1. Notice given in the capacity of data controller
As Zenith Sigorta Aracılık Hizmetleri Limited Şirketi, whose corporate details are published below, and in the capacity of Data Controller under Law No. 6698, your personal data may be recorded, stored, updated, disclosed or transferred to third parties where legislation permits, classified and otherwise processed in the ways set out in the KVKK, within the framework explained on this page.
2. How your personal data may be processed
Under Law No. 6698, the personal data you share with Zenith Sigorta Aracılık Hizmetleri Limited Şirketi and through www.zenith.com.tr may be processed by us wholly or partly by automated means, or by non-automated means forming part of a data recording system — obtained, recorded, stored, altered and reorganised; in short, subjected to every kind of operation performed on data. Under the KVKK, any such operation is treated as “processing of personal data”.
3. Purposes and legal grounds of processing
The personal data you share is processed:
- To perform the services we provide to our clients in a manner consistent with the contract and with current technology, to present offers for our products and services and to issue policies;
- To record identity, address and other necessary information in order to establish the identity of the transacting 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 Official Gazette No. 29457 of 26.08.2015, the Distance Contracts Regulation published in Official Gazette No. 29188 of 27.11.2014, and other relevant legislation;
- To prepare all records and documents required as the basis of payment systems, electronic contracts or paper transactions in the field of banking and electronic payment, and to comply with obligations of record keeping, reporting and notification imposed by legislation and by other authorities;
- To provide information to public prosecutors, courts and relevant public officials on request and as required by legislation, in matters of public security and legal disputes;
- To offer members a broad range of opportunities, or to share data within a lawful framework with persons or institutions able to offer them;
in accordance with Law No. 6698 and its secondary legislation.
4. Third parties and organisations to whom data may be transferred
For the purposes stated above, the persons and organisations to whom the personal data you share with Zenith Sigorta Aracılık Hizmetleri Limited Şirketi may be transferred are: our principal shareholders and shareholders; our direct or indirect domestic and international affiliates; primarily member firms using the www.zenith.com.tr infrastructure and, without limitation, persons and organisations connected with the service provided; solution partners, domestic and international organisations and other third parties from whom we receive services or with whom we co-operate in order to carry out our activities, including in the capacity of Data Processor.
5. How your personal data is collected
Your personal data may be processed and collected:
- Through forms on the www.zenith.com.tr website and mobile applications, in the form of information such as name, surname, national identity number, address, telephone, business or personal email address; together with preferences on pages accessed using a username and password, IP records of transactions carried out, cookie data collected by the browser, data covering browsing duration and detail, and location data;
- From persons who share their personal data with Zenith Sigorta Aracılık Hizmetleri Limited Şirketi for purposes such as establishing a commercial relationship, making a job application or submitting an offer — by business card, curriculum vitae or otherwise — in a physical or virtual environment, face to face or at a distance, verbally, in writing or electronically;
- In addition, from data obtained indirectly through other channels: websites, blogs, competitions, surveys, games, campaigns and similar (micro) websites and social media; newsletter opening or click activity; data made available by publicly accessible databases; and publicly visible profiles and data on social media platforms such as Facebook, Twitter, Google, Instagram and Snapchat.
6. Personal data obtained before the KVKK came into force
Personal data lawfully obtained before 7 April 2016, the date on which the KVKK entered into force — through membership, consent to electronic messages, the purchase of products or services or otherwise — is also processed and stored in accordance with the terms and conditions set out in this document.
7. Transfer of your personal data
Personal data collected by any of the methods listed above, whether processed in Turkey or processed and stored outside Turkey, may also be transferred to service intermediaries located abroad — in countries accredited by the Personal Data Protection Board and offering an adequate level of protection for personal data — while remaining within the scope of the KVKK and in a manner consistent with the purposes of the contract.
