GDPR

Disclosure Text Regarding Processing of Personal Date

We, as Trabzonspor Club Association (“Trabzonspor”), attach great importance to the confidentiality and security of your personal data and treat it with sensitivity. Within this framework, it is our priority to process and store any personal data belonging to all persons affiliated with Trabzonspor, including our members, our customers who benefit from our products and services, and our business contacts, in accordance with the Law concerning Protection of Personal Data, numbered 6698 (“KVKK”).

We, as Trabzonspor, in the capacity of “Data Officer” in accordance with KVKK and with the awareness of this responsibility, would like to inform you as follows on the purposes of processing your personal data, the methods and reasons for collecting your data, personal data processing activities, your rights concerning processing of your personal data and the application rules of procedures, as means of exercise of these rights.

1. Data Officer Identification and Contact Information

This disclosure text has been prepared byTrabzonspor Club Association, incorporated in Turkey, whose information is provided below, in the capacity of “Data Officer” to address the relevant data owners

Title :Trabzonspor Club Association

Address : Trabzonspor Club Administration Building - Mehmet Ali Yılmaz Tesisleri Ahmet Suat Özyazıcı Cad. No 41 Ortahisar/Trabzon

Central Reg. No : 0859004636100001

Telephone : 0462-325 09 67 (pbx)

Fax : 0462-325 55 15- 0462-325 61 35

KEP address : trabzonsporkulubudernegi@hs03.kep.tr

This disclosure text covers personal data processing related to Trabzonspor and affiliated companies /establishments*, including companies / establishments and subsidiaries operating under the structure of Trabzonspor Club Association.

1. What Personal Data Do We Collect?

We, as Trabzonspor, collect personal data belonging to association members, visitors (real persons who have visited / visited all our platforms and / or physical locations / facilities in electronic environment including websites, mobile sites, social media accounts of our Association and related companies operating under the structure of the association), our customers, business partners, business contacts who benefit from our products and services (to the shareholders, officials and employees of the institutions with whom we have business relations such as suppliers, contractors, subcontractors) and other third parties (volunteers, ceremony children, etc.) in accordance with KVKK, when deemed necessary.

We, Trabzonspor, may collect the following personal data relating to the relevant data holders for processing in accordance with KVKK and any information and documents containing the same, when required:

• Identification data: Data concerning the identity of the person such as same and surname, ID number, passport number, nationality information, date of birth;

• Contact data:Data that enables contact with the person such as phone number, address, e-mail address;

• Financial data: Data, which may be collected depending on the legal relationship, established with the relevant person such as payment information, bank account information, credit card information;

• Audio-visual data: Personal data such as photographs and audio recordings;

• Personnel Data:Personnel data that can be collected from real persons affiliated with our Association;

• Professional Experience Data: Data on professional knowledge of real persons;

• Physical Space Security Data: Personal data, such as security and camera recordings, obtained on entry to physical space and during the stay in the space;

• Personal Data with Special Qualifications: Data on disability, personal health data, association membership, criminal conviction and security measures;

• Risk Management Information: Data, which may be processed to manage commercial, technical and administrative risks;

• Transaction Security Information: Data regarding transaction security data such as IP address, password, and password operations;

• Legal Action Information: Personal data and customer transaction data that can be processed in files, lawsuits and correspondences with judicial authorities, marketing data, data collected by automated means through, cookies and other means.

1. What methods and legal reasons do we collect / process your personal data?

We collect by a variety of methods that are fully or partially automated or non-automated as part of any data recording system provided that it is verbal, written or electronic as follows

