Data Protection Policy
Thank you for your interest in our website. The protection of your privacy is very important to us. Therefore, we will process your data carefully, for a specific purpose and on the basis of your consent, and only in accordance with the legal requirements for data protection.
In this data protection policy we inform you about the aspects of data processing within our website.
The responsible body within the meaning of the data protection laws is:
Vitra Karo Sanayi ve Ticaret A.Ş. (hereinafter „Vitra Karo“)
Şifa Mah. Hükümet Cad.
No:5 Tuzla İstanbul-Turkey
Telefon +90 (212) 35080000
E-Mail: [email protected]
I. When and for what purpose does Vitra Karo collect personal data?
It is generally possible to use our websites without submitting personal data.
If you use one of our contact form, you enter your data voluntarily. We use this data (such as name, surname, address, e-mail address telephone, profession, country, city and message content) exclusively for the purpose for processing contact requests and only for the execution of our own business purposes.
When you access our website, information of a general nature is automatically recorded. This information (server log files) includes, for example, the type of web browser, the operating system used, the domain name of your internet service provider and such like. This is only information that does not allow conclusions to be drawn about you. This information is technically necessary in order to correctly deliver the contents of websites requested by you and is mandatory when using the internet. Anonymous information of this kind is statistically evaluated by us, in order to optimize our internet appearance and the technology behind it.
We do not sell your data, nor do we use it for unspecified purposes.
Your personal data will only be used by Vitra Karo to fulfil your wishes.
Below we inform you in detail about the handling of your data.
II. General information about our services
If you use our contact form, we will ask you for personal data (at the time of collection, we will explain which information is required and which you may voluntarily provide).
To protect the security of your data during transmission, we use state-of-the-art encryption techniques (such as SSL) over HTTPS.
For users who have signed up for one or more of the following services, it is possible to change or delete the information provided at registration at any time. Of course, we will also provide you with information about the personal data we hold about you at any time. We are happy to correct or delete this at your request, as long as no statutory retention requirements prevent this. To contact us in this context and to revoke your consent, please use the contact details provided at the end of this data protection policy.
III. Our services in detail
In the following, we would like to explain our services to you in detail, and in particular the legal basis for and purpose of the data processing.
Contact form
If you contact us via e-mail or our contact form, the information you provide will be stored for the purposes of processing the request as well as for any follow-up questions and sending you any requested information, if applicable.
Purpose of data processing:Responding to your request.
Legal basis:Article 6(1)(b) of the GDPR (required for implementing pre-contractual measures that are made at the request of the person in question)
Right to revoke your consent
Consent that you grant is always voluntary and may be revoked at any time with effect for the future, without giving reasons.
You can contact Vitra Karo at the address above to do this.
IV. Collecting data during your visit to our website
Along with the information that you submit yourself, we collect other data from you during your visit through cookies and tracking. We would like to clarify this in the following.
1. Cookies
Some of our websites use “cookies”. This standard technology refers to small text files that are stored on the device you use and allow your visit to a website to be made more convenient or more secure, among other things. Via the cookies, we automatically
receive certain data about your computer and your internet connection, such as your IP address, the browser used and operating system. Cookies may also be used to better tailor the offerings on a website to the visitor’s interests or generally improve the site based on statistical analysis.
You can decide yourself whether the browser you use permits cookies or not. Please note that website features may be restricted or even suspended if cookies are disabled.
Cookies cannot be used to start programs or transmit viruses to a computer. Using the information in the cookies, we can make navigation easier for you and allow our web pages to be displayed correctly.
Please see our cookie policy for more information about this.
2. Use of Google Analytics
This website uses Google Analytics, a web analysis service provided by Google Inc, (hereafter referred to as “Google”). Google Analytics uses “cookies”, or text files stored on your computer that permit analysis of your use of the website. The information generated by the cookie about your use of this website is generally transmitted to a Google server in the United States and stored there. If IP anonymisation is activated on these websites, however, your IP address will first be abbreviated within member states of the European Union or in other signatory states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the United States and abbreviated there. Google will use this information on behalf of the operator of this website to evaluate your use of the website, compile reports about website activity and provide other services to the website operator related to the use of the website and internet usage.
