Cookie Policy

Radiva Isı Sistemleri San. ve Tic. Ltd. Şti. (“Radiva”) values the protection of personal data and respect for privacy.

This Cookie Policy and Privacy Notice has been prepared by Radiva, as the data controller, to explain the methods, purposes and legal bases for processing personal data when using the website at radiva.com, the parties to whom such data may be transferred, cookie preferences and the rights of data subjects.

The relevant sections also explain the processing of personal data in connection with account registration, orders and communications through the website, as well as social media interactions relating to these services. This notice provides information under the Turkish Personal Data Protection Law No. 6698 (the “Law”); it does not constitute a declaration of explicit consent or permission to receive commercial electronic communications.

1. Definitions

Website: The Radiva website available at radiva.com.

Law: The Turkish Personal Data Protection Law No. 6698.

Data Controller: Radiva Isı Sistemleri San. ve Tic. Ltd. Şti., which determines the purposes and means of processing personal data.

Personal Data: Any information relating to an identified or identifiable natural person.

Online Visitor / Data Subject: A natural person, whether or not they have an account, who visits the website or whose personal data is processed in connection with the activities described in this notice.

Cookie: A small text file stored on your device through your browser when you visit the website. Cookies may be used for different purposes; the purpose and duration of use of each cookie are assessed separately.

Server Log Files: Files containing records of website access and activity, such as IP addresses, access times and pages visited.

Pixel Tags and Similar Technologies: Technical tools that may collect information about website use or interaction with content. Where they involve the processing of personal data, the relevant data protection rules also apply to these tools.

Board: The Turkish Personal Data Protection Board.

2. Personal Data Processed

The personal data processed varies depending on your activity on the website, the service you request and, where required, the permissions you grant. The information listed below is not collected to the same extent from every visitor.

2.1. Website visitors

Transaction security information, such as IP addresses and website traffic logs, may be processed. Depending on the cookies and similar technologies used, cookie identifiers, visit and browsing records, preference information, and country or region information derived from IP addresses may also be processed. Records for advertising and marketing purposes should not be created unless the applicable condition for processing personal data is met.

2.2. Account registration, forms, orders and after-sales services

The following information may be processed in connection with the activity you carry out:

• First name and surname; Turkish identification number or tax identification details where required by the nature of the transaction and applicable legislation.
• Contact details, such as email address, telephone number, delivery address and billing address.
• Products added to the basket and purchased, product dimensions and selected specifications, order history, order tracking codes, shipping and delivery information.
• Shopping lists, requests for price and stock notifications, gift voucher and loyalty points information, where the relevant features are used.
• IBAN, account number and related financial transaction information, to the extent required for payment or refund processing.
• Requests, complaints and explanations submitted through website forms, customer service and after-sales support channels, as well as updates you make to your account information.

Listing these data does not mean that all of them are stored in cookies. Forms, order transactions and cookies are different methods of collecting data.

2.3. Activities through social media

If you contact Radiva, post a comment or submit a request through social media, the first name, surname, username/profile details, photograph, contact details and message content you share on the relevant platform may be processed, limited to the scope of the interaction.

If registration or sign-in through a social media account is offered and you choose this option, the information you authorise the platform to share with Radiva is handled within the scope of the relevant activity. The fact that information is visible on a social media platform does not mean that it may be used for any purpose.

3. Methods and Legal Bases for Collecting Personal Data

Personal data is collected through the website, registration and contact forms, order and return transactions, customer service, social media interactions, cookies, server log files and similar technologies in use. Data may be collected by wholly or partly automated means, or by non-automated means provided that the data forms part of a filing system.

Your personal data is processed on the legal basis applicable to each activity:

Conclusion or performance of a contract — Article 5/2-c of the Law: This applies to data necessary for account registration and order processing, providing the products and services you request, and carrying out delivery and after-sales services.

Express provision in law and legal obligations — Articles 5/2-a and 5/2-ç of the Law: This applies to activities such as invoicing, accounting, maintaining statutory records and responding to lawful requests from competent authorities, to the extent required by the relevant obligation.

