Swanleuco Protection of Personal Data | Privacy Statement | GDPR
1. Definitions
In the Clarification Text and the Approval Form of Processing and Protection of Personal Data;
Service: means the services provided to the Member on the Site.
Personal Data: any information related to an identified or can-be-identified real person,
The Law on the Protection of Personal Data (“LPPD”): the Law on the Protection of Personal Data numbered 6698, which entered into force by being published in the Official Gazette on April 7, 2016,
SITE: the website with the https://www.swanleuco.com/ URL address,
Member: all real or legal persons who are internet users and members of the SITE,
Data Operator: any real or legal person that processes Personal Data based on the authority granted by the Data Officer on his/her behalf,
Data Responsible: refers to Swanleuco.
Text: refers to the Clarification Text and Approval Form of processing and protection of personal data.
2. Data Responsible
Your personal data that you share in accordance with LPPD as a partner, member, supplier, visitor, grantee, or supported person; shall be assessed by the SITE determined as data responsible within the scope specified below.
3. Method of Collecting Personal Data and Its Legal Grounds
Your personal data is collected by the SITE in two different ways;
Data You Have Directly Given to Us: indicates the personal data that the users give for the fulfillment of the Service before and during the use of the SITE on their own initiatives such as membership application form, SITE Contact Forms, SITE E-Bulletin Registration Forms, Grant Scheme Application Forms, Job Application Forms, and so on. These personal data include all personal data provided directly by the Users to the SITE. For instance, name-surname, contact information, identity information, answers to the questionnaires, demographic data, and content information fall into this category.
Data We Obtain When You Use the SITE: include the personal data regarding the usage habits of the Users through specific software or technological means during the service provided by the SITE. For example, location data and favorites, as well as interests and usage data, are included in this type of data.
The data obtained in this way may be collected, processed and transmitted for the purposes stated in the given Text within the scope of the personal data processing conditions and purposes designated in Articles 5 and 6 of the LPPD in accordance with the basic principles foreseen by the LPPD for the services provided by the SITE to be offered in the prescribed legal framework
4. Process Your Processed Personal Data and Personal Data Processing Purpose
4.1 Your Processed Personal Data:
The personal data provided by you during the membership procedure to the SITE and/or within the scope of the fulfillment of the Service that can be subject to processing as a sort of example are as follows:
Identity Data      
Name, surname, date of birth, country of birth, city of birth, gender, marital status, nationality, Turkish identity card information (Republic of Turkey Identity Number, serial number, certificate number, father name, mother name, birthplace, province, district, neighbourhood, volume no, family serial number, serial number, section no., page no., registration no., place of issue, reason of issue, issue date, previous surname, copy of the birth certificate
Contact Data      
Phone number, open address information, e-mail address (extension number, corporate e-mail address), social media account information
Special Quality Personal Data          Syndicate, criminal record, disability status/definition/percentage, religion, health data, blood type, health reports, association/foundation membership
Training Data       Education status, certificate and diploma information, foreign language information, education and skills, CV, courses taken
Audiovisual Data                
Real person photo, voice record, camera record belonging to a real person
Performance and Career Development Data             
Education and skills, seniority, experience, which courses taken in which date, where and in what fields s/he has worked, signed a participation form
Family and Relative Data  Marriage certificate; names, surnames, Turkish Identity Numbers, genders, dates of birth, height, weight, duties, phone numbers of spouse and children; names, surnames and phone numbers of his/her relatives
Military service postponement, copy of driver license, vehicle license plate, traffic ticket query result, relative of a martyr status, trainee status, information that the member approves to be shared through the social media channels in case of connecting with the social media accounts, navigation and clicking information on the SITE, location information of where the application is used, internet access logs, input and output logs, cookie usage information
4.2 Purposes of Processing Personal Data:
4.2.1 Pursuant to Articles 4, 5 and 6 of the LPPD, in order for the SITE to provide better service to you, in accordance with the legal obligation arising from the related legislation, primarily the Law No. 5651 on Regulating Broadcasting in the Internet and Fighting Against Crimes Committed through Internet Broadcasting and the related secondary legislation, the Law No. 6563 on the Regulation of Electronic Commerce and the related secondary legislation, the Law No. 5237 Turkish Criminal Code and the Law No. 6698 on the Protection of Personal Data, your personal data will be processed and stored
  1. As suitable for the rules of law and honesty
  2. As accurate and up-to-date, if necessary
  3. For specific, clear and legitimate purposes
  4. As connected, limited and measured to the processed purposes
  5. In accordance with the rules of protection for the period of time required for the processed or prescribed purpose in the relevant legislation,
in a way connected to the SITE activities given below, with a view to enabling you to make the best of the membership advantages of the SITE, with your explicit consent, and on condition that your personal data shall not be used outside the scope and purposes identified by the given Text and shall be secured through information security measures.
4.2.2 As explained in detail in Article 7; the SITE has the ability to associate behaviors of the users, no matter whether they are member or not, through a cookie on the browser and define remarketing lists that select metrics such as the number of pages viewed, the duration of visits, and the number of target achievement, as the baseline for online behavioral advertising and marketing. Targeted ad content can then be shown to these users on the SITE or other sites on the Image Advertising Network according to the interests of the user. While Google AFS ads are directed to the SITE, Google may place cookies on users’ browsers, read cookies contained therein or use web beacons to collect information.