We also use the technical extension “Google Signals”, which enables cross-device tracking. This makes it possible to assign an individual website visitor to different end devices. However, this only happens if the visitor has logged in to a Google service when visiting a website and has activated the option “personalized advertising” in his Google account settings at the same time. Even then, however, no personal data or user profiles are accessible to us; they remain anonymous to us.
If you do not want “Google Signals” to be used, you can disable the “Personalized advertising” option in your Google Account preferences.
You can prevent the storage of cookies by configuring your browser software accordingly; however, please note that in this case you may not be able to use all the features of this website to their full extent. You can also prevent the collection of data generated by the cookie related to your use of the website (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plugin available through the following link: Browser add-on for disabling Google Analytics.
Alternatively to the browser add-on or for use within mobile browsers please click the following link to prohibit the collection of user data for this website on this browser: Set the Google Analytics opt-out cookie. The opt out functionality is enabled through a cookie that disables future data collection when you visit this website. As soon as you delete your cookies, you need to click the link again.
3. Use of Google Maps
This website uses Google Maps API to provide visual representations of geographical information. When using Google Maps, data about the visitor’s use of the map function will be collected, processed and used by Google. For more information about Google’s data processing, please refer to the Google privacy policy. You can also modify your personal data privacy settings in Google’s Safety Centre.
Detailed instructions about managing your own data in connection with Google products can be found here.
4. Google AdWords
Our website uses Google conversion tracking. If you reached our website through an ad placed on Google, Google Adwords will place a cookie on your computer. The cookie for conversion tracking is set when a user clicks an ad placed on Google. These cookies expire after 30 days and cannot be used for personal identification. If the user visits certain pages on our website and the cookie has not expired yet, we and Google can detect that the user clicked on the ad and was redirected to this page. Every Google AdWords customer receives a different cookie. Thus cookies cannot be used to trace AdWords customers through the websites. The information
obtained using the conversion cookie serves to generate conversion statistics for AdWords customers who have opted for conversion tracking. The customer receives the total number of users that clicked on their ad and were redirected to a site with a conversion tracking tag. However, they will not receive any information that could be used to personally identify users.
If you do not want to participate in tracking, you can decline the setting of cookies required for this – for example through the browser setting that generally disables the automatic setting of cookies or by adjusting your browser so that cookies from the domain “googleadservices.com” are blocked.
Please note that you may not delete opt-out cookies as long as you do not want any measurement data recorded. If you have deleted all the cookies in your browser, you will need to reset the respective opt-out cookie.
5. Use of Google Remarketing
This website uses the Remarketing feature provided by Google Inc. This feature serves to present website visitors within the Google advertising network with ads based on their interests. A “cookie” will be stored in the website user’s browser that makes it possible to recognise the visitor when they access websites that belong to Google’s advertising network. Visitors on this page can be shown ads related to content that the visitor previously accessed on websites that use Google’s remarketing function.
According to their own information, Google does not collect any personal data during this process. However, if you wish to opt out of Google’s Remarketing feature, you can always disable it by configuring the corresponding settings at http://www.google.com/settings/ads. Alternatively, you can disable the use of cookies for interest-based advertising via the Network Advertising Initiative by following the instructions at http://www.networkadvertising.org/managing/opt_out.asp.
Google is certified under the Privacy Shield Framework and as a result, offers a guarantee that complies with European data protection law.
(https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active)
6. Embedded YouTube videos
We embed YouTube videos on some of our websites. The operator of the corresponding plug-in is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit a page that includes the YouTube plug-in, a connection to the YouTube servers will be established. This will inform YouTube which pages you visit. If you are logged into your YouTube account, YouTube can match your surfing behaviour to you personally. You can prevent this by logging out of your YouTube account beforehand.
If a YouTube video starts playing, the provider will set cookies that collect information about user behaviour.
If you have disabled the storing of cookies for the Google Ad program, you also do not need to anticipate these cookies when viewing YouTube videos. However, YouTube also stores non-personal usage information in other cookies. If you would like to prevent this, you will need to block the storing of cookies in your browser.