Your personal data may be transferred to:
- Business partners and suppliers with whom we co-operate or from whom we receive services for the provision and promotion of products and services, together with banks, financial institutions, the Banks Association of Turkey Risk Centre and other natural or legal persons;
- Competent authorities able to establish your location in the event of an emergency call;
- Lawyers, auditors, consultants and other third parties from whom services are received;
- Attorneys and representatives authorised by you;
- Regulatory and supervisory authorities, and official bodies such as courts and enforcement offices, together with other public institutions entitled to request your personal data;
- Legal persons in a commercial relationship with Zenith Sigorta Aracılık Hizmetleri Limited Şirketi that hold your telephone number;
- Banks and similar financial institutions, in respect of information such as SIM card changes and the telephone number connected to mobile internet, for the purpose of transaction and information security and identity verification during banking and similar financial transactions carried out over your mobile line;
- Where you hold a verified account, legal persons such as financial institutions, telecommunications companies, law offices and municipalities that hold various items of your information, so that they may make critical notifications to you and reach you for promotional, marketing and similar purposes.
8. Storage and protection of personal data
Under Article 12 of the KVKK, Zenith Sigorta Aracılık Hizmetleri Limited Şirketi is obliged to prevent the unlawful processing of personal data held in its systems and databases, to prevent unauthorised access, and to take software measures such as hashing, encryption, transaction logging and access management, together with physical security measures, in order to ensure their preservation. Should it become known that personal data has been obtained by others through unlawful means, the Personal Data Protection Board will be notified immediately, in writing and in accordance with legislation.
9. Keeping personal data accurate and up to date
Article 4 of the KVKK imposes an obligation to keep personal data accurate and up to date. Accordingly, in order for obligations arising under applicable legislation to be met, our clients are required to share accurate and current data, or to update it through the website or mobile application.
10. Rights of the data subject under Law No. 6698
Article 11 of Law No. 6698 came into force on 7 October 2016. Under that article, the rights of the Data Subject from that date are as follows:
The Data Subject may apply to Zenith Sigorta Aracılık Hizmetleri Limited Şirketi (the data controller) and, in relation to themselves:
- Learn whether their personal data is being processed;
- Request information if their personal data has been processed;
- Learn the purpose of processing and whether the data is used in accordance with that purpose;
- Know the third parties to whom their personal data has been transferred, in Turkey or abroad;
- Request correction where personal data has been processed incompletely or inaccurately;
- Request erasure or destruction of personal data within the conditions set out in Article 7 of the KVKK;
- Request that any correction, erasure or destruction be notified to third parties to whom the personal data has been transferred;
- Object to an outcome adverse to them arising from analysis of the processed data exclusively by automated systems;
- Claim compensation for loss suffered as a result of unlawful processing of their personal data.
11. Contact and how to apply
All services provided on our website www.zenith.com.tr belong to and are operated by Zenith Sigorta Aracılık Hizmetleri Limited Şirketi, registered at 19 Mayıs Mahallesi Sümer Sokak Zitaş Blokları C5 Blok, Kozyatağı, Kadıköy, Istanbul.
Requests under the KVKK may be sent by petition to the address stated above, by registered post with return receipt.
Zenith Sigorta Aracılık Hizmetleri Limited Şirketi may respond to requests received, positively or negatively, in writing or by digital means, provided that the response is reasoned and given within 30 days. As a rule the necessary operations are carried out free of charge. Where an operation entails a cost, Zenith Sigorta Aracılık Hizmetleri Limited Şirketi reserves the right to request a fee, determined on the tariff set by the Personal Data Protection Board under Article 13 of the Law on the Protection of Personal Data.
By sharing your personal data on our website, in our applications and through our other channels, you declare that you accept our Personal Data Policy and the terms it contains regarding processing, methods of processing, transfer and sale of data and other related matters; the use of that data on the website, in applications and on social media channels; the making of notifications and recommendations; that it may be shared commercially with third parties provided this is to the benefit of members; and that you will apply to Zenith Sigorta Aracılık Hizmetleri Limited Şirketi before exercising your legal rights — by an express consent, defined in the KVKK as “consent relating to a specific subject, based on information and expressed with free will”.