• Through the application forms that you have submitted to us for membership of the Association, all information, documents, correspondence and forms, presented to contain personal data,
• Through internet and mobile sites belonging to our Association and companies operating under the structure of our Association and our social media accounts, being operated in various social media channels,
• Through other communication methods including e-mail, telephone, short messages (“SMS”) or multimedia messages (“MMS”), printed and electronic forms that we use within the scope of sales, marketing and public relations activities,
• Through other communication methods including e-mail, telephone, short messages (“SMS”) or multimedia messages (“MMS”), printed and electronic forms that we use within the scope of communication and support activities,
• Through the records obtained through the call center service of our Association and companies operating under the structure of Association;
• by means of closed-circuit security cameras in our facilities;
• through other communication methods, including printed and electronic forms that you use in sports and social organizations / events and sports activities realized by Trabzonspor,
• through the Contracts we have signed with you or the company you represent, commercial offers, printed and electronic forms, documents, correspondences and applications filed before us within the scope of the business activities we carry out
• by means of business cards and other documents provided by you within the scope of our business meetings and events,
• through affiliated companies / establishments* of Trabzonspor, third persons, such as business contacts or companies providing services / products.

We process your personal data relying on one or more of the following legal grounds according to the abovementioned methods:

• Presence of your express consent,
• Processing requirement under the provisions of currently effective laws and regulations in Turkey;
• Necessity for protection of your or any other person’s life or bodily integrity, while you were unable to express consent due to actual disability,
• Requirement for the performance of the contract concluded with you or your company,
• Necessity to process your personal data for performance of our legal obligations,
• Publication of your personal data by you,
• Necessity for exercise or protection of our legal and contractual obligations,
• Requirement of processing your personal data for our legitimate interests, provided that your fundamental rights and freedoms are not impaired.

We store all processed personal data for the periods stipulated in KVKK and other legislation and in any case until the elimination of the legitimate purposes, specified above, by taking all necessary administrative and technical measures.

1. For what purposes do we process your Personal Data?

We process the collected personal data for the following purposes, according to its nature:

1. Planning and executing our membership activities at Trabzonspor in accordance with the Associations Law and related legislation for the purposes defined by the association charter;
2. Conduction of necessary planning, organization, studies and announcements regarding the activities and events, held by our Association;
3. Conduction of necessary planning, evaluation and studies by our business units to present you our products and services, offered by Trabzonspor and / or affiliated companies / establishments of Trabzonspor;
4. Conduction of commercial activities carried out by the affiliated companies / establishments of Trabzonspor and conduction business processes accordingly;
5. Conduction of advertising and marketing activities for offered products and services, and provision of information concerning promotion, campaigns, offers, bulletins, sponsorship, event and similar issues, conduction of corporate communication activities;
6. Conduction of marketing and customer relationship management activities;
7. Conduction of corporate communications and within this framework, organization of events, campaigns and receptions, and publication concerning these, conduction of market research studies;
8. Extraction of statistics, such as number, type of users, visit frequency, behavior, geographical locations and similar statistics for improvement of digital platforms, offered for use by our customers, provision of personalized content, campaigns and advertisements according to areas of interest and needs of platform users and the use of cookies for this purpose;
9. Follow-up and evaluation of requests, suggestions and complaints from related persons, contact satisfaction management and conduction of planning, statistics and satisfaction evaluation studies in this regard;
10. Making arrangements for domestic and international travel, transportation, visa and accommodation for sports activities / events;
11. Management of relationships with business contacts, suppliers, subcontractors and firms with similar business relationship, and the conduction of works and commercial relationships;
12. Provision of legal and commercial security of Trabzonspor and affiliated companies/establishments of Trabzonspor and the persons, engaged in a business relationship with Trabzonspor;
13. Planning and execution of occupational health and safety processes;
14. Provision of legal, technical and commercial occupational safety of the affiliated persons in our facilities and to ensure the security of the building;
15. Exercise of legal rights, use of information about the transaction history after the termination of the legal relationship, as evidence in case of dispute;
16. Identifying and implementing commercial, legal and business strategies;
17. Implementation of financial policies; e-invoice management;
18. Planning, auditing and execution of information security processes, management of information technology infrastructure;
19. Conduction of planning, reporting, statistical studies and similar studies within the scope of activities of Trabzonspor and related companies / establishments of Trabzonspor and / or
20. Compliance with domestic legislation, provision of information requested by public institutions and organizations, fulfillment of reporting obligations.

