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Electronic Message Notification

TS CLUB Ticari Ürünler ve Turizm İşletmeciliği Tic. A.Ş. (`TS CLUB`)

Information Disclosure Text on Processing of Personal Data

As Trabzonspor Ticari Ürünler ve Turizm İşletmeciliği Tic. A.Ş. (`TS CLUB` or the `Company`); We attach great importance to the privacy and security of your personal data and handle these data carefully. Within this framework, it is one of our priorities to process and store all kinds of personal data of all persons associated with TS CLUB, including our customers benefiting from our products and services and our contacts with whom we have business relations, in accordance with the Law No. 6698 on Protection of Personal Data (`LPPD`).

As TS CLUB, acting in the capacity of `Data Controller` in accordance with LPPD and with the awareness of this responsibility, we would like to inform you as follows with respect to the purposes of processing of your personal data, the methods and reasons of collection of your data, the personal data processing activities, your rights regarding the processing of your personal data, and the procedures and principles of filing an application which is the method for exercising these rights.

1. Identity and Contact Details of the Data Controller

 This information disclosure text was issued by Trabzonspor Ticari Ürünler ve Turizm İşletmeciliği Tic. A.Ş., which is incorporated in Turkey and the details of which are given below, and which acts as the `Data Controller`, for the attention of the data subjects (relevant persons).

Title: Trabzonspor Ticari Ürünler ve Turizm İşletmeciliği Tic. A.Ş.

Address: 1 Beşirli Mahallesi Şenol Güneş Spor Kompleksi MedicalPark Stadyumu TS Club Ortahisar TRABZON

Mersis (Central Registration System) No : 0859043141800058

Phone: + 90 462 325 09 67

Fax : + 90 462 325 94 03

Registered E-mail Address: [email protected]

2. Which Personal Data Do We Collect?

As TS CLUB, we collect personal data of our customers, members and visitors (natural persons who visit/have visited any of our electronic platforms, including our company`s websites, mobile sites and social media accounts) who benefit from our products and services, our business partners, and our business contacts (shareholders, officials and employees of any entity with which we have any type of business relations, such as suppliers or subcontractors), in the cases where necessary and in accordance with LPPD.

As TS CLUB, we may collect the following personal data regarding the data subjects (relevant persons), and all kinds of information and documents containing such data, in cases where necessary, all of which shall be processed in accordance with LPPD:

-Identity data: Data related to the identity of a person such as name-surname, Republic of Turkey ID number, passport number and gender

-Contact data: Data that enable contact with a person, such as phone number, address and e-mail address

-Financial data: Data that can be collected according to the legal relationship we have established with the data subject, such as payment details, bank account details and credit card details

- Audio-Visual data: Personal data such as photos and voice recordings

- Data pertaining to customer transactions: Data regarding the transactions performed by a customer, such as customer expenditures details, shopping/basket information, customer preferences, instructions and requests

-Risk Management Information: Data processed for the management of commercial, technical and administrative risks

-Transaction Security Information: Data related to transaction security such as IP address and password transactions

-Marketing data: Data processed for marketing purposes, targeting information, and data collected by automated means by cookies and other means 

-Information pertaining to Legal Transactions: Personal data that can be processed in the case of files, lawsuits and correspondence with judicial authorities, and data such as personal information and professional experience that can be collected from business contacts, when necessary.

3. With Which Methods and on What Legal Grounds Do We Collect / Process Your Personal Data?

We collect your personal data,

§ Through our company`s Websites and mobile sites, and our social media accounts operated in various social media channels,

§ Through other communication methods that we use within the scope of sales, marketing and public relations activities, including e-mail, phone, short messages (`SMS`) or multimedia messages (`MMS`), or printed and electronic forms,

§ Through other communication methods that we use within the scope of communication and support activities, including e-mail, phone, short messages (`SMS`) or multimedia messages (`MMS`), or printed and electronic forms,

§ Through the records taken through our call center service;

§ Through other communication methods, including printed and electronic forms that you use in organizations/events held by TS CLUB,

§ Through the contracts that we have signed with you or the company you represent within the scope of the business activities we carry out; the commercial offers made, printed and electronic forms, documents, correspondences, and applications made to us,

§ Through the business cards and other documents given by you within the scope of the job interviews and events held by us,

§ Through third parties such as TS CLUB`s business contacts or companies from which it procures services/products,

and by various methods that are fully or partially automated, or non-automated but are part of a data recording system, and either verbally, in writing or electronically.

