Privacy Policy
ENGLISH
This is a joint Data Protection Notice provided by D Et ve Et Ürünleri Gıda Pazarlama Tic. A.Ş. (“D Et”) and Nusret UK LTD. (“Nusret UK”) pursuant to the UK General Data Protection Regulation and Data Protection Act 2018 (“Data Protection Law”) and when we refer to “Nusr-et” or “we” or “us” we mean the two of us. It confirms that D Et and the Nusret UK jointly determine the purposes and means of processing of your personal data as joint controllers. This means that both businesses work together to decide why and how your personal data is processed via website for the purposes stated in this Data Protection Notice.
We are committed to protect the privacy and security of your personal data as a data controller. Therefore, we are committed to ensuring that your personal data is handled in accordance with the principles set out in the Data Protection Law. This Data Protection Notice explains how we collect, use, disclose, retain and protect your personal data.
2. WHEN DOES THIS DATA PROTECTION NOTICE APPLY?
This Data Protection Notice applies to your personal data that we collect, use and process in connection with the transaction you take when you visit our website www.nusr-et.com.tr as a website visitor, job applicants, customer or potential customer.
3. HOW DO WE COLLECT PERSONAL DATA?
We may obtain your personal data from the following sources:
a) from you directly: (for example, at the time of subscribing to any services offered on our website, including but not limited to email mailing lists, interactive services or requesting further goods or services);
and/or
b) from your device or browser: data that is automatically collected (which will vary depending on your browser settings) by your browser or device, for example, the IP address of your internet service provider, the operating system you use, the name and version of your internet browser. The information provided by your browser does not identify you personally;
c) from correspondence with us (for example, by e-mail or any other digital or electronic form, including social media).
If you contact us, we may keep a record of that correspondence.
4. CATEGORIES OF PERSONAL DATA AND PURPOSES AND LAWFUL BASIS FOR PROCESSING
We may process your personal data in different ways. In all cases we are committed to protecting your personal data. In each of the subheadings listed below, we describe how we obtain your personal data and how we treat it.
4.1. WEB SITE VISITORS
We may collect personal data related to web site visitors.
4.1.1. Personal data that we collect and process
| Category of Personal Data | Personal Data |
|---|---|
| Personal Identification Data | First name, last name, date of birth |
| Contact Information Data | E-mail address |
| Technical Data | This is data about your computer hardware and software that is automatically collected by us such as; device type (eg mobile, computer, laptop, tablet), browser information (e.g. browser type, language and history), IP address, operating system, access times, settings and referring website addresses. |
| Marketing Data | Cookie data (for more information please see our Cookie Policy) |
4.1.2. Why do we collect your personal data and what are our lawful bases for it?
| Purpose of Data Processing | Lawful Basis |
|---|---|
| Provide our website services to website users | Legitimate Interest |
| To comply with all applicable law and fulfil our obligations arising thereunder, including but not limited to keeping records/filing notifications as required under the law and to fulfil our obligations regarding keeping internet access data logs, and to communicate with relevant governmental authorities | To comply with legal obligations. |
| Monitor any external security threats to our systems (such as hacks) | Legitimate Interest |
| Remembering website users’ preferences | Your prior consent |
| Marketing and advertising | Your prior consent |
| To carry data enrichment processes for more effective marketing activities | Your prior consent |
| To provide Personalized Advertising Services | Your prior consent |
4.1.3. How long do we keep your personal data?
We will keep your personal data only for as long as is necessary for the purposes for which it was collected in connection with your requests via our website or your use of our website.
4.2. JOB APPLICANTS
We may collect personal data related to job applicants for positions advertised on our website.
4.2.1. Personal data that we collect and process
| Category of Personal Data | Personal Data |
|---|---|
| Personal Identification Data: | Name, surname, date of birth, place of birth, ID number, marital status, nationality. |
| Contact Information Data: | Cell phone number, home phone number, personnel e-mail, address information. |
| Information relating to performance and training: | Curriculum Vitae, education information, certificate of employment records, work and performance details, professional and personal skills, interview and employment reviews. |
| Your Professional Experience: | Profession details, diploma information. |
| Visual and Audio Records | Photograph, visual records (video records), voice records. |
| Information Obtained from your Reference: | Reference complaint, feedback and appreciation. |
| Your Special Categories of Personal Data: | Personal health records and criminal record. |
4.2.2. Why do we collect your personal data and what are our lawful bases for it?
| Purpose of Data Processing | Lawful Basis |
|---|---|
| Evaluation of your application | Performance of a contract with you or to take steps at your request, before entering a contract |
| Storage of candidates’ data for future openings | Your prior consent Your prior consent for special categories of personal data |
| Execution of reference check | Company’s legitimate interest. |
4.2.3. How long do we keep your personal data?
We will keep and process your Personal Data only for as long as is necessary for the purposes for which it was collected. If you are successful and we hire you, we will keep your CV as part of your employee record for the duration of your employment with us. We will keep CVs and documents submitted by unsuccessful candidates for no longer than 2 years, unless we obtained their consent to keep it for longer.
4.3. CUSTOMER
We may collect personal data related to our existing customers.
4.3.1. Personal data that we collect and process
| Category of Personal Data | Personal Data |
|---|---|
| Personal Identification Data: | Name, surname, date of birth. |
| Contact Information Data: | Phone number, e-mail. |
| Customer Operation Details: | Customer complaint, request and appreciation, invoice details, order details, request details. |
| Marketing Information | Surveys, information that is obtained from campaign study. |
| Your Financial Information: | Card details |
In case the health data, which is considered sensitive personal data, is shared by you during our processing activities, it shall be processed on the legal basis of your explicit consent, in order to evaluate your requests. Apart from the aforementioned data, no personal data is processed except for the ones you voluntarily provide us during our services.
