Papel Commercial Customer Clarification Text
PAPEL COMMERCIAL CUSTOMER CLARIFICATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA
Maslak Mah. Eski Büyükdere Cad. Link Plaza Sitesi Link Plaza Blok No: 3-5 Interior Door No: 33 Sarıyer/İstanbul, Papel Elektronik Para ve Ödeme Hizmetleri Anonim Şirketi ("Our Company" or "Papel"), as the data controller, may process, transfer to third parties and store your general or special categories of personal data within the framework of the following purposes and conditions in accordance with the Personal Data Protection Law No. 6698 ("KVKK"). This Papel Commercial Customer Clarification Text on the Protection and Processing of Personal Data ("Clarification Text") has been prepared to inform Papel Commercial Customers about how and why we collect, process, store and transfer your personal data in Papel Corporate Account processes and to whom and for what reason.
1. Methods of Collection of Personal Data
In the following cases, we may collect your personal data from you, from the information and documents you have submitted to Papel, through the website, our call centre, public platforms or through other persons and institutions we have contracted with or through authorised public institutions and organisations, digitally or physically, in written, verbal or voice recording form, automatically or non-automatically:
(i) When you contact us via our customer service or other communication channels,
(ii) When you create a corporate account on the Papel Website,
(iii) When you apply for the use of Papel's payment services,
(iv) Through system integrations made through public institutions and organisations (BKM, KPS, APS, İKS, etc.),
(v) Judicial authorities, Revenue Administration, Republic of Turkey Ministry of Treasury and Finance, PTT, Invoice generating institutions and persons you are in contact with for your payments/collections.
(vi) Parties from whom we receive services that mediate the establishment of a contractual relationship with Papel, contracted banks and other financial institutions, our representatives, companies providing outsourced services, organisations from which services are received such as electronic commerce sites,
(vii) Through the contracts, instructions, information and documents you submit, your payment order instructions and the hardware and applications you use when you become a Papel POS Customer.
2. Processed Personal Data
Papel will process your personal data for the purposes specified in this Clarification Text. In case of any change in your personal data and/or purposes, Papel will update this Clarification Text and publish the current version separately. The personal data belonging to you as a Customer collected and used by Papel are as follows:
Data Category |
Personal Data |
Identity Data |
Name-surname, previous surname, parents' name, Turkish ID number, date of birth, name-surname, parents' name, Turkish ID number, date of birth, nationality, identity information on the identity card and/or driver's licence of the person making the application and/or company partners, VKN and title of the person who is the customer, Foreign identification number. |
Contact Data |
Telephone number, e-mail, address of the applicant, mobile phone and e-mail address of the authorised person, workplace address, workplace/mobile phone number of the workplace, mobile phone and e-mail address of the card customer, registered e-mail address. |
Financial Data |
Customer's IBAN and card number information, bank account information, prepaid card information, income and asset information, etc. |
Audio and Visual Data |
Voice Recording Data. |
Occupational Data |
Data on work and occupation, information to determine the type of workplace, introductory and explanatory information and documents related to the enterprise. |
Risk Data |
Information processed for the management of commercial, technical, administrative risks, etc. (e.g. data obtained from the Credit Bureau and Interbank Card Centre and the Merchant Registration System). |
Customer Transaction Data |
Call centre voice recordings, past transaction records, invoice information, promissory note information, order information, etc. |
Marketing Data |
Your information obtained through marketing activities. |
Legal Transaction Data |
With the permission of KVKK and IYS, judicial administrative authority requests, information in the case file, etc. |
Process Security Data |
Shopping history information, Survey, Cookie records, Information obtained through campaigns, etc. |
3. Legal Reasons and Purposes of Processing Personal Data
Your personal data are processed for the following legal reasons and purposes in accordance with the applicable legislation and KVKK. The main processing purposes and legal reasons of your personal data may be updated due to changes in our company policies and legislation:
Category of Personal Data Processed |
Processing Purposes |
Legal Reasons |
Identity, Communication, Customer Transaction, Finance, Transaction Security, Risk; |
In order to conclude agreements regarding the payment methods you have requested within the scope of your corporate account application, to receive and evaluate your applications and requests and to provide you with our products and services, to carry out, execute and develop the necessary transactions in order to provide our products and services to you, execution of the contracts that we have concluded with you regarding the execution of operational processes or that we have concluded with third parties in order to provide you with these products and services, to improve our services and to manage operational requirements, to fulfil our contractual and legal obligations, to perform accounting and financial transactions in order to protect our customers from risks and damages with our website, application and other platforms where we offer our products / services; |