We process your personal data that we collect in accordance with the above methods, based on one or more of the legal reasons specified below:

§ Where you have granted your explicit consent,

§ Where the provisions of laws and regulations in force in the Republic of Turkey necessitate their processing,

§ Where their processing is obligatory for the protection of life or bodily integrity of you or someone else, when you are unable to express your consent due to an actual impediment,

§ Where data processing is necessary for the performance of the contract that we have concluded with you or your company,

§Where processing of your personal data is necessary to fulfill our legal obligations,

§ Where your personal data have been made public by yourself,

§ Where data processing is necessary for the exercise or protection of our legal or contractual rights as a company,

§ Where processing of your personal data is necessary for our legitimate interests, provided that it will not damage your fundamental rights and freedoms.

We keep all your personal data we process, in accordance with the periods required by LPPD and other legislation and as long as the above legitimate purposes do not cease to exist, and in any case, by taking all necessary administrative and technical measures.

4. For What Purposes Do We Process Your Personal Data?

We process your personal data that we collect, for the following purposes depending on their nature:

(1) Fulfilling the requirements of the contracts concluded by TS CLUB, supplying, producing, selling and delivering the products and services provided, developing products and services and making the necessary research and evaluations to make them available to you, and providing after-sales support services;

(2) Carrying out the commercial activities conducted by TS CLUB, and conducting the business processes accordingly;

(3) Monitoring and fulfilling the obligations arising from consumer legislation and replying to consumer applications;

(4) Carrying out advertising and marketing activities regarding the products and services provided, providing information on publicity, promotions, campaigns, offers, bulletins, sponsorship, events and similar issues, and carrying out corporate communication activities;

(5) Carrying out Marketing and Customer Relationship Management practices;

(6) Organizing corporate communication activities and other events, campaigns and invitations in this context, providing information about them, and carrying out market research practices;

(7) In order to improve the digital platforms that we make available to our customers and to provide the users of the platform with an efficient and personalized experience; obtaining statistics on the number and type of users, frequency of their visits, their behaviors, geographical locations and similar statistics; providing personalized content, campaigns and advertisements according to the interests and needs of the platform users, and using cookies for this purpose;

(8) Monitoring and evaluating the requests, suggestions and complaints received from data subjects, managing satisfaction of data subjects and implementing planning, statistics and satisfaction evaluation practices in this context;

(9) Managing the relations with business contacts, suppliers, subcontractors and companies with which we have similar business relations, and conducting business and commercial relations;

(10) Ensuring the legal and commercial security of persons having a business relationship with TS CLUB (such as planning of the administrative operations regarding the services provided by our company, evaluation processes for business partners/customers/suppliers (their officials or employees), and legal compliance process);

(11) Planning and executing occupational health and safety processes;

(12) Exercising legal rights and using information regarding the transaction history as evidence in the case of a dispute after the termination of a legal relationship;

(13) Determining and implementing commercial, legal and business strategies;

(14) Implementing the policies regarding financial affairs; e-invoice management;

(15) Planning, auditing and implementing information security processes and managing information technology infrastructure;

(16) Carrying out planning, reporting and statistical practices and similar examinations within the scope of activities of TS CLUB, and/or

(17) Ensuring compliance with the relevant domestic legislation, providing information requested by public institutions and organizations, and fulfilling any reporting obligations.

5. Do we transfer your Personal Data to third parties and/or to abroad?

We may transfer your personal data that we collect, to related companies/organizations* of TS CLUB, for the above-mentioned purposes and in accordance with the provisions of LPPD.

