Acto Pharma

Processing of Personal Data and Data Security



For all your questions and requests regarding all the Policies stated below, ACTO PHARMA HİJYEN SAN. TİC. A.Ş., you can reach the following communication ways:


Address:  Akçaburgaz Mh. 3038 Sk. No: 11 34522 Esenyurt – Istanbul – Turkey

Phone:  +90 850 432 22 86




Acto Pharma Hijyen San. Tic. A.Ş (, we strive to protect the rights of our members who use our site and benefit from our services on all platforms in order to ensure safe and complete use of our services. Accordingly, this Actopharma Privacy Policy (“Policy”) has been prepared in order to process the personal data of our members in full compliance with the Law on Protection of Personal Data (“Law”) numbered 6698 and to inform our users in this context. Security Policy – Personal Data Retention and Destruction Policy and Cookie Policy are an integral part of this Policy.



This Policy is made within the scope of the “disclosure obligation of the data controller” specified in Article 10 of the Law No.6698 (Law).


Who is the Data Controller?

It refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system. ACTO PHARMA HİJYEN SAN. TRADE A.Ş   acts as  DATA SUPERVISOR (Actopharma).


Who is the Personal Data Processing Policy Applied? (Related person)

Under the Law, “Relevant Person” refers to the real person whose personal data is processed, and within the scope of this Policy, the relevant persons – but not limited to those listed – include the following:

– All users connecting / using Actopharma E-commerce channels

– All users using Actopharma Mobile applications

– All our customers in the Actopharma database (CRM System)

– All our customers who shop from Actopharma Headquarters / office or Actopharma E-Commerce channels

– Using any of the Actopharma communication options

– All our customers who communicate with Actopharma through their Actopharma social media accounts (including but not limited to sharing comments, making requests)

– Our customers participating in the activities organized by Actopharma

– All our customers who fill out questionnaires and forms in order to benefit from the opportunities Actopharma offers to its customers.

– All users connected to the guest network (wifi) in Actopharma’s offices, warehouses and stores

– Employee candidates who send a resume to Actopharma through career portals, İŞKUR, via e-mail, through a reference, by physically filling out the application form.

– All our employees

– Our former employees who previously worked in Actopharma but whose employment contract expired for any reason

– All our business partners and their employees within the scope of our commercial activity

– Shares / will share personal data with Actopharma face to face, distance, verbally, in writing or electronically, without being limited to the foregoing; all natural persons who have directly given / will give or have enabled / will allow to be obtained by Actopharma


Which Data Are Processed?

First of all, we would like to state that; Personal data can be processed in accordance with the provisions of the Law No. 6698 on the Protection of Personal Data in line with the “Explicit Consent” of the Relevant Person.

Below are the data processed by Actopharma and considered as personal data in accordance with the Law. Unless otherwise explicitly stated, the term “personal data” within the scope of the terms and conditions provided within the scope of this Policy shall include the following information.

– Identity Information

– Communication information

– User Information

– User Transaction Information

– Process Security Information

– Financial Information

– Marketing Knowledge

– Request / Complaint Management Information

Data that are irreversibly anonymized by Articles 3 and 7 of the Law on the Protection of Personal Data will not be considered as personal data in accordance with the provisions of the aforementioned law and the processing activities related to these data will be carried out without being bound by the provisions of this Policy.

5/2 of the Law on the Protection of Personal Data. We would like to remind you that there is no need to obtain consent from the individuals in cases that fall within the scope of the cases listed in the Article These situations are counted as follows:

  1. a) It is clearly prescribed in the laws.
  2. b) It is mandatory for the protection of the life or physical integrity of the person who is unable to disclose his consent due to actual impossibility or whose consent is not legally valid.
  3. c) It is necessary to process personal data belonging to the parties of the contract, provided that it is directly related to the establishment or performance of a contract.

ç) It is mandatory for the data controller to fulfill his legal obligation.

ç) The person concerned has been made public by himself.

  1. d) Data processing is mandatory for the establishment, use or protection of a right.
  2. e) Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.


