1. BASIS REFERENCE

The obligations of data controllers are defined in the relevant provisions regarding the processing or protection of personal data as laid out in the Personal Data Protection Law No. 6698 (KVKK), Law No. 6502 on the Protection of Consumers, Law No. 6563 on the Regulation of Electronic Commerce, Regulation on Service Providers and Intermediary Service Providers in Electronic Commerce, and the Processing or Protection of personal data in the Regulation on Commercial Communication and Commercial Electronic Messages Data.

Serving its customers at RAZORUS.com, we, as SFRS Bilisim Sanayi ve Ticaret Ltd. Sti. (hereinafter referred to as the "Company") care deeply about protecting the personal data of our visitors, customers and members and have resolved to meticulously fulfill our legal obligations in this regard. To this aim, we attach great importance to the collection, processing and protection of all personal data belonging to visitors, customers and members who benefit from our products and services in accordance with the Law on the Protection of Personal Data No. 6698 (KVKK) 

Our Company, in its role as the data controller, is obliged to supply you with all necessary information regarding our obligations and your rights, in accordance with the provisions of the Law on the Protection of Personal Data (KVKK) and the Communiqué on the Procedures and Principles to be Complied with in Fulfilling the Obligation to Inform,  and as such provides information below concerning the identity of the data controller and of, if any, its representative, the purpose of the processing of personal data,  to whom and for which purposes the processed personal data may be transferred, the method and legal basis of collection of personal data, as well as other rights referred to in Article 11 of the Law on the Protection of Personal Data (KVKK).

2. DEFINITIONS

Within the scope of this clarification notice, the following definitions of terms apply:

Explicit consent: Consent on a specific subject, based on information and expressed with free will.

Anonymization: Making it impossible to associate data to an identified or identifiable natural individual in any way, even in the case of matching with other data.

E-commerce: The exchange of products, goods or services, etc., carried out online in an electronic environment without physical contact, for example, any commercial activity.

Personal data: Any type of information pertaining to an identified or identifiable natural individual.

Processing of personal data: preventing the use thereof of the obtaining, recording, storing, protecting, altering, adapting, disclosing, transferring, retrieving, making available for collection or categorization of any personal data, both wholly or partially, either by automatic or non-automatic means which is a part of any data recording system.

Destruction of personal data: Rendering personal data inaccessible, unrecoverable and unusable by anyone under any means.

Data registration system: The registration system in which personal data is processed and structured according to specific criteria.

Consent of data owner: The data owner's free and willing consent to the processing of personal data belonging to him/her, through a declaration or by giving explicit consent.

Data controller: referring to the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

3. DOCUMENTATION OF DATA CONTROLLER

Presented here is the Corporate Identity information for SFRS Bilisim Sanayi ve Ticaret Ltd. Sti. in compliance with the Personal Data Protection Authority (KVKK) directive for ‘Data Controllers’:

Trade register number:              43010

Central Registration Number:     0769070896200015

Tax Administration Office:          Eskişehir V.D.B.

Tax number:                             7690708962

Headquarters:                          Sümer Mh. Evliyagil Sk. No:44/A Odunpazari, Eskisehir

Phone:                                    +90(850) 885 25 15

Web site:                                 www.razorus.com

E-mail Address:                       info@razorus.com

4. METHODS AND OBJECTIVES OF COLLECTING AND PROCESSING PERSONAL DATA

To fulfill our obligations to our customers arising from any future contracts that may be made and to ensure that we are able to provide the very best service possible, we need to collect and process your personal data. 

Your personal data is collected electronically or manually through automatic or non-automatic methods within the scope of our e-commerce activities, in the form of any completed applications submitted in written form or within the electronic domain, membership and communication forms, contracts, customer request and transaction documents, e-bulletin memberships, memberships and shares made on our website or in our social media accounts, phone calls, e-mails and SMS. 

Within this context, your identity information (name, surname, TR identity number, gender, date of birth), contact information (invoice and delivery address, e-mail, telephone number), customer transaction data that you share while subscribing to our Site or ordering from our web-shop (orders placed on our Site, favorite products, messages containing your requests and instructions, information such as your transaction dates, IP number) are collected and processed.