5. Transfer and/or Sharing of Personal Data
6. Duration for Record Storage
Pursuant to the Law on the Regulation of Electronic Commerce numbered 6563 and the secondary legislation; the approval, withdrawal of approval, the content of the commercial electronic message, and other records relating to the message shall be recorded to be submitted to the Ministry, if necessary; the records of approval and other records of commercial electronic communications shall be kept for three years respectively from the date of the expiration of the validity of the approval and the date of registration. If provided for in applicable laws and regulations, personal data shall be kept for the period specified in these legislations.
7. Cookie Usage
Cookies are text files that are loaded by your internet browser and contain small pieces of information that are stored on your computer, mobile phone, or tablet when you visit the SITE or when you install the mobile application on your mobile phone or tablet. The SITE shall collect, process and secure your navigation information in order to provide better service to its members and to make them benefit from the membership advantages within the scope of its legal obligation, provided that they are not used outside the scope and purpose specified by this Text. The SITE may match information gathered from you through different methods or at different times, such as information collected online and offline, and may use this information with those obtained from other sources, such as third parties. Moreover, the SITE cookies; may use “advertising technology” to provide you with ads which you may be interested in when you visit the search engines and/or the SITE. The SITE uses session cookies and persistent cookies. The session cookie expires when you close your browser. The persistent cookie, on the other hand, lasts a long time on your hard disk. You can remove the persistent cookies and reject both the session cookies and the persistent cookies by following the instructions given in your browser’s “help” file or by visiting the links “www.allaboutcookies.org/” and “http://www.youronlinechoices.eu“. If you reject persistent cookies or session cookies, you may continue to use the SITE, but you may not have access to all functions of the website or your access may be limited.
8. Measures for the Protection of Personal Data
Protection of personal data is an important issue for the SITE. The SITE takes the necessary precautions against unauthorized access to personal data or their loss, misuse, disclosure, alteration or destruction. The SITE uses commonly accepted security technology standards such as firewalls and Secure Socket Layer (SSL) encryption when storing personal data. Furthermore, when you send your personal data to the SITE, this data is transmitted through the SSL. The SITE undertakes to keep your personal data confidential, to take all kinds of technical and administrative precautions and to pay ultimate attention to provide privacy and security. Even though the SITE has taken the necessary precautions regarding the information security, in case your personal data is damaged or captured by the third persons as a result of the attacks on the website and the system, the SITE immediately informs you and the Personal Data Protection Board.
9. Amendments
The SITE may make an amendment at any time in this Text. These changes shall enter into force immediately upon the sharing of the Clarification Text and Approval Form of Processing and Protection of Personal Data on the site “www.swanleuco.com”. You will be informed about the changes made in the Text.
10. The Rights of the Personal Data Holder as stipulated in Article 11 of the LPPD
As personal data owners, if you submit your request concerning your rights to the SITE by the methods set forth below in this Text, the SITE will conclude the request free of charge within thirty days at the latest according to the nature of the claim. However, if a fee is provided for by the Personal Data Protection Board, the fee shall be charged at the rate specified by the SITE. In this context, the personal data owners have the right to;
You can also access your profile and make any necessary changes and/or updates in the “settings” section of the SITE application to change or update your data if there are any missing or incorrectly processed personal data or any changes have been made regarding your personal data.
In accordance with Article 13/1 of the LPPD, you may transmit your request for the exercise of your rights listed above to the SITE in writing or by other means provided by the Personal Data Protection Board. In this regard, the channels through which you will submit your applications in writing to the SITE in accordance with Article 11 of the LPPD and their procedures are explained below.
In order to use your above-mentioned rights, by filling out the form at https:// www.swanleuco.com which includes your statement regarding your right among those specified in Article 11 of the LPPD that you ask to benefit from, along with the required information to determine your identification; you can deliver a signed copy of the form together with the documents determining your identification to “Swanleuco, “Kılıcdede Mah. Kastamonu Sok. No:6 Kat:11/154 55060, Samsun, Turkey” by hand, send it through notary or several methods indicated in the LPPD or transmit your request to swanleuco@swanleuco.com e-mail address in a secure e-signed manner.
11. Communication Permit
Agreeing with the General Terms of Use and the Clarification Text and Approval Form of Processing and Protection of Personal Data, you give permission to the collection, storage, processing, usage and transmission of your personal data that you have expressly consented to be shared with us with the purpose of the conduct of our SITE activities, provision and offering of several advantages to you and the presentation of advertisement, sales, marketing, survey, reservation and all kinds of similar electronic communication that are all special to you along with the transmission of other communication messages. In parallel with the same purposes, these personal data are to be shared with all of the subsidiaries and affiliates of Swanleuco and with the third parties in the country and/or abroad in which we are in a contractual relationship. You also give permission to the sharing of your personal data to a certain extent with the third parties such as outsourcing service providers, cargo companies, law offices, research companies, call centers, software companies for complaint management and security provision, agencies, consulting companies, companies involved in the printing industry, social media channels and so on. Furthermore, these information will be shared with the third parties with which we are in a contractual relationship and which have the same legal and technical responsibilities with us regarding the data protection and security, and conform to the related Legislation provisions in order to provide you the services in a flawless manner, transmit your potential posts in a healthy way, and to deliver your notifications through mobile phone, SMS and/or e-mail at the right time. The members acknowledge and express their consent to the use and storage of personal data by the SITE in this manner. In accordance with Article 12 of the Law on the Protection of Personal Data, the SITE shall take all necessary measures to store the personal data in a secure way and to prevent unauthorized access and unlawful data processing.
12. Applicable Law, Authorised Court, and Execution Offices
The Clarification Text and the Approval Form of Processing and Protection of Personal Data are subject to the laws of the Republic of Turkey. The Samsun Central Court and Execution Offices are authorized to settle any dispute arising from the implementation of this Text.