What does the processing of your Personal Data mean?

Processing of personal data; Obtaining, collecting, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying these data by fully or partially automated or non-automatic means provided that they are part of any data recording system, or It refers to all kinds of operations performed on data such as preventing their use.


Personal Data Processing Purposes and Legal Basis

All kinds of personal data collected within Actopharma directly or indirectly and that may differ depending on the service provided by Actopharma, its commercial activities and even legal requirements will be processed according to the personal data inventory and  within the scope of the Data Security Policy  , directly or indirectly belonging to the Related Persons. all personal data obtained via the route;

  1. a) Confirming the identity information of the shopper through and / or E-Commerce channels; To be able to provide the necessary information in order to fulfill all of our contractual obligations, especially the distance sales contract and the contracts concluded as per the Consumer Protection Law; to fulfill the acts;
  2. b) To be able to provide information to all public officials upon request in matters pertaining to public security and upon request from the Civil and Criminal Courts, as required by the legislation;
  3. c) To be able to use it in all kinds of marketing activities of Actopharma, in particular, to inform about the special and general campaigns organized by Actopharma;
  4. d) To be able to know our customers who shop from the store, website and / or mobile applications and to be able to carry out marketing activities in this direction;
  5. e) To be able to use it in various marketing and advertising activities and to be able to conduct marketing activities, surveys and market analysis in electronic and / or physical environment through contracted organizations;
  6. f) To be able to evaluate and report customer complaints and suggestions regarding our services, to share data with our contracted business partners in this regard and within the scope of marketing activities;
  7. g) To be able to fulfill our legal obligations and to use our rights arising from the current legislation,
  8. h) To be able to transfer the service to third parties and third companies (our contracted business partners) to fulfill the legal obligation,
  9. i) To be able to store in data data for the purpose of fulfilling contractual obligations (such as delivery of the product, etc.),
  10. j) To be able to store your contact information in data data in order to remind you of your rights against Actopharma,
  11. k) Recruiting employees within the framework of Actopharma’s human resources policies and needs, conducting and developing recruitment processes
  12. l) To evaluate and finalize job applications and to communicate with candidates who have applied for a job.
  13. m) May be processed by Actopharma in order to carry out our human resources policy, to evaluate, develop and improve our policy and services, to evaluate the performance of our employees.

Actopharma headquarters, offices and warehouses are monitored by security cameras in order to ensure the safety of our customers, job candidates and employees; For this reason, we would like to inform you that the images of the people visiting our stores, central offices and warehouses can sometimes be recorded by a security camera and that all public officials will be informed and shared with them upon request from the administrative and judicial authorities in order to ensure public safety.

We would like to inform you, our employee candidates, that the resumes of our employee candidates who send their CVs to Actopharma in order to apply for a job in the above-mentioned ways, the information obtained at the time of the application can be used to evaluate the position they applied for or the possible positions that may arise in the future, and can be stored in Actopharma’s HR data. The personal files of our staff who are currently working within Actopharma and our former personnel who have worked in Actopharma continue to be kept within Actopharma in accordance with our legal obligations.

We would also like to state that the personal data of all our business partners and their employees who benefit from the protection of the Law on the Protection of Personal Data within the scope of our commercial activities can be processed as Actopharma’s customer portfolio in order to fulfill the contractual obligations during and after the commercial relationship.

All these personal data explained above in detail, in accordance with the basic principles stipulated by KVKK and within the personal data processing conditions and purposes specified in Articles 4, 5 and 6 of the KVKK, Turkish Code of Obligations No 6098, Law No 6502 on the Protection of the Consumer. We operate in accordance with all legal regulations and in line with the above purposes, including the Labor Law No. 4857, the Law No. 6563 on the Regulation of Electronic Commerce and the regulations issued in accordance with these Laws.