You can find more information about data protection on “YouTube” in the provider’s data privacy policy: https://www.google.de/intl/de/policies/privacy/
7. Social plugins
We offer you the option of using “social media buttons” on our website. We rely on the “Shariff” solution to protect your data during use of these features. As a result, these buttons are only integrated onto the website as graphics that contain a link to the corresponding website of the button’s provider. Clicking this graphic will redirect you to the respective provider’s services. Your data will not be sent to the respective provider until then. As long as you do not click the graphic, there will be no exchange of any kind between you and the provider of the social media button. Information about the collection and use of your data in social networks can be found in the relevant provider’s respective terms and conditions of use.
We have integrated social media buttons for the following companies on our website:
Facebook Inc. (1601 S. California Ave – Palo Alto – CA 94304 – USA)
Twitter Inc. (795 Folsom St. – Suite 600 – San Francisco – CA 94107 – USA)
Pinterest (808 Brannan Street, San Francisco, CA 94103, USA)
Instagram (601 Willow Rd – Menlo Park CA 94025 – USA)
8. Facebook-Pixel
We have installed the Facebook Custom Audiences pixel on our website.
Facebook collects the personal data of website visitors and processes them in accordance with Facebook’s Data Policy. This includes any interaction on the website as well as information about the user’s device (hereinafter “visitor data”). Please refer to Facebook’s Information About Page Insights data for more information about visitor data processing.
Visitor data can be used to personalise content and tailor advertisements that reflect a visitor’s interest in specific posts on websites or their interaction with this content.
With regards to the aforementioned purposes, cookies, i.e. small pieces of text used to store the above-mentioned information anonymously (i.e. without specific data such as names or email addresses), are stored on the devices of visitors to our website. Users can read more about cookies and how they can opt out in Facebook’s Cookies Policy. (Link to Facebook’s Cookie Policy)
Facebook processes visitor data in the USA, whereby Facebook is certified under the EU-US Privacy Shield Agreementand therefore guarantees to comply with European data protection law.
Vitra Karois jointly responsible with Facebook for processing the personal data of visitors to our website collected using the Facebook Custom Audiences pixel in accordance with Article 4(7) of the GDPR and for this purpose has entered into a special agreement with Facebook in accordance with Article 26 (1, 2).
This agreement stipulates that Facebook is primarily responsible for data processing and that Vitra Karohas no access to visitors’ individual data (but rather can only retrieve aggregated statistics, e.g. regarding gender or age distribution). Furthermore, Facebook agrees to comply with data subject rights and e.g. to respond to requests regarding data information, objections and deletion.
Vitra Karoasks its website visitors to contact Facebook directly in view of exercising their data subject rights with regard to the processing of their data by Facebook. Vitra Karowould also only be able to forward e.g. information requests to Facebook.
Furthermore, Vitra Karoand Facebook have agreed that the Irish Data Protection Commission is the lead supervisory authority responsible for overseeing the personal data processed under their shared responsibility. Visitors to the Facebook site have the right to lodge a complaint with the Irish Data Protection Commission in addition to their local supervisory authority.
9.Vitra Karo Pages on social networks/ platforms
We use our pages on social networks and platforms for active communication with customers and users. When you visit these pages, your data may be collected and stored for market research and advertising purposes in order to create user profiles using pseudonyms. We use these in order to be able to display advertising to you within and outside the platforms, which is based on your presumed interests. For this purpose, cookies are used when visiting our pages, which store the usage behavior of the pseudonymous user.
You will find a complete description of the respective processing and the possibilities for objection in the details of the respective providers.
They can also best support you with information requests and the assertion of user rights. Should you require our help in this regard, please do not hesitate to contact us.
10. Purpose of processing, legal basis and legitimate interests
The following applies to the above items:
Purpose of data processing: Secure operation of the website as well as allowing targeted communication with customers.
Legal basis: Article 6 (1) (f) GDPR (legitimate interest)
Legitimate interests:
- Ensuring proper function of our website
- Optimisation of our website
- Collecting statistics related to use of our website
- Processing for the purposes of direct advertising
V. Recipients/categories of recipients
1. Other companies in the Vitra Karo
Personal data that you provide during registration (your name, e-mail address, telephone) will be shared with other companies in the Vitra Karo group in order to allow the respective company to provide customer service for you.