Pursuant to Article 5/2 (a) of the KVKK, it is explicitly stipulated by law, pursuant to Article 5/2 (c) of the KVKK, it is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract, pursuant to Article 5/2 (ç) of the KVKK, it is mandatory for the data controller to fulfil its legal obligation, pursuant to Article 5/2 (e) of the KVKK, data processing is mandatory for the establishment, exercise or protection of a right; |
Identity, Communication, Legal Action, Audio and Visual, Customer Action; |
To carry out communication and information processes regarding our products and services that you benefit from as your corporate account customer; to manage all requests and complaints including notifications such as customer relations, experience, satisfaction, complaints, objections, requests, suggestions, to inform you about the terms of use and other contractual and legal obligations, to prevent fraud and unauthorised access, and to follow up and execute all legal processes;
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Pursuant to Article 5/2 (a) of the KVKK, it is explicitly stipulated by law, pursuant to Article 5/2 (c) of the KVKK, it is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract, pursuant to Article 5/2 (ç) of the KVKK, it is mandatory for the data controller to fulfil its legal obligation, pursuant to Article 5/2 (e) of the KVKK, data processing is mandatory for the establishment, exercise or protection of a right; |
Identity, Communication, Transaction Security, Legal Transaction, Customer Transaction, Professional, Risk, Finance; |
To check the national and international lists published in accordance with the legislation on Prevention of Laundering Proceeds of Crime and Financing of Terrorism and Prevention of Financing the Proliferation of Weapons of Mass Destruction, to fulfil the obligations regarding identification and customer recognition, to record information such as business occupation, income status, purpose of making transactions, especially identification and address determination and confirmation, to make suspicious transaction notifications, to carry out compliance processes in accordance with foreign legislation;
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Pursuant to Article 5/2 (a) of the KVKK, it is explicitly stipulated by law, pursuant to Article 5/2 (c) of the KVKK, it is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract, pursuant to Article 5/2 (ç) of the KVKK, it is mandatory for the data controller to fulfil its legal obligation;
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Identity, Communication, Legal Action, Risk Management, Finance, Customer Transaction, Transaction Security; |
In order to comply with the legislation to which Papel is subject and to cooperate with regulatory bodies and law enforcement agencies, to fulfil our obligations to provide information, record keeping, reporting and other obligations arising from the legislation (Law No. 6493, Banking Law No. 5411, Banking Law No. 5464, Bank Cards and Credit Cards Law No. 5464 and the legislation on Prevention of Laundering Proceeds of Crime and Financing of Terrorism, MASAK General Communiqué No. 5, Law No. 6563 on the Regulation of Electronic Commerce and its regulations, CBRT, BRSA, CMB, MASAK, GİB, Central Registry Agency Inc. No. 5 MASAK General Communiqué, Law No. 6563 on the Regulation of Electronic Commerce and its regulations, CBRT, BRSA, CMB, MASAK, RA, Central Registry Agency Inc, Ministry of Treasury and Finance, Credit Bureau, TBB Risk Centre and other authorities); |
Pursuant to Article 5/2 (a) of the KVKK, it is explicitly stipulated by law, and pursuant to Article 5/2 (ç) of the KVKK, it is mandatory for the data controller to fulfil its legal obligation; |
Identity, Contact, Customer Transaction, Audio and Visual Records; |
For the management, planning and realisation of relationships and processes established with service providers, business partners, our representatives, companies we represent or suppliers; |
Pursuant to Article 5/2 (c) of the KVKK, provided that it is directly related to the establishment or performance of a contract, it is necessary to process personal data belonging to the parties to the contract; |
Identity, Communication, Finance, Marketing, Customer Transaction; |
Regarding the products and services of Papel itself or its domestic and foreign direct and indirect subsidiaries and other shareholders, including its main shareholder, and their subsidiaries, affiliates, subsidiaries and the organisations with which it cooperates, in whose favour it acts as an intermediary or agent, or which are or are the representatives of Papel; in particular, products and services subject to payment services activities and products and services offered together with the aforementioned companies; To explain and market the aforementioned products and services, to plan and carry out marketing, promotion and communication activities, to offer offers through all channels including digital channels and social media channels, to carry out promotion, marketing, promotion, cross-selling and campaign activities and to design marketing and promotional activities specific to you, to carry out credit, behavioural scoring, market research, data analytics studies for marketing purposes to determine and develop suitable products and services to be offered to you, customer satisfaction; |