Actopharma provides personal data provided by the Data Owner, creating a membership record and account and keeping the records related to this, making use of the services provided by the Data Owner on, detecting system errors and monitoring performance and improving the operation of, maintenance and support services. To carry out the necessary work by business units to make use of the products and services offered by Actopharma, including the purposes of providing backup services, and to carry out the relevant business processes, and to customize these products and services according to the likes, usage habits and needs of the relevant people and to recommend and promote them planning and execution of the activities that are taking place,Carrying out the necessary work by the relevant business units for the realization of the commercial activities carried out by Actopharma and carrying out the related business processes, ensuring the legal, technical and commercial-business security of Actopharma and the people with whom it has business relations, and planning and execution of Actopharma’s commercial and / or business strategies can be processed for their purpose.


Transfer of Personal Data

First of all, we would like to state that your personal data are not shared with third parties without your explicit consent.

But; We would also like to state that we are obliged to share your personal data requested by us due to our legal obligations. For example; We are able to share your personal data as per our legal obligation upon request from judicial authorities and public institutions. Likewise, in order to fulfill our obligations arising from the Law, a transfer can be made to our contracted business partners, from whom we receive services in this regard, solely for this purpose. In addition, your personal data can be shared with third parties in order to fulfill our contractual obligations with you. Before making these shares, we take technical and legal measures to prevent violations of your and ours. But;

Again, your personal data can be provided to our business partners, suppliers, services for the purposes of ensuring the legal and commercial security and supervision of people who have any relationship with Actopharma, administrative operations, business partner / customer / supplier (authorized or employees) evaluation processes to carry out Actopharma’s human resources policies. can be transferred to our providers, Group Companies, Company officials, shareholders, legally authorized public institutions and private persons within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law.

It can be shared with various agencies, advertising companies and survey companies, other third parties and our relevant business partners within the scope of various marketing activities related to the product groups that are of interest to you and to provide you with better service.

We would also like to state that your information may be shared for reference purposes upon request from third company officials regarding our former personnel who previously worked in Actopharma.

Your personal data collected in accordance with KVKK and Articles 1 and 3 above; It can be transferred in accordance with the basic principles stipulated by the KVKK and within the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK and for the purposes stated above.

In addition, Actopharma transfers personal data abroad for the above-mentioned purposes;

  • If the data owner has explicit consent, or
  • In cases where there is no explicit consent of the data owner but one or more of the other conditions mentioned above are met;
  • There is adequate protection in the country where the data is transferred, and
  • If there is not enough protection in the country where the data is transferred, it can be transferred provided that Actopharma undertakes sufficient protection in writing with the data controller in the relevant foreign country and the permission of the Personal Data Protection Board is obtained.

In this context:

There will be 3rd parties that can access your Personal Data anonymously or openly / in order to fulfill the requirements of the contracts made with the parties, taking into account the DATA SECURITY policies and taking the necessary commitments. Actopharma will be able to update the 3rd parties it works with from time to time. In this case, notifications will be made in accordance with the legislation, and your approval will be obtained if necessary. Third party parties will not process your data without your EXPRESS CONSENT where direct and explicit consent is required.


Within the scope of the Data Owner’s explicit consent, Actopharma follows the actions of the Data Owners on, increasing the user experience, creating statistics, profiling, direct marketing and remarketing, creation of promotional suggestions specific to the Data Owner and It will be able to process data for the purpose of transmission and use of the data obtained in this context in all kinds of advertising and material content and share this data with the parties mentioned below.


Collection Method of Personal Data and Legal Reason

Personal data is collected on and in all kinds of electronic media.


Among the methods of collecting data:

– Call center: The information of all persons contacting our customer line at +90 850 432 22 86 can be processed provided that the above-mentioned purposes – The purpose of the person’s search – is limited to the scope of the contract between Actopharma and the Related Person.

– Actopharma E-Commerce Channels: As a result of the membership applications to be made through the page, the data can be processed in accordance with the application conditions. All our customers can contact Actopharma if they wish, and apply for membership.

– With your personal application to or Actopharma Headquarters: info @ and similar e-mail addresses are written communication channels that allow customers to reach Actopharma by e-mail, and to communicate the information of all Relevant Persons who reach Actopharma through these channels will be stored for the purpose.

