PRIVACY NOTICE ON THE PROTECTION OF PERSONAL DATA
CSM Binicilik Malzemeleri ve Hizmetleri A.Ş. (hereinafter referred to as “Cavalier SanMarco” or “Company”) prioritizes the protection of the fundamental rights and freedoms of its customers, including the right to privacy and the assurance of information security. This notice has been prepared to inform you about the processing of your personal data in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK”), published in the Official Gazette dated 07.04.2016 and numbered 29677. Cavalier SanMarco reserves the right to update this notice in line with any future legal regulations.
Under KVKK, your personal data shared within the scope of our Customer Communication and Satisfaction Program, website membership at https://cavaliersanmarco.it, or other micro-applications developed by Cavalier SanMarco—including your name, surname, mobile number, email address, city, address, purchase and payment information, and location data obtained through electronic programs—may be stored, recorded, updated, and processed in accordance with the law.
Additionally, processing is required for the fulfillment of obligations under the Consumer Protection Law No. 6502 and the Distance Contracts Regulation.
If you make purchases without registering on the site, your data will be processed in line with the applicable legal basis under the KVKK. If you are a member, your data will be processed with your explicit consent. If you are not a member, no data is processed on the basis of explicit consent.
Definition of Data Processing
According to the Law, “processing of personal data” refers to any operation performed on personal data, whether fully or partially automated or part of a data recording system, such as collection, recording, storage, retention, alteration, rearrangement, disclosure, transfer, acquisition, classification, or prevention of use.
Purposes of Processing Your Personal Data
Your personal data may be processed by Cavalier SanMarco for the following purposes in compliance with the fundamental principles of the Law and Articles 5 and 6:
1. Based on Explicit Consent
Data: Name, surname, mobile number, email, city, address, payment info, location
Purposes:
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Promote products and services; enhance customer relations and corporate image
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Offer personalized shopping experiences and communication (surveys, satisfaction practices, marketing analytics)
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Share personalized campaigns, promotions, and advertisements via digital or third-party platforms
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Notify users of updates and site changes
2. Necessary for Contract Formation or Execution
Data: Name, phone, address, order and payment details
Purposes:
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Process and fulfill orders and payments
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Handle and resolve inquiries/complaints
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Comply with contractual obligations in distance sales
3. Required for Legal Obligations
Data: Name, address, billing and payment info
Purposes:
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Ensure legal, technical, and commercial security of Company and stakeholders
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Comply with legal and regulatory requirements
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Share information with authorities when required by law
4. For the Establishment, Exercise, or Protection of Legal Rights
Data: Name, address, complaints, order and payment info
Purpose:
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Use as evidence in potential disputes
5. Based on Legitimate Interests
Data: Name, address, order and payment info
Purposes:
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Ensure smooth operation of business processes
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Plan and implement commercial strategies
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Support customer and supplier service workflows
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Improve user shopping experience
6. Explicitly Prescribed by Law
Data: Name, address, order and payment info
Purposes:
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Record and verify user identity for online transactions
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Generate required records in digital or physical formats
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Prevent fraudulent or unlawful transactions
Transfer of Personal Data
Your data may be transferred, in accordance with Articles 8 and 9 of the Law, to:
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Domestic/foreign business partners, suppliers, logistics providers, banks (for payment), Customer Communication Program partners
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Social media platforms (Google, YouTube, Facebook, Instagram, WhatsApp, Twitter, LinkedIn, Yandex, Pinterest, Snapchat, Twitch, TikTok, Oracle BlueKai, Bip, etc.)
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Service providers, subcontractors, mobile operators, and authorized legal or administrative institutions
Methods and Legal Grounds for Data Collection
Personal data may be collected:
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Through our websites and mobile apps
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Via contact with our teams, call centers, emails, SMS, or other communications
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During contract signing or customer service processes
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Through social media or third-party support systems
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Via cookies or technical files installed on your browser
Legal bases include:
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Explicit consent (Article 5/1)
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Necessity for performance of a contract
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Legal obligation of the data controller
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Legitimate interest
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Exercise or protection of a right
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Explicitly prescribed by law
Your browsing data may be collected, processed, securely stored, and shared with third parties only for the purposes stated in this notice.
Your Rights as a Data Subject
You may apply to CSM Binicilik Malzemeleri ve Hizmetleri A.Ş. to exercise the rights under Article 11 of the Law:
a. Learn whether your data has been processed
b. Request information on the processing
c. Learn the purpose of processing and whether it is used accordingly
ç. Know third parties your data is shared with (domestic or abroad)
d. Request correction of incomplete/incorrect data
e. Request deletion or destruction of data under Article 7
f. Request notification to third parties of any correction/deletion
g. Object to decisions based solely on automated processing
h. Request compensation for damages due to unlawful processing
How to Apply
You may complete the official Data Subject Application Form and submit it:
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By notary to:
Orta Mah. Topkapı Maltepe Cad. No: 20-22 İç Kapı No: 4, Bayrampaşa / İstanbul -
By email using your registered email address to: …………………………….
Requests will be answered within 30 (thirty) days, free of charge. However, if the process incurs a cost, fees may be charged as determined by the Personal Data Protection Board.