In addition, in the presence of the legal reasons stated above and in line with the specified purposes, we may transfer your personal data to TS CLUB`s domestic and/or overseas business partners, business contacts, suppliers, sponsors, consultancy firms from which we receive support in the areas of law and tax and in similar areas, domestic and/or overseas service providers from which we receive support in the areas of storage, archiving, payment systems and information technologies support (server, hosting, software, cloud computing, etc.), and also banks and financial institutions, our shareholders, and legally competent public institutions and private persons, provided that such transfer is in compliance with the provisions set forth under LPPD.

*TS CLUB and its related companies/organizations are listed below.


-Trabzonspor Club Association

oTrabzonspor Futbol İşletmeciliği Tic. A.Ş.

oTrabzonspor Sportif Yatırım ve Futbol İşletmeciliği Tic. A.Ş.

oTrabzonspor Ticari Ürünler ve Turizm İşletmeciliği Tic. A.Ş.

o1461 Trabzon Futbol İşletmeciliği Tic. A.Ş.

oTrabzonspor Telekomünikasyon Danışmanlık ve Servis Hizmetleri Tic. A.Ş.

oBordo Mavi Enerji Elektrik Üretim A.Ş.


As TS CLUB, we undertake that your personal data will be kept securely and will not be processed unlawfully.



6. The Rights of Data Subjects Listed Under LPPD and Application Procedures and Principles


i. Your Rights Related to Your Personal Data

We would like to specify that you have the following rights regarding your data processed within TS CLUB:

(1) To learn whether or not your personal data have been processed,

(2) If your personal data have been processed, to request information regarding them,

(3) To learn the purpose of processing of your personal data and whether or not your personal data are used in line with their intended purpose,

(4) To learn the third parties, if any, to whom your data have been transferred in Turkey or abroad, and which data have been transferred,

(5) To request the correction of personal data that may have been processed incompletely or inaccurately,

(6) In the case of correction, deletion or destruction of your personal data, to request that third parties to whom such personal data have been transferred be notified of such operations,

(7) To request the deletion or destruction of your personal data that have already been processed, in the case the reasons requiring them to be processed have ceased to exist or your personal data are no more up-to-date,

(8) To object to the occurrence of a result which is detrimental to you as a result of analysis of your processed personal data exclusively through automated systems,

(9) To request compensation of damages in the case that you incur damages as a result of unlawful processing of your personal data.


ii. Application

You may submit to our Company your requests regarding your rights listed above, by filling out the application form given below, in writing, or through registered e-mail address, secure e-signature, mobile signature, or your e-mail address that you have previously communicated to us and is recorded in our system. Please click here for the application form.

We, as TS CLUB, will conclude your requests on a free-of-charge basis as soon as possible depending on the nature of the request but within thirty days at the latest. Depending on the nature of your request and your application method, we may ask for additional confirmations (such as by sending a message to your registered phone, giving you a phone call etc.) in order to determine whether or not the application has in fact been made by you and thus to protect your rights. In the case that any cost arises due to fulfillment of your request, we may claim from you only those fees contained in the tariff determined by the Personal Data Protection Board.

We may accept the requests made to TS CLUB, or reject them by explaining the reason therefor, and we may submit this reply to the applicant either in writing or electronically. If the request is accepted, we, as TS CLUB, are obliged to fulfill the request immediately.


In the case that your requests submitted to TS CLUB are rejected by the Company, or you are not satisfied with the reply given by the Company, or no reply is received, you may file a complaint with the Personal Data Protection Board within 30 days following the date when the reply is communicated to you, and within 30 days from the end of the 30-day period in the case that no reply is received.


7. Electronic Commercial Messages

As Trabzonspor Ticari Ürünler ve Tur. İşl. Tic. A.Ş., we use some of your data that we collect in the data bank under the Law No. 6563 on Regulation of Electronic Commerce, for periodic campaign practices such as messages to be communicated at regular intervals in the form of SMS, e-mail or voice call, designing special promotional activities for customer profiles, and customer classification practices for ensuring that unwanted e-mails are not sent, as well as in accordance with the relevant legal regulations.   


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