Establishment, exercise or protection of a right — Article 5/2-e of the Law: This applies to processing necessary for assessing requests and complaints, resolving disputes and protecting legal rights.

Legitimate interests — Article 5/2-f of the Law: Following the necessary assessment, this applies to processing required for purposes such as ensuring information security and preventing misuse, provided that your fundamental rights and freedoms are not harmed. This legal basis does not constitute general permission for all tracking or marketing activities.

Explicit consent — Article 5/1 of the Law: This applies to activities that are not based on another condition for processing personal data and require explicit consent. Cookies and similar technologies falling within this scope should not be activated before explicit consent has been given for the relevant purpose.

Where reliance is placed on the fact that data has been made public by the data subject, the processing is assessed only within the purpose for which the data was made public. Visiting the website, continuing to use it or reading this notice does not, by itself, constitute explicit consent.

4. Purposes of Processing Personal Data

Personal data is processed for the following purposes, in connection with the legal bases set out in Section 3 and to the extent required by the relevant activity:

Account registration and sales: Creating and managing accounts, receiving orders, processing payments and invoices, and handling delivery, returns, exchanges and after-sales support.

Communications and customer relations: Answering your questions, assessing your requests and complaints, providing information about orders and services, and sending notifications you have requested.

Security and legal obligations: Ensuring the security of the website and transactions, preventing unauthorised access and misuse, maintaining records in accordance with applicable legislation and responding to legal requests.

Preferences, analytics and marketing: Remembering preferences, assessing website use, improving content and services, and carrying out promotional and advertising activities, depending on the feature used and the applicable condition for processing personal data. Activities requiring explicit consent should not begin before the relevant permission has been obtained.

Consent to cookies does not also constitute permission to send promotional emails or SMS messages. Commercial electronic communications are assessed separately in light of their own purposes and applicable legislation.

5. Cookies Used and How to Control Them

5.1. Types of cookies

Strictly necessary cookies: Cookies needed to provide a service requested by the user or to enable communication technically. Maintaining a session, operating the shopping basket and security functions may fall within this category. Classification depends on the actual function of the cookie.

Functional cookies: Cookies used to remember preferences and personalise the user experience. Uses that are not necessary for a service explicitly requested by the user and are not based on another condition for processing personal data are subject to explicit consent.

Analytics / performance cookies: Cookies that enable website traffic and use to be assessed. Analytics activities requiring explicit consent should not begin before permission has been given.

Advertising / marketing cookies: Cookies used for purposes such as displaying interest-based advertisements, retargeting or tracking interactions with advertisements. Permissions relating to these purposes must be managed separately.

Cookies may be classified as first-party or third-party cookies depending on who places them, and as session or persistent cookies depending on their duration. These classifications do not automatically make a cookie strictly necessary or exempt from consent.

5.2. Cookie preferences and withdrawal of explicit consent

For cookies requiring explicit consent, you must be able to set your preferences by separate category, refuse cookies and subsequently withdraw permission you have given. Simply continuing to use the website or closing the information banner is not regarded as consent.

You can view, delete or block cookies through your browser’s privacy and security settings. Browser settings do not replace the preference and consent management that must be provided on the website. Blocking strictly necessary cookies through your browser may affect functions you request, such as signing in or using the shopping basket.

Withdrawal of explicit consent takes effect for the future and does not, in itself, invalidate the lawfulness of processing carried out on the basis of valid explicit consent before its withdrawal.

6. Recipients of Personal Data and Purposes of Transfer

6.1. Transfers to recipients in Türkiye

To the extent required by the relevant activity and in accordance with the conditions set out in Article 8 of the Law, personal data may be transferred to business partners and service providers for sales, delivery, payment, accounting, technical infrastructure and support processes. Information necessary to meet a relevant legal obligation or respond to a lawful request may also be provided to authorised public institutions and organisations.