Having your explicit consent in accordance with Article 5(1) of KVKK. (If you withdraw your explicit consent, data processing and transfer activities will be terminated by Papel for the specified purposes). |
4. Transfer of Personal Data to Third Parties
Your personal data are shared with the following parties for the following purposes, provided that we comply with the conditions stipulated in Articles 4 and 8 of the KVKK and take the necessary security measures:
Transferred Party |
Transfer Purpose |
Business Partners, Agents, Suppliers and External Service Providers; |
Your personal data may be shared with cooperating companies, representatives, suppliers, outsourcing companies, cloud computing service providers, mobile service providers authorised by the Information and Communication Technologies and Communications Authority in order to ensure your transaction security and to provide and deliver the products and services we have offered you / you have requested from us, lawyers, law offices, notaries, company auditors, independent audit, rating and valuation companies in order to fulfil legal processes and our legal obligations. |
Public Institutions and Organisations; System Integrations Shared through Public Institutions and Organisations; |
Central Bank of the Republic of Turkey, Banking Regulation and Supervision Agency, Personal Data Protection Authority / Board, Capital Markets Board, MASAK, TÖDEB, Banks Association of Turkey, KOSGEB, Revenue Administration, Undersecretariat of Treasury, Information Technologies and Communication Authority, Social Security Institution, if we are legally obliged, Your personal data may be shared with legally authorised public or private institutions/organisations such as tax authorities, ministries, judicial authorities, police, public prosecutors' offices, courts and judicial authorities/investigation authorities such as arbitration/mediation bodies in order to fulfil our legal obligations. In addition, your personal data may be shared in order to process your applications correctly within the framework of customer identification obligations (Identity Sharing System, Address Based Population Registration System, etc.) and to make inquiries in the systems for your security. |
Banks, Payment Service Providers, Card System Organisations and other Financial Institutions; |
It may be shared with banks providing POS, Papel business partners, Papel representatives and persons, institutions and/or organisations on whose behalf and account we carry out representation activities in order to fulfil our obligations arising from representation activities. In addition, it may be shared with financial institutions that are members of the payment programme in order to carry out payment transactions or are involved in the payment making business required for certain types of payments in order to provide the products and services you have requested or to fulfil your request. |
Risk Centres (such as BKM, KKB) |
Your personal data may be shared for the purposes of risk management, management of risk monitoring activities and fulfilment of our legal obligations (for example, reporting your information to BKM to be recorded in the "merchant registration system" that BKM is obliged to create in accordance with the legislation). |
Business Partners, Suppliers and External Service Providers; |
In the presence of your explicit consent, your personal data in the categories of identity, communication, customer transaction, finance and marketing will be transferred to Papel's domestic and foreign service providers in order to design, plan and execute campaigns, promotions, product service promotion processes and to communicate for these purposes. |
5. Your Rights as a Personal Data Owner
Pursuant to Article 11 of the KVKK, you have the following rights as a personal data owner:
(i) To learn whether your personal data is being processed or not,
(ii) Requesting information if your personal data has been processed,
(iii) To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
(iv) To know the third parties to whom your personal data are transferred domestically or abroad,
(v) To request correction of your personal data in case of incomplete or incorrect processing,
(vi) To request the deletion or destruction of your personal data in case the reasons requiring their processing disappear,
(vii) Request notification of correction and deletion to third parties to whom your personal data are transferred,
(viii) Object to the occurrence of a result that is to your detriment by analysing personal data exclusively through automated systems,
(ix) In case you suffer damage due to unlawful processing of your personal data, to request compensation for your damage.
Pursuant to Article 13 of the KVKK, if you wish to exercise any of your rights mentioned above as a personal data owner, you may submit your request in the following ways by filling out your request in accordance with the instructions written in the data owner application form on our Company's website.
(i) "Maslak Mah. Eski Büyükdere Cad. Link Plaza Site Link Plaza Block No: 3-5 Interior Door No: 33 Sarıyer/İstanbul" in person or through a notary public or
(ii) by registered electronic mail (KEP) to our registered e-mail address "papelelektronik@hs01.kep.tr" or
(iii) by using secure electronic signature, mobile signature or your e-mail address previously notified to us and registered in our system to our e-mail address "destek@papel.com.tr"
Sincerely,
Papel Elektronik Para ve Ödeme Hizmetleri Anonim Şirketi