Corporate General Clarification Text on the Processing of Personal Data

As Cebir Giyim San. ve Tic. Ltd. Şti (“Maraton Sportswear”), we have prepared this clarification text to inform our Visitors, Online Visitors, Customers, Potential Customers, Supplier Employees, and Supplier Representatives regarding the processing, storage, and transfer of personal data within the scope of the Law No. 6698 on the Protection of Personal Data (“KVKK”) and related legal regulations.

1) What Categories of Personal Data Do We Process and For What Purposes?

Your personal data is processed by Cebir Giyim San. ve Tic. Ltd. Şti (“Maraton Sportswear”) in accordance with the principles set forth in Article 4.2 of KVKK:

Lawfulness and fairness
Accuracy and, where necessary, up-to-date
Processing for specific, explicit, and legitimate purposes
Relevance, limitation, and proportionality to the purpose of processing
Retention for the period required by relevant legislation or the purpose of processing

Depending on the nature of our business relationship, individuals may fall into more than one category. Personal data may be processed for the purposes outlined below:

Visitors

Identity information (e.g., name, surname) and physical space security data (e.g., CCTV recordings) are processed for:

Visitor registration and tracking
Ensuring physical security of premises

Online Visitors

For users accessing our website, the following data may be processed:

Transaction security data (e.g., IP address)
Marketing data (e.g., browsing history, cookie records)
Identity and contact information (e.g., email address), if voluntarily provided

Purposes include:

Compliance with legal obligations
Execution of information security processes
Handling requests and complaints
Communication activities
Providing information to authorized persons, institutions, and organizations
Enabling access to our website

Customers

For individual customers or representatives/employees of corporate customers, the following data may be processed:

Identity and contact information
Customer transaction data (e.g., order details)
Physical space security data
Financial data (e.g., balance sheets)
Legal transaction data
Marketing data (e.g., purchase history)

Purposes include:

Compliance with legal obligations
Financial and accounting operations
Execution and supervision of business activities
Logistics operations
After-sales support services
Sales processes
Marketing analysis
Contract management
Providing information to authorized bodies
Ensuring physical security
Resolving legal disputes
Archiving and data retention
Risk management
Advertising, campaign, and promotional activities
Sending commercial electronic messages
Customer loyalty management
Communication activities

Potential Customers

For potential individual or corporate customers, the following data may be processed:

Identity and contact information
Customer transaction data
Physical space security data
Marketing data

Purposes include:

Management of sales processes
Contract execution
Ensuring physical security
Advertising, campaign, and promotional activities
Sending commercial electronic messages
Your personal data may be processed for the purpose of conducting marketing analysis activities.Supplier Employees

We may process the identity, contact, and physical security data of our supplier employees for the following purposes:

Execution of communication activities
Execution and supervision of business operations
Ensuring physical premises security
Management of supply chain processes
Execution of logistics operations
Compliance with legal obligations
Execution of occupational health and safety procedures

Supplier Representatives

We may process the identity, contact, physical security, customer transaction, financial, marketing, and legal transaction data of individual suppliers or representatives of corporate suppliers for the following purposes:

Execution and supervision of business operations
Execution of goods/services procurement processes
Execution of financial and accounting operations
Execution of contract processes
Execution of investment processes
Ensuring physical premises security
Management and follow-up of legal affairs

2) Methods of Collecting Your Personal Data

Your personal data, as categorized above, may be collected through physical means such as order forms, contracts, and visitor forms, or via information systems and electronic devices (e.g., telecommunications infrastructure, computers, and phones), third parties (e.g., KKB and Findeks), our website, and other documents provided by the data subject. Data may be collected through automated or non-automated means.

3) Legal Basis for Processing Your Personal Data

Your personal data is processed by Cebir Giyim San. ve Tic. Ltd. Şti. (“Maraton Sportswear”) based on the legal grounds specified in Article 5 of KVKK, in line with the purposes outlined above:

Explicitly stipulated by law
Necessity for the performance or establishment of a contract
Necessity for the data controller to fulfill legal obligations
Necessity for the establishment, exercise, or protection of a right
Provided it does not harm the fundamental rights and freedoms of the data subject, necessity for the legitimate interests of the data controller

4) Do We Share Your Personal Data with Third Parties?

Personal data of our visitors may be shared with law enforcement agencies and judicial authorities in the event of legal disputes or upon request in accordance with applicable legislation.
Personal data of our online visitors may be shared with judicial authorities and authorized public institutions and organizations for the resolution of legal disputes or upon lawful request.
Personal data of our customers may be shared with authorized public institutions and organizations for the purposes of legal compliance, execution and follow-up of legal affairs, and provision of information to authorized entities. Additionally, to ensure proper execution of our services, data may be shared with group companies, IT service providers, suppliers, shipping companies, insurance providers, banks, and our financial advisor. Such data may also be transferred to our legal counsel and judicial authorities for use as evidence in potential future legal disputes.
Personal data of our potential customers may be shared with our legal counsel and judicial authorities for use as evidence in potential future legal disputes.
Personal data of our supplier employees may be shared with authorized public institutions and organizations for legal compliance, execution and follow-up of legal affairs, and supervision of business activities. To ensure proper service delivery, data may also be shared with group companies, IT service providers, suppliers, shipping companies, banks, and our financial advisor. Additionally, such data may be transferred to our legal counsel and judicial authorities for use as evidence in potential future legal disputes.
Personal data of our supplier representatives may be shared with authorized public institutions and organizations for legal compliance, execution and follow-up of legal affairs, and supervision of business activities. To ensure proper service delivery, data may also be shared with group companies, IT service providers, suppliers, shipping companies, banks, and our financial advisor. Additionally, such data may be transferred to our legal counsel and judicial authorities for use as evidence in potential future legal disputes.

5) How Can You Exercise Your Rights Regarding Personal Data?

In accordance with Article 11 of the Law on the Protection of Personal Data (KVKK), you may submit your requests regarding your personal data to Cebir Giyim San. ve Tic. Ltd. Şti (“Maraton Sportswear”) using the “Application Form to the Data Controller,” which has been prepared for your convenience and is available at:

maratonsw.com
cebirtekstil.com

Data Controller: Cebir Giyim San. ve Tic. Ltd. Şti. (Maraton Sportswear)

Address: Mahmutbey Mahallesi, 2567. Sokak No:6, Bağcılar / Istanbul

Email: [email protected]