Transfers to group companies, subsidiaries or affiliates are considered only where there is an actual need for the transfer and a valid legal basis. Such relationships do not, by themselves, confer general access to personal data.

6.2. Transfers outside Türkiye

Where personal data is transferred outside Türkiye because service providers or technical infrastructure located abroad are used, the conditions set out in Article 9 of the Law must also be met.

In addition to the relevant condition for processing personal data, a transfer must rely on an applicable adequacy decision or one of the appropriate safeguards provided for in the Law. Where neither an adequacy decision nor an appropriate safeguard is available, the exceptions under the Law may only be considered within the prescribed conditions and the limits applicable to occasional transfers. Explicit consent to the use of cookies does not, by itself, make regular transfers outside Türkiye lawful.

7. Rights of Data Subjects under Article 11 of the Law

By submitting a request to Radiva, you may exercise the following rights under Article 11 of the Law:

• Learn whether your personal data is being processed.
• Request information about the processing if your personal data has been processed.
• Learn the purposes of processing and whether your data is used in accordance with those purposes.
• Learn the third parties to whom your data has been transferred in Türkiye or abroad.
• Request correction of personal data that has been processed incompletely or inaccurately.
• Request the erasure or destruction of your personal data under the conditions set out in Article 7 of the Law.
• Request that the third parties to whom your data has been transferred be notified of any correction, erasure or destruction.
• Object to a result that is detrimental to you arising from the analysis of your data exclusively through automated systems.
• Request compensation for damage suffered as a result of unlawful processing of your personal data.

7.1. How to submit a request

Data controller: Radiva Isı Sistemleri San. ve Tic. Ltd. Şti.

Website:radiva.com

Email:info@radiva.com

Registered electronic mail (KEP) address: radiva@hs01.kep.tr

You may submit your requests in writing or by the methods specified in the Communiqué on the Principles and Procedures for Requests to the Data Controller. Requests using registered electronic mail (KEP), a secure electronic signature or a mobile signature may be submitted in accordance with the relevant procedural requirements.

If you wish to submit a request by email, you may write to info@radiva.com from an email address that you have previously provided to Radiva and that is registered in our system.

Your request must include your first name and surname; your signature for written requests; your Turkish identification number if you are a citizen of the Republic of Türkiye, or your nationality and passport number or identification number, if any, if you are a foreign national; your residential or business address for correspondence; your email address, telephone and fax number for notifications, if available; and the subject of your request. Relevant information and documents must also be attached.

7.2. Handling requests

Requests are handled as soon as possible, depending on their nature, and no later than thirty days. As a rule, requests are handled free of charge; however, if an additional cost is incurred, a fee may be charged in accordance with the tariff set by the Board. If the request results from an error by Radiva, any fee charged will be refunded.

If a request is accepted, the necessary action is taken; if it is rejected, the reasons for rejection are explained. The response is provided in writing or electronically.

If your request is rejected, the response is insufficient or no response is provided within the prescribed period, you may lodge a complaint with the Board within thirty days of becoming aware of the response and, in all cases, within sixty days of the date of your request, provided that you have first exhausted the request procedure with Radiva.

8. Data Security, Retention and Updates to This Notice

Radiva is required to take the necessary technical and organisational measures to prevent unlawful processing of and unlawful access to personal data, safeguard the data and ensure an appropriate level of security.

Personal data is retained for the period prescribed by applicable legislation or required for the purpose of processing. When the grounds requiring processing no longer apply, the data is erased, destroyed or anonymised in accordance with applicable legislation.

If you are redirected from the website to other websites or applications, the relevant services’ own data processing practices and notices may also apply. This does not remove Radiva’s obligations arising from its own data processing and transfer activities.

This notice is updated when legislation or actual data processing practices change. A new processing activity requiring explicit consent cannot begin solely on the basis of an update to this notice or your continued use of the website.

Visiting the website or reading this notice does not constitute blanket consent to the processing of personal data for all purposes or to the use of cookies.