The protection of personal data is among the highest priorities of OPUS KİMYA A.Ş. (the "Company"), which operates under the INEA brand and is 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 by 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, tax ID / national 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, and device and browser information relating to your use of the website, as well as interaction data obtained through hCaptcha, which we use to protect our forms against bots and abuse

vi. Marketing and Advertising Data (where you have given explicit consent): Your e-mail address, phone number and address transmitted to advertising platforms in hashed form, and ad interaction and conversion (purchase) data

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 and issue reports,

●        Collecting post-order customer satisfaction reviews,

●        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 evaluations within the Company,

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

●        Protecting our website and forms against bots and abuse, and carrying out information security processes,

●        Carrying out marketing activities,

●        Providing information in response to requests from competent authorities on matters of public security,

●        Fulfilling legal obligations and enabling the exercise of rights arising from applicable legislation,

●        Carrying out targeted digital advertising (where you have given explicit consent, including the creation of custom audience lists on advertising platforms such as Meta and Google),

●        Measuring advertising and campaign performance, conversion tracking and remarketing (where you have given explicit consent).

In addition, the sending of commercial electronic messages and marketing activities are carried out only where you have given explicit consent. You may withdraw your explicit consent at any time by using the "unsubscribe" link in the e-mails sent to you or by writing to kvkk@opus.com.tr.

Legal Basis for Processing and Method of Collection

Your personal data is processed on the legal bases set out in the table below, in accordance with Article 5 of the Law:

Purpose of Processing	Legal Basis
Sales, payment collection, delivery, logistics, customer service and after-sales processes	Article 5(2)(c) of the Law (necessary for the establishment or performance of a contract)
Invoicing, accounting and tax records; responding to requests from legal authorities	Article 5(2)(a) (expressly provided for by law) and Article 5(2)(ç) (necessary for compliance with a legal obligation)
Management of legal claims and disputes	Article 5(2)(e) (necessary for the establishment, exercise or protection of a right)
Risk management, operational activities, reporting and statistics, website and form security (including hCaptcha), measurement of customer satisfaction	Article 5(2)(f) (legitimate interests of the data controller)
Marketing, commercial electronic messages, targeted advertising, custom audiences, ad performance measurement and remarketing, analytics and marketing cookies	Explicit consent (Article 5(1))

 

Where explicit consent is required (in particular for marketing activities, ad performance measurement and transfers abroad), your data is processed on the basis of your explicit consent.

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

For detailed information on the cookies used on our website, please see our Cookie Policy.

Transfer of Personal Data

Your personal data may be transferred to administrative and official authorities, independent auditors, tax advisers and other external professional advisers, transport companies, auditing and consulting firms, organisations with which we have agreements for sending commercial electronic messages, programme partner organisations, suppliers, financial institutions, similar business partners, and domestic third-party service providers, limited and proportionate to the purposes stated under "Purposes of Processing" and in accordance with Article 8 of the Law.

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 Personal Data Protection Board (the "Board") has issued an adequacy decision regarding the country, sector or international organisation to which the transfer will be made; (ii) in the absence of an adequacy decision, where a Standard Contract approved by the Board has been signed or other appropriate safeguards have been provided; (iii) in limited cases where the above safeguards cannot be provided, with your explicit consent given after you have been informed of the possible risks of the transfer.

In this context, data obtained through the analytics and marketing tools used on our website (Google Analytics, Meta Pixel, etc.) may be transferred abroad because the servers of these service providers are located abroad.

On our website, hCaptcha is used to secure our forms; Shopify for our e-commerce infrastructure; and Google (Analytics, Ads, Customer Reviews) and Meta services for measurement, advertising and customer reviews. These service providers may process your data on servers located abroad. Where you have given explicit consent, your e-mail address, phone number and address may be transmitted in hashed form to Google and Meta and used to measure advertising performance and to create custom audience lists. You may withdraw the explicit consent you have given in this context at any time by writing to kvkk@opus.com.tr.

In addition, under the "Shopify Network Intelligence" feature offered by our e-commerce infrastructure provider Shopify, customer data relating to our store may be processed by Shopify, together with data obtained from other stores, for the purposes of providing product development, ad targeting and personalisation services. Within this processing, your data is not visible to any other store and is used solely for Shopify's own service improvement.

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 your personal data if it is incomplete or inaccurate,

f) Request the erasure or destruction of your personal data where the reasons requiring its processing no longer exist,

g) Request that the operations carried out under (e) and (f) be notified to the third parties to whom your personal data has been transferred,

h) Object to a result that is to your detriment arising from the exclusively automated analysis of your data,

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

You may submit your requests under the Law to the Company (i) in writing; (ii) through a notary; (iii) via registered electronic mail (KEP); (iv) from your registered e-mail address to kvkk@opus.com.tr; or (v) with a secure electronic signature.

Your application will be concluded as soon as possible depending on the nature of the request and within 30 days at the latest, free of charge. However, if the process requires an additional cost, a fee may be charged according to the tariff set by the Board.

Retention Periods

Your personal data is retained for the period required by the purpose of processing and the periods prescribed by applicable legislation. In this context:

●        Invoice, accounting and tax records: 10 years (under the Tax Procedure Law)

●        Order and customer transaction data: 3 years (under consumer legislation)

●        Communication, marketing and ad measurement data: Until withdrawal of explicit consent or 3 years at most

●        Cookie and site usage (analytics) data: Varies depending on the type of cookie and is specified in our Cookie Policy

When the retention period expires or the purpose of processing ceases to exist, 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

Article 11 of Law No. 6698 on the Protection of Personal Data (the "Law") grants the person defined as the data subject (the "Applicant") the right to make requests for information regarding the processing of their personal data.

Under Article 13(1) of the Law, applications relating to these rights must be submitted to the Company, as data controller, in writing or by other methods determined by the Board.

Accordingly, applications made to the Company "in writing" may be submitted by printing out this form, in person, through a notary, from the e-mail address registered in our system, or by signing it with a "secure electronic signature" as defined in the Electronic Signature Law No. 5070 and sending it to the Company's registered electronic mail address.

The written application channels and how applications should reach us are set out below.

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