Customer Privacy Notice
This privacy notice has been prepared by Çakmakçı Kıymetli Madenler A.Ş. (hereinafter referred to as the “Company”) in accordance with Article 10 of the Turkish Personal Data Protection Law No. 6698 (“KVKK”), the Communiqué on the Principles and Procedures to be Followed in Fulfilling the Obligation to Inform, the relevant secondary legislation and the decisions and principle decisions of the Personal Data Protection Board in force, in order to provide information on the processing of the personal data of customers benefiting from our jewellery and precious metals trading services.
Your personal data is processed by our Company in its capacity as data controller, whose identity and contact details are set out below:
- Title: Çakmakçı Kıymetli Madenler A.Ş.
- Address: Mollafenari, Nuru Osmaniye Cd. No:58/A Fatih / İstanbul
- Phone: 0212 945 99 98
- Website: https://www.cakmakcikiymetlimadenler.com/
If you enter into a jewellery and precious metals trading relationship with our Company, the categories of personal data set out below are processed:
a) Identity Data
Name and surname, date of birth, place of birth, Turkish identity number (passport number or foreign identity number for foreign customers), civil registry information, signature.
b) Contact Data
Telephone number, e-mail address, address (place of residence) information.
c) Customer Transaction Data
Purchase and sale transaction details of precious metals trading, transaction amount and type of commodity, date and time of the transaction, customer account information, details of the executed agreements.
d) Legal Compliance Data
Corporate documents submitted on behalf of corporate customers (signature circulars, trade registry gazette, tax certificate, power of attorney, etc.), ultimate beneficial owner declarations and identity documents, and information relating to PEP (politically exposed person) screening under MASAK legislation.
e) Image Data
Image recordings obtained through the closed-circuit television recording system installed at our branch.
The personal data of our customers is processed for the following purposes:
- Conducting contractual processes relating to the purchase and sale of precious metals and to related financial services,
- Establishing customer identity and fulfilling know-your-customer obligations,
- Meeting the suspicious transaction reporting, identity verification and ongoing monitoring obligations under Law No. 5549 on the Prevention of Laundering Proceeds of Crime, the regulations of the Financial Crimes Investigation Board (MASAK) and the relevant secondary legislation,
- Fulfilling obligations arising from the regulations of the Central Bank of the Republic of Türkiye and from foreign exchange legislation,
- Performing document issuance and archiving obligations under the Tax Procedure Law, the Turkish Commercial Code and other financial legislation,
- Fulfilling the burden of proof in potential legal disputes and protecting the legitimate interests of the Company,
- Responding to the requests of competent public institutions, organisations and supervisory authorities,
- Verifying the powers of representation and corporate documents of corporate customers.
Customer personal data is processed under the KVKK on the following legal bases:
- KVKK Article 5/2-a: Expressly provided for by law — the customer identification, record-keeping and retention obligations arising from Law No. 5549, the regulations of the Central Bank, the Tax Procedure Law, the Turkish Commercial Code and the relevant MASAK regulations.
- KVKK Article 5/2-c: Directly related to the conclusion or performance of a contract — personal data processing activities that are necessary for the conclusion and performance of precious metals purchase and sale agreements.
- KVKK Article 5/2-ç: Necessary for the data controller to fulfil its legal obligations — foreign exchange legislation, tax legislation and MASAK notifications.
- KVKK Article 5/2-f: Legitimate interests of the data controller — protection against legal disputes and ensuring the security of the Company, provided that fundamental rights and freedoms are not harmed.
Customer personal data may be shared with the recipient groups set out below within the framework of the relevant legal basis:
- MASAK, the BRSA (BDDK), the Central Bank, the Ministry of Treasury and Finance, tax offices and other competent public institutions and organisations: within the framework of statutory reporting obligations,
- Judicial authorities and law enforcement agencies: pursuant to a court decision or a legal obligation,
- Independent auditors and financial advisors: within the scope of audit activities and only to the extent necessary,
- Group companies and business partners: provided that the conditions set out in Articles 8 and 9 of the KVKK are met and as specified in the updated versions of this privacy notice.
Customer personal data is retained for the following periods in accordance with the statutory retention periods:
- Under Law No. 5549 and MASAK regulations: at least 8 (eight) years from the date of the transaction,
- Financial records under the Tax Procedure Law: 5 (five) years,
- Commercial documents under the Turkish Commercial Code: 10 (ten) years,
- Contractual documents and residence records: 10 (ten) years from the termination of the contract (general statute of limitations under the Code of Obligations).
Upon expiry of the retention periods or where the purpose of processing ceases to exist, your personal data is deleted, destroyed or anonymised.
Within the scope of PEP (Politically Exposed Person) screening under Law No. 5549 or similar risk assessment processes, information that may be regarded as special categories of personal data within the meaning of Article 6 of the KVKK is processed only to the extent provided for by law and where mandatory; the security of such data is ensured by taking the adequate measures determined under Article 12 of the KVKK and by the Personal Data Protection Board.
Pursuant to Article 12 of the KVKK, our Company takes appropriate technical and administrative measures to prevent the unlawful processing of your personal data, to prevent unlawful access to your data and to ensure its preservation. In this context, customer information is made accessible only by authorised personnel and through authorised systems, and data processing activities are carried out within the framework of the Company's internal policies and its Personal Data Processing and Protection Policy.
Pursuant to Article 11 of the KVKK, our customers have the following rights:
- To learn whether their personal data is being processed,
- To request information if it has been processed,
- To learn the purpose of processing and whether the data is used in accordance with that purpose,
- To know the third parties to whom the data is transferred in Türkiye or abroad,
- To request the correction of data processed incompletely or inaccurately,
- To request the deletion or destruction of the data within the conditions set out in Article 7 of the KVKK,
- To request that the above operations be notified to the third parties to whom the data has been transferred,
- To object to a result arising to their detriment as a consequence of the analysis of the processed data exclusively by automated systems,
- To claim compensation for damages incurred as a result of unlawful processing.
It should be noted that, with regard to data relating to customer identification and transaction records that is mandatory under Law No. 5549, a request for deletion or destruction cannot be fulfilled before the statutory retention periods expire; this constitutes a legal exception within the scope of Article 7 of the KVKK.
You may submit your applications to exercise the rights set out above, together with documents proving your identity:
- By delivering them in person to the Company address,
- By sending a wet-signed petition by registered mail with return receipt,
- Through our registered electronic mail (KEP) address, or
- By sending them to [email protected] using a secure electronic signature or another method allowing identity verification.
Your applications will be answered within thirty (30) days at the latest, depending on the nature of the request.
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