We can share the data from your profile with other companies in the Vitra Karo group if both companies are responsible for your personal data or if the other companies act as our service provider and your personal data is processed according to our instructions or on our behalf.
We share anonymised and aggregated information with other companies in the Vitra Karo group to use for trend analysis.
2. Other third parties
We will only share the data you provide for the purposes of contract fulfilment, such as with shipping companies or payment service providers, or in cases where we are legally obliged to do so. Examples of these recipients include
- Authorities and courts (legal duty of disclosure)
- Lawyers (assertion of claims)
- Credit institutes (processing payment transactions)
- Credit agencies (for checking credit history)
- Auditors and income tax auditors/accountants (legal audit assignment)
- Insurance companies, insurance agents
- Tax consultants
- Expert/appraiser
- Health insurance providers/pension funds (social insurance carriers)
3. Data transmission to third countries
If we process data in third countries (meaning countries outside the European Union (EU) or the European Economic Area (EEA)) or this occurs in the process of utilising the services of third parties or transmitting data to third parties, this will only be done for the purpose of fulfilling our contractual obligations, on the basis of your consent, due to a legal obligation or based on our legitimate interests.
In doing so, we ensure that your personal data is processed in compliance with the European level of data protection, based on special guarantees or due to corresponding contractual obligation including adequate technical and organisational measures.
VI. Information about children
We do not knowingly collect any personal data about children under 13 years old as a matter of principle. If we become aware that we have unintentionally collected personal data about children under 13 years old, we will take steps to delete this information as quickly as possible insofar as we are not obliged to retain it under the applicable law.
VII. Obligation to provide data, automatic decision making, profiling
1. Do I have an obligation to provide data?
In the context of the contractual relationship, you must provide the personal data that is necessary for acceptance, implementation and completion of the contractual relationship and for fulfilment of the duties related to the contract, or that we are obliged by law to collect. Without this data, we will generally not be able to conclude or implement the contract with you.
2. To what extent is there automated decision making/profiling:
Within the framework of the procedure for sending newsletters described under III. 2, we use profiling to the extent described there.
VIII. Deleting or locking data
We abide by the principles of data reduction and data economy.
We therefore only store your personal data as long as necessary to achieve the purposes described here or for the retention period stipulated by the legislator. Once the respective purpose has ceased to exist or this period has lapsed, the relevant data is routinely locked or deleted in accordance with legal regulations. If processing is based on consent, the respective purpose generally is considered to cease to exist when the consent becomes invalid due to revocation or passage of time. If processing is necessary for fulfilment of the contract, this will generally occur when the contract has been completed in full and after the retention period expires, as required in particular under the German Commercial Code (HGB) and the German Fiscal Code (Abgabenordnung).
IX. What data protection rights do you have?
You have the right to information under Article 15 of the GDPR, the right to correction under Article 16 of the GDPR, the right to erasure under Article 17 of the GDPR, the right to restriction of processing under Article 18 of the GDPR, the right to objection under Article 21 of the GDPR, and the right to data portability under Article 20 of the GDPR.
You can contact our data protection commissioner to exercise these rights.
You also have the right to file a complaint with a competent data protection supervisory authority (Article 77 of the GDPR in conjunction with Section 19 of the German Federal Data Protection Act, BDSG). A list of supervisory authorities (for the non-public sector) with addresses can be found here:
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html
X. Our data protection officer
If you have questions about this statement or about data protection at Vitra Karo, you can contact our data protection officer directly:
Contact details for our data protection officer:
Vitra Karo Sanayi ve Ticaret A.Ş.
Şifa Mah. Hükümet Cad.
No:5 Tuzla İstanbul-Turkey
Telefon +90 (212) 35080000
E-Mail: [email protected]
XI. Changes to our data protection provisions
We reserve the right to adjust this data privacy notice occasionally to ensure it always meets the current legal requirements or to reflect changes to our services in the data privacy notice, e.g. when introducing new services. In this case, the new data privacy notice will apply to your next visit to our website.