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PARO PROGRAM PROCESSING OF PERSONAL DATA CLARIFICATION TEXT

1. WHAT IS PARO PROGRAM AND WHO IS DATA RESPONSIBLE?

PARO is a loyalty program managed by Tani Pazarlama ve Iletisim Hizmetleri A.S. Tani is a Koç Group company that creates and manages marketing programs that provide consumers with various advantages and opportunities.

2. HOW CAN I BECOME A PARO PROGRAM MEMBER?

Paro Program membership starts with your membership or activation through channels such as SMS, WEB, Call Center, Mobile Application, etc. belonging to Tani or Program partners.  Activation is carried out by activating your loyalty cards or mobile phone number you receive from Program partner merchants with your name, surname, mobile phone number or loyalty card number and date of birth.  Some Program Partners may require different information to activate.  To activate,  you can transact at www.paro.com.tr.

3. WHO ARE THE PROGRAM PARTNERS?

Arçelik Pazarlama A.Ş. (Arçelik, Beko), Aygaz A.Ş. (Aygaz, Mogaz, Pürsu), Divan Turizm İşletmeleri A.Ş., Koç Finansman A.Ş., Koçtaş Yapı Marketleri Ticaret A.Ş., Opet Petrolcülük A.Ş., Öztaner Gıda ve İhtiyaç Maddeleri Ltd. Şti (Özhan Market), RMK Classic Giyim Tekstil Ticaret A.Ş. (Brooks Brothers, Edwards), Setur Servis Turistik A.Ş., Tat Gıda Sanayi A.Ş., Türk Traktör ve Ziraat Makineleri A.Ş., Yapı ve Kredi Bankası A.Ş., Yurtiçi Kargo Servisi A.Ş. Paro program partners can be updated.  You can follow current  program partners at www.paro.com.tr. Program Partners are also Paro member businesses.

4. WHAT ARE THE METHOD, LEGAL REASON AND PURPOSE OF PROCESSING OF MY PERSONAL DATA AS A MEMBER OF THE PARO PROGRAM?

The following types of personal data of Paro Program Members ("Personal Data") is obtained through store, station, call center, website, mobile application belonging to Tanı or Paro Program Partners to which members get in contact with, social media channels if become a member, dealers, agencies and franchises of Paro Program Partners, use of Chippin Platform if Paro Program Members are also Chippin Platform members.

Personal Data obtained by the above methods are processed for the following purposes and legal reasons:

PERSONAL DATA PROCESSING PURPOSE AND LEGAL REASON

Name, surname, mobile phone, date of birth, Paro card number, license plate, credit card number

Your specified personal data is obtained during the activation of your Paro Program membership, based on legal reasons regarding the performance of the contract and legitimate interest. Your name, surname, mobile phone and date of birth data are processed in order to enable you to benefit from the Paro Program membership and to finalize your requests and complaints.

It is mandatory to process this personal data in order to become a Paro Program Member. Your license plate will be processed if you activate it through our Opet Petrolcülük A.S. or Aygaz A.S. member businesses. Your credit card number will be processed if you give your express consent to participate in the Paro Program through our Yapı ve Kredi Bankası A.S member workplace.

Your e-mail, address, license plate, answers to surveys, Turkish ID No., gender, the stores you visit and your shopping details at Program Partner brands, vehicle model / year, marital status, name-surname, mobile phone number, date of birth, place of residence, education, job information, interests, device information that can be obtained via mobile devices (device identification number, operating system, browser name, device brand/model)

Due to the fact that you use Paro program, if you share your information with Tani or any Program Partners or if you subscribe via social media, update your information, campaign, give your information via Chippin Platform, your personal data are processed for carrying out singularization studies by keeping the data up-to-date, special analysis, promotion, marketing activities, direct mailing studies for you based on the open consent reason if you gave your consent to enter Paro Program.

If you become Paro Program Member, your personal data will be used for product and campaign developments, general analysis studies, reporting, statistical analysis, legitimate interests and performance of the contract legal reasons.

In addition, if you have given commercial electronic message permission, this personal data is processed for the purpose of presenting and promoting the products and services of the Program Partners in general and customized to you so that you can benefit from special advantages for passwords.

Your location and device usage information that you provide through mobile applications and IOT devices

If you use our mobile application, Program Partners' mobile applications and Program Partners' IOT-enabled devices, your location and device usage information is processed if you also give your consent.

Your location data is processed based on the legal reason for open consent, in case of your consent for the purpose of conducting analysis, promotion and marketing activities specific to you.

Unless you give your consent for the processing of your location data, your location data is not processed just because you are a Paro Member.

If you consent to the processing of your location data, you can withdraw your consent at any time via the relevant application/device.

Your browsing movements and behavior information on the websites and mobile applications of Tani and Program Partners (such as activities on the website/mobile application, products viewed, added to the basket, and from which page you entered the website)

If you give your explicit consent to cookies via websites and mobile applications, your behavioral movements in online environments are processed for the purpose of conducting analysis, promotion and marketing activities specific to you, based on the legal reason of open consent.

Unless you give your consent to the cookie permission, your online behavior information is not processed just because you are a Paro Member.

5. WITH WHOM AND FOR WHAT PURPOSES WILL MY PERSONAL DATA BE SHARED?

If you give your open consent to participate in the Paro Program, your personal data collected within the scope of the Program,

  • may be shared with our suppliers for us to give you program benefits,
  • Paro Program partners and Paro Program Partners' dealers, franchises and agents in order to ensure the up-to-dateness and integrity of your information, to receive program benefits and to carry out marketing activities.

