1. Purpose
Jewellery Technology Research Inc. (“JTR” or the “Company”) aims to process personal data belonging to individuals in accordance with the Law on the Protection of Personal Data No. 6698 (“KVK Law”) and other applicable regulations.Personal data provided or to be provided to our Company, and/or obtained by our Company through other means, is processed by our Company as the "Data Controller."
2. Collection and Procedure of Personal Data from Individuals
Our Company processes your personal data in line with the purposes stated in this Disclosure Text. If there is any change in the purpose of processing, additional consent will be obtained from you.
Personal data collected and used by our Company include (but are not limited to):
- The myJTR web application uses your location data to display the exact location of your stores in the interface.
- The myJTR App accesses your camera, photos, and documents to allow you to upload your vehicle’s insurance, registration, and other documents.
- The myJTR App accesses your contact list to enable personalized communication. It does not delete your contacts or store your data.
Your personal data is collected before or during the contractual relationship through the information, documents, and materials you provide to our Company or obtained from third parties and public institutions for legally stipulated reasons, using both physical and electronic means.
3. Purposes and Legal Reasons for Processing Personal Data
Your personal data may be processed for the following purposes (including but not limited to):
- Registering prospective customers in the system,
- Marketing analysis, cookies, reporting, CRM, surveys, campaigns, advertisements, access via social media accounts, promotions, information, sales, after-sales, and marketing operations,
- Using a customer relationship management system,
- Creating invoices, collecting incoming calls, providing customer services,
- Updating and tracking customer information,
- Recording and tracking customer interactions and proposals,
- Executing and monitoring customer communications,
- Monitoring customer sales reports and orders,
- Handling customer requests, proposals, and complaints,
- Tracking customer visits,
- Obtaining communication permissions from customers,
- Sending informational messages,
- Collecting feedback on new vehicles,
- HR processes,
- Managing service appointment requests,
For the legitimate interests of our Company, without harming the fundamental rights and freedoms of the data subject:
- Creating customer records,
- Following up legal processes,
- Analyzing sales and service data.
Your personal data will be retained for a reasonable period as stipulated by applicable regulations or until the purpose of processing is eliminated, and in any case, within the statutory limitation periods.
4. Transfer of Personal Data to Third Parties
Procedures and principles regarding personal data transfers are regulated under Articles 8 and 9 of the KVK Law. Personal data and special categories of personal data may be transferred to third parties both domestically and internationally.
4.1. Transfer of Personal Data to Third Parties Within Turkey
Your personal data may be shared with the following individuals and organizations, limited to the fulfillment of the above-mentioned purposes:
- A Business partners and solution providers from whom we receive support for our activities,
- Authorized dealers and service providers,
- Financial institutions for payment, collection, and financing services,
- Authorized institutions and organizations such as regulatory and supervisory authorities, courts, and enforcement offices, within the scope of legal obligations.
4.2. Transfer of Personal Data to Third Parties Within Turkey
In accordance with the conditions set forth in Articles 8 and 9 of the KVK Law, and provided that the necessary security measures are taken, your personal data may be transferred abroad:
- If the recipient countries have adequate protection as determined by the Personal Data Protection Board, or
- In the absence of adequate protection, if the data controllers in Turkey and the relevant foreign country provide a written commitment for adequate protection and obtain the Board’s permission.
5. Ensuring the Security and Confidentiality of Personal Data
In accordance with Article 12 of the KVK Law, our Company takes all necessary technical and administrative measures to ensure an appropriate level of security in order to prevent the unlawful processing of personal data, prevent unlawful access to personal data, and safeguard the protection of personal data.
5.1. Technical Measures Taken to Ensure the Lawful Processing of Personal Data and to Prevent Unlawful Access
JTR has implemented all kinds of technical and technological security measures to protect your personal data and to safeguard it against potential risks.
5.2. Administrative Measures Taken to Ensure the Lawful Processing of Personal Data and to Prevent Unlawful Access
- Training and raising awareness of company employees regarding the KVK Law,
- Ensuring that, in cases of personal data transfer, contractual clauses are included in agreements with the receiving parties to guarantee data security,
- Identifying what needs to be done for KVK Law compliance and preparing internal policies for implementation.
5.3. Measures to Be Taken in Case of Unlawful Disclosure of Personal Data
In the event that personal data is obtained by others through unlawful means, our Company will notify the data subject and the Personal Data Protection Board as soon as possible.
6. Use of Location Data
The myReveal mobile application, developed by JTR, utilizes location services to establish wireless connections (Bluetooth/Wi-Fi) with devices and ensure proper pairing.Due to technical requirements of mobile operating systems, location services must be enabled for wireless connections to function properly. Therefore, if location services are disabled, the application will not operate as intended, and it will not be possible to connect to the device. Additionally, location data may be stored on JTR servers to enable device tracking in cases of loss or theft. This data is used solely for the purpose of device security, is never shared with third parties, and is not used for commercial purposes.
7. Deletion, Destruction, and Anonymization of Personal Data
Pursuant to Article 7 of the KVK Law, although personal data has been processed in compliance with the relevant legislation, if the reasons requiring its processing cease to exist, the personal data shall be deleted, destroyed, or anonymized ex officio or upon the request of the data subject by our Company.
The procedures and principles regarding this process shall be carried out in accordance with secondary legislation to be issued based on the KVK Law.
8. Rights of the Customer
Pursuant to Article 11 of the KVK Law, you may submit requests to our Company regarding your personal data on the following matters:
- To learn whether your personal data has been processed,
- To request information if your personal data has been processed,
- To learn the purpose of processing and whether your personal data is being used in accordance with that purpose,
- To know the third parties to whom your personal data has been transferred domestically or abroad,
- To request correction if your personal data has been processed incompletely or inaccurately and to request that this correction be communicated to third parties to whom the data was transferred,
- To request the deletion, destruction, or anonymization of personal data if the reasons requiring processing have been eliminated, and to request that this be communicated to third parties to whom the data was transferred,
- To object to any result that arises to your detriment as a result of analysis conducted exclusively through automated systems of the processed personal data,
- To demand compensation if you suffer damage due to unlawful processing of your personal data.
Requests arising from the KVK Law may be submitted to our Company by sending a written petition to the following address:
JTR MÜCEVHER TEKNOLOJİLERİ ARAŞTIRMA MERKEZİ A.Ş – Alemdar Mahallesi Nuruosmaniye Caddesi No: 12 34110 Cagaloglu - Fatih / Istanbul Türkiye In accordance with Article 13 of the KVK Law, if your application complies with the “Application Procedure” specified in Article 5(2) of the Communiqué on the Principles and Procedures for Application to the Data Controller, your application will be concluded free of charge within 30 (thirty) days depending on the nature of your request.
If your request is rejected, the reasons for the rejection will be communicated to you in writing or electronically. This Clarification Text may be updated by our Company when necessary.