4.3.2. Why do we collect your personal data and what are our lawful bases for it?
| Purpose of Data Processing | Lawful Basis |
|---|---|
| Conducting reservation process | Performance of a contract with you or to take steps at your request, before entering a contract. |
| Execution of request, complaint and satisfaction management processes | Company’s legitimate interest. |
| Execution of communication activities | Performance of a contract with you or to take steps at your request, before entering a contract. |
| Informing the law enforcement in case of crime or illegality | To comply with legal obligations. |
| To send updates about the Nusr-Et products and services by e-mail or SMS | Your prior consent. |
| To carry data enrichment processes for more effective marketing activities | Your prior consent |
| To provide Personalized Advertising Services | Your prior consent |
4.3.3. How long do we keep your personal data?
We will Process your Personal Data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.
4.4. POTENTIAL CUSTOMER
We may collect personal data related to potential customers.
4.4.1. Personal data that we collect and process
| Category of Personal Data | Personal Data |
|---|---|
| Personal identification data | First name, last name |
| Contact information data | Cell phone number, email address |
4.4.2. Why do we collect your personal data and what are our lawful bases for it?
| Purpose of Data Processing | Lawful Basis |
|---|---|
| To make a reservation | Performance of a contract with you or to take steps at your request, before entering a contract |
| To send updates about the Nusr-Et products and services by e-mail or SMS | Your prior consent. |
| To carry data enrichment processes for more effective marketing activities | Your prior consent |
| To provide Personalized Advertising Services | Your prior consent |
4.4.3. How long do we keep your personal data?
We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defence of legal claims.
5. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
Affiliates
We may share your personal data with D Et ve Et Ürünleri Gıda Pazarlama Tic. A.Ş to use the same guest management and IT systems; to provide personalized advertising and data enrichment services. Such transfers are governed by Data Protection Law compliant agreements between the affiliates for the protection, integrity and confidentiality of personal data.
Service Providers
We may disclose information about you to organisations that provide services for us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the Data Protection Law and other relevant data protection laws.
- We may share your information with the following types of service providers:
- technical support providers who assist with our servers and IT infrastructure,
- third party software providers, where the provider hosts the relevant personal data on our behalf;
- professional advisers including but not limited to solicitors, accountants, tax advisors, auditors and insurance brokers;
- service providers that assist us in providing our services.
Law Enforcement or Government Bodies
We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of employment agreements, or as required by law.
6. TRANSFERS OF PERSONAL DATA OUTSIDE THE UK
We share personal data with external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. Where these vendors are located within the UK, we ensure that they are contractually obligated to comply with the UK data protection rules. We also ensure in our contracts with these organisations that they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.
We share personal data with the Nusr-Et busines partners and affiliates located outside the UK. Where these countries are not recognised as locations providing adequate protection for personal data, we sign the UK adjusted EU Commission-approved contract (so called Standard Contractual Clauses) to protect your data or where necessary obtain your consent as required by UK GDPR to be able to transfer lawfully.
7. LINKS TO OTHER WEBSITES
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Data Protection Notice. Nusr-et has a presence on social media (Facebook, Twitter, YouTube etc.) and you can interact with us through your existing social media accounts and their relevant privacy policies.
8. YOUR DATA PROTECTION RIGHTS
You have the following rights in relation to your personal data in accordance with the provisions of Section 3 of UK GDPR;
- Ø Right to be informed: organisations must tell individuals what data of theirs is being collected, how it is being used, how long it will be kept and whether it will be shared with any third parties.
- Ø Right of access: individuals have the right to request a copy of the information that an organisation holds on them.
- Ø Right of rectification: individuals have the right to correct data that is inaccurate or incomplete.
- Ø Right to erasure and right to be forgotten: in certain circumstances, individuals can ask organisations to erase any personal data that is stored on them, including the Internet.
- Ø Right of portability: individuals can request that organisation transfer any data that it holds on them to another company.
- Ø Right to restrict processing: individuals can request that an organisation limits the way it uses personal data.
- Ø Right to object: individuals have the right to challenge certain types of processing, such as direct marketing.
- Ø Rights related to automated decision-making including profiling: individuals can ask organisations to provide a copy of its automated processing activities if they believe the data is being processed unlawfully. You should also remind individuals that they are free to exercise their rights and explain how they can do this.
9. HOW CAN YOU WITHDRAW YOUR CONSENT?
If you consent to us processing your personal data, please note that you may withdraw this consent at any time. In order to withdraw the consent, please contact privacy@nusr-et.com.tr .Please note that your consent can only be withdrawn for future processing activities and such a withdrawal does not have any influence on the lawfulness of past processing activities. In some cases, we may be entitled in spite of your withdrawal to continue to process your personal data on a different legal basis.
10. UPDATING THIS DATA PROTECTION NOTICE
We reserve the right to update this Data Protection Notice at any time. We will let you know about the changes by publishing the updated version of the Data Protection Notice on www.nusr-et.com.tr We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Data Protection Notice.
11. HOW TO GET IN TOUCH WITH US AND HOW CAN YOU EXERCISE YOUR LEGAL RIGHTS?
If you have any questions about our Data Protection Notice , or if you would like to make a complaint about a possible breach of personal data or to exercise one of your data protection rights, please contact us as described below.
Contact us;
Company E-mail address: privacy@nusr-et.com.tr
If you have any concerns about how we process your personal data, please feel free to contact our data protection officer, who will investigate the matter and make a comeback to you, by sending an email to privacy@nusr-et.com.tr
If you are still not satisfied after our response or believe we are not using your personal information in line with the law, you also have the right to complain to the data-protection regulator in the country where you live or work.