We would like to point out that your shopping information you have made with one Program partner is not shared with another Program partner.

You can access the up-to-date list of Paro Program Partners' dealers, franchises and agents at "www.paro.com.tr".

6. WILL MY PERSONAL DATA RECEIVED BEFORE I APPROVED THE STATEMENT OF CONSENT BE PROCESSED UNDER THE PARO PROGRAM?

If you provide us with your identifying personal data such as mobile phone, license plate, in addition to your shopping information, in the purchases you have made from the Program partners before the date of your approval of the Declaration of Consent Regarding the Processing of Personal Data ("Declaration of Consent"), your information will be kept confidential, but as of the date you gave your consent to the Consent Statement, your previously provided personal data and shopping information will also be opened retrospectively and Your Personal Data will be processed by the relevant Program partner within the scope of the Programs and within the framework of this Clarification Text. The same will be true for your Paro cards, if you shop with your card before the Consent Statement, your card and shopping information will continue to be processed by the relevant Program partner by matching your Personal Data after you approve the Consent Statement.

7. HOW LONG WILL MY PERSONAL DATA BE PROCESSED?

Your Personal Data will continue to be processed within the scope of the Paro Program, during and after the program, unless otherwise requested by you or unless the reasons requiring processing are eliminated.

In case the Paro Program changes its name or turns into another program, necessary announcements will be made in this regard, and your personal data will continue to be processed within this scope to the extent that the data processing scope of the new program is compatible with this Clarification Text.

Even if you have a request to withdraw your open consent, the use of your Personal Data for purposes subject to open consent will be terminated, but will continue to be processed for the purposes specified in Articles 5/2 and 6/3 of the Personal Data Protection Law.

8. WHAT ARE MY RIGHTS REGARDING MY PERSONAL DATA AND HOW CAN I USE IT?

As a personal data owner, we declare that you have the following rights in accordance with Article 11 of the Law:

  • To find out whether your personal data are processed or not,
  • To request information if your personal data have been processed,
  • To find out about the purpose of processing your personal data and whether they have been processed for the intended purpose or not,
  • To find out about the third parties to whom your personal data have been transferred either domestically or abroad,
  • In the event that your personal data have been processed incompletely or incorrectly, to demand the correction thereof and to ask for the actions taken in this respect to be notified to the third parties to whom your personal data have been transferred, 
  • To demand the deletion or destruction of your personal data, even if they have been processed in compliance with the Law or the other provisions of the law, in the event that the purposes requiring the processing of such data no longer exist, and to ask for the actions taken in this respect to be notified to the third parties to who your personal data have been transferred, 
  • Objecting results against the person by analyzing the processes data via automatic systems individually,
  • To claim for any damages that you may incur as a consequence of the illegitimate processing of personal data.

You can send you applications aimed to your rights listed above to our Company by filling Data Owner Application Form which you can access at https://www.paro.com.tr/content/uploads/basvuru-formu.pdf. Depending on the nature of your request, your applications will be concluded free of charge as soon as possible and within thirty days at the latest; However, if the transaction requires an additional cost, you may be charged according to the tariff determined by the Personal Data Protection Board.

PARO PROGRAM CONDITIONS

1. A Paro Member ("Member") must approve the Paro Membership Consent Statement and register with a mobile phone number in order to benefit from the Paro Program and use the points earned. The member accepts and undertakes that he/she is responsible for not giving or using the card and number, user name and/or password given to him/her and keeping them, also to notify 4447276 Paro Consultancy Line in case of a change in mobile phone number, closure or transfer of the line, if it is determined that the card or mobile phone has been abused by the Member or someone else, or the Program has been abused, all kinds of rights and gains regarding membership will be taken back, other measures can be applied. If the necessary notification is not made, Tani or other Program Partners cannot be held responsible for the points defined for the mobile phone number due to the transfer of the line to someone else. The member accepts that Tani and Program Partners is not responsible for disputes originating from this matter, he/she will not give card number or mobile phone to another person, if he gives, all responsibility falls to him/her and he will lose all rights including the points he/she earned. If the membership card or mobile phone is lost or stolen, the member will notify call center. The Member is responsible for any damages that may arise until the notification is made. The conditions in this article will also apply to all vehicles other than the card used in the Programs.

2. Paro Program terms and benefits may differ and vary with each Program Partner. Tani may change the terms of the Paro Program, suspend the program, cancel the membership, and receive membership fees, except for the purposes such as the use of personal data, without prior notice. Points earned during the year may be reset on 31 January of the following year. The current conditions can be learned from the communication channels of the Paro Program. Tani and Program Partners shall not be held responsible in any way regarding disputes originating from faults of the goods that wasn't sold to the Member by them, delayed or wrong announcements, promotions, points etc., not being able to provide facilities such as points to the member due to the electronic infrastructure of the system. The conditions in this article will also apply to other programs to be commissioned.

3. Tani or the Member may terminate the membership at any time and without any reason, provided that they give notice 1 week before. In this case, the membership expires in 1 week. Members will be able to benefit from their rights until the expiration date of membership, in case of valid conditions. When the membership expires, the points accumulated on the card and the rights granted to the Member will be deleted and taken back by Tani.

The members accepts accuracy of the information explained with this form and in other ways, he/she will update them if there is any change, Tani and Program Partners' books and records will be counted as final evidence in case of disputes, natural persons living in Turkey over the age of 18 can become a member of the Paro Program, and legal entities can be included in the Program with the decision of Tani unless otherwise regulated and announced by Tani and Program Partners.