1. Do we transfer your Personal Data to the 3rd parties and / or to a foreign country?

We transfer collected personal data to Trabzonspor's affiliated companies / establishments,* including future companies/establishments and/or subsidiaries, yet to be incorporated under the structure of Trabzonspor in accordance with the provisions of KVKK for the purposes, given above.

In addition, we may transfer your personal data, in case of presence of the legal reasons, given above and in line with the stated purposes, to domestic and/or foreign business partners business contacts, suppliers, sponsors of Trabzonspor and affiliated companies/establishments of Trabzonspor, consulting firms, rendering services in the field of law, tax etc., domestic and/or foreign service providers in the fields storage, archiving, payment systems, information technology support (server, hosting, software, cloud computing, etc.), banks and financial institutions, our shareholders, legally competent public institutions and private persons, institutions/establishments, authorized in Turkey and/or abroad for foreign football events and their contracted business partners; provided that the provisions, regulated in KVKK, will be observed.

* Trabzonspor and its affiliated companies are listed below.

• Trabzonspor Club Association
  • Trabzonspor Futbol İşletmeciliği Tic. A.Ş.
  • Trabzonspor Sportif Yatırım ve Futbol İşletmeciliği Tic. A.Ş.
  • Trabzonspor Ticari Ürünler ve Turizm İşletmeciliği Tic. A.Ş.
  • 1461 Trabzon Futbol İşletmeciliği Tic. A.Ş.
  • Trabzonspor Telekomünikasyon Danışmanlık ve Servis Hizmetleri Tic. A.Ş.
  • Bordo Mavi Enerji Elektrik Üretim A.Ş.

As Trabzonspor, we hereby undertake that your personal data will be stored securely and will not be processed unlawfully.

1. Rights of Data Owners within the Scope of KVKK and Application Rules and Procedures

1. Your Rights Regarding Your Personal Data

We would like to state that you have the following rights concerning your data that is being processed within the structure of Trabzonspor:

1. To learn whether your personal data is processed ,
2. If your personal data is being processed, to obtain information about the same,
3. To learn the purpose of processing of your personal data and whether your personal data is used in line with its purpose ,
4. If any, to learn about the third persons, to whom the data is transferred within Turkey or abroad and to learn which data was transferred,
5. To request correction of processed personal data if the same is incomplete or incorrect,
6. In case of correction, deletion or destruction of your personal data, to request notification of these procedures to third persons, to whom your personal data is transferred,
7. To request the deletion or destruction of your processed personal data, in case the reasons, requiring processing of your personal data cease to exist or in case your personal data become outdated,
8. To contest a conclusion, which is unfavorable for you, arising as a result of analysis of your personal data exclusively via automatic systems,
9. To request remedial of damages in case you suffer any damages due to unlawful processing of your personal data.

1. Application

You may forward your claims regarding your rights to our Company in writing by completing the application form or through your registered e-mail address, secure electronic signature, mobile signature or e-mail address that you have previously informed us about and registered in our system.Please click here for the application form.

As Trabzonspor, we will resolve your requests free of charge and as soon as possible depending the nature of the request and no later than thirty days. We may request additional verifications (sending messages to your registered phone, calling, etc.) in order to determine whether the application belongs to you depending on the nature of your request and the method of application and therefore to protect your rights. In case a cost arises due to fulfillment of your requests, we may only claim the fees, given in the tariff, determined by Personal Data Protection Board.

We may accept requests, made to Trabzonspor or dismiss the same by providing reasoning, and we may deliver such response to the requesting person in writing or in electronic medium. If the request is accepted, we, as Trabzonspor, are obliged to fulfill the request promptly.

1. Complaint

If your requests directed to Trabzonspor are dismissed, if you are not satisfied with the response given by Trabzonspor or if no response is provided, you may file a complaint before Personal Data Protection Board within 30 days after the service of the response or within 30 days after the expiry of 30-day period in case no response is given.