Such data transmitted to our Company by you accurately and completely may be processed to establish contracts for the sale of a product; to execute and fulfill legal obligations; to enable customers to benefit from membership opportunities; to perform product sales and after-sales support processes; to perform activities/actions pertaining to customer satisfaction; to perform financial and accounting duties; to execute company and product loyalty processes as well as financial and legal obligations; and for the purpose of fulfilling requests and complaints, while informing the authorized persons, institutions and organizations. For example, it can be used to issue a valid invoice for a product purchased, to receive payment, to make deliveries and, if necessary, to carry out return transactions and to manage any other requests and complaints. In addition, when subscribed to our E-Newsletter and with permission given to send e-mails, members can be informed about any promotions or special invitations being offered via commercial electronic messages and be invited to participate in surveys. Customers and visitors to our Site reserve the right to choose whether to receive this communication upon becoming a member or chose to later change this preference setting in his/her account information. Upon request, members can leave this communication channel at any time, at which time all personal data registered in our system will also be erased.

Pursuant to Article 5 of the Law on Personal Data Protection (KVKK), personal data may be processed without express consent in the event that processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract, or necessary for compliance with a legal obligation to which the data controller is subject, provided that said processing shall not violate the fundamental rights and freedoms of the data subject. On the other hand, pursuant with Article 6 of the Law on Personal Data Protection (KVKK), as our Company does not request special categories of personal data (data of a personal nature), individuals are not obliged to share such data with us. Should such data be shared, it may only be processed after explicit consent has been provided.

5. TRANSFER OF PERSONAL DATA

The personal data you provide is used by our company to research your preferences and allow us to tailor the products and services we offer to better match your needs, tastes and usage habits while enabling us to take all necessary measures to store and protect your data in accordance with the highest security standards. In accordance with the conditions specified in Article 8 of the Law on Personal Data Protection (KVKK), it is mandatory under the terms of the legislation for the controller to fulfill legal obligations to transfer data pertaining to legal processes, financial affairs and data obtained for similar purposes to such relevant persons and institutions of the administrative and official authorities, as well as to the institutions or organizations authorized to request your personal data such as regulatory and supervisory institutions, courts and enforcement offices, tax consultants and lawyers, domestic third party providers from whom services are received or are to be received, our shareholders, and such business partners which help deliver our products and services to you (such as companies that receive web infrastructure services, cargo companies). Additionally, in accordance with Article 9 of the Law on Personal Data Protection (KVKK), said data can be transferred to overseas business partners, provided that your explicit consent has been obtained.


6. RIGHTS OF THE DATA SUBJECT WITHIN THE SCOPE OF ARTICLE 11 OF THE LAW ON PERSONAL DATA PROTECTION (KVKK)

Pursuant to Article 11 of the Law on Personal Data Protection (KVKK), the data subject, has the right to request by applying to our Company through one of the methods described below, to learn whether or not personal data is processed about him/her; to demand for information as to whether his/her personal data has been processed; to learn the purpose of the processing of his/her personal data and whether this personal data is used in compliance with the purpose; to know the third parties to whom his/her personal data are transferred to domestically or abroad; to request the rectification of incomplete or inaccurate data, if any; to request the erasure or destruction of his/her personal data under the conditions referred to in Article 7 of the Law on Personal Data Protection (KVKK); to request reporting of operations carried out by third parties to whom the personal data has been transferred, regarding requests for rectification of personal data and the erasure or destruction of his/her personal data in the case of incomplete or inaccurate reporting during personal data processing; to object to the occurrence of a result against the person himself/herself by analysing the data processed solely through automated systems; and to claim compensation for damage arising from the unlawful processing of his/her personal data.

Pursuant with Article 13 of the Law on Personal Data Protection (KVKK), the data subject reserves the right to request the implementation of this Law to the Company in writing or by other means detailed below and the Company shall conclude demands in the request within the shortest time by considering the nature of the demand and at the latest within thirty days and free of charge. However, should the action require an extra cost, fees may be charged in accordance with the tariff determined by the Personal Data Protection Board.  

In order to exercise the rights regulated in Article 11 of the Law on Personal Data Protection (KVKK), a request should be made by filling out, signing, and sending the form to the Company’s registered headquarters at Sümer Mh. Evliyagil Sk. No:44/A Odunpazarı Eskişehir. Documents confirming your identity should be personally delivered to our headquarters; sent through a public notary; sent to our registered electronic mail (KEP) address sfrsbilisim@hs01.kep.tr with a secure electronic signature or sent to the Data Controller by any of the other methods specified in the Communiqué on Application Procedures and Principles published by the Personal Data Protection Board.

7. ERASURE, DESTRUCTION AND ANONYMIZATION OF PERSONAL DATA

Pursuant to Article 7 of the Law on Personal Data Protection (KVKK), personal data is to be erased, destroyed or anonymized by our Company, ex officio or upon the request of the data owner, in the event that all of the reasons requiring its processing are redundant, regardless of its having been processed in accordance with the provisions of the law.