic mail (KEP) address.

Details of each written application channel are set out below.

Application Method	Address for Application	Information to Include in the Application
In Person	Esentepe Mah. Ali Kaya Sk. No:1B Polat Plaza B Blok K:11 34394 Şişli / Istanbul	The envelope should state "Request for Information under the Law on the Protection of Personal Data".
Via Notary Public	Esentepe Mah. Ali Kaya Sk. No:1B Polat Plaza B Blok K:11 34394 Şişli / Istanbul	The notification envelope should state "Request for Information under the Law on the Protection of Personal Data".
Via Registered Electronic Mail (KEP)	opusofis@hs01.kep.tr	The subject line should state "Request for Information under the Law on the Protection of Personal Data".
Via Registered E-mail	kvkk@opus.com.tr	The application must be sent from your e-mail address registered in our system; the subject line should state "Data Subject Request under the Law on the Protection of Personal Data".