– Actopharma, head office and warehouses: Images of all visitors and employees recorded on the security camera will be stored. Again, the personal information of the people visiting our stores, head offices and warehouses can be processed provided that it is limited to the above-mentioned purposes.

– Job Applications: Personal data regarding job applications are received through career portals, e-mail, İŞKUR, reference and physically filling the application form.

Personal data collected for the aforementioned legal reasons can be processed and transferred for the purposes specified in Articles 5 and 6 of Law No. 6698 and in this Policy.


Rights of Personal Data Owner

 DATA OWNERS-RELATED PERSONS, in  accordance with Article 11 of the Law ,

–  LEARNING  Learning whether personal data is being processed about them, requesting information if their personal data has been processed,

– LEARNING IF TRANSFERRED TO THE THIRD PARTIES  Learning the purpose of processing personal data and whether they are used for their intended purpose, to know the third parties to whom personal data are transferred,

–  CORRECTION-NOTIFICATION  Requesting correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to third parties to whom personal data is transferred,

–  REQUEST FOR DESTRUCTION In  the event that the reasons for processing are eliminated despite the fact that it has been processed in accordance with the provisions of the Law and other relevant laws, to request the deletion or destruction of personal data and to notify the third parties to whom the personal data has been transferred,

–  OBJECTION It  has the right to object to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems and to demand the compensation of the damage in case of damage due to unlawful processing of personal data.

Requests for the use of these rights can be transmitted by personal data owners through the methods specified in the Policy on the Processing and Protection of Personal Data prepared by Actopharma within the scope of Law No. 6698 on Actopharma will finalize these requests within thirty days. Actopharma reserves the right to charge a fee based on the fee schedule (if any) determined by the Personal Data Protection Board regarding the requests.


Applications for this purpose:

Actopharma Headquarters By applying by the Relevant Person or institution, personally;

By making an identity confirmation from the customer service line of +90 850 432 22 86;

By sending an e-mail to the e-mail addresses to be specified on the and / or site,

By other methods determined by the Personal Data Protection Board

It can be done.


How Long Will Your Personal Data Be Processed and What Are the Methods of Disposal?

While determining the retention periods of personal data, Actopharma determines the legislation in force and the purposes of processing the data subject to the process. In accordance with the KVKK, your personal data processed for the purposes specified in this Clarification Text, KVKK Art. Your personal data will be deleted, destroyed or anonymized by us when the purpose of processing in accordance with 7 / f.1.

Within the scope of Actopharma Data Security Policy and Personal Data Retention and Destruction Policy

The maximum period determined within the scope of personal data processing inventory 

Within this period

  •      Deletion,
  •      Destruction and
  •      Anonymization

Process (Deletion, destruction and anonymization will collectively be referred to as “destruction”.)

– Periodic destruction processes

Is to determine.


Actopharma, when the conditions for the processing of Personal data and Special Qualified personal data disappear, in other words, when the EXCLUSIVE consent is eliminated, the EXCEPTIONS that enable the processing of personal data without the explicit consent of the Personal Data subject and the Special Qualified Personal Data concerned are eliminated,

Evaluating technical and administrative reasons, it destroys the data with the option of the appropriate method of destruction below:

  1.     Deletion:  Deletion of personal data is the process of making personal data inaccessible and unavailable for the relevant users in any way.
  2.     Destruction: The  destruction of personal data is the process of making personal data inaccessible, retrieved and reusable in any way.

III.    Anonymization: The  anonymization of personal data is making personal data unrelated to an identified or identifiable natural person under any circumstances, even if they are matched with other data.



Actopharma, as a data controller, you have shared with YOUR EXPRESS CONSENT:

To prevent unlawful processing of personal data,

To prevent unlawful access to personal data,

To ensure the protection of personal data,

in order to take all necessary technical and administrative measures to ensure the appropriate level of security.

In the event that personal data is processed by another natural or legal person on its behalf, Actopharma makes the necessary warnings to take the above-mentioned measures and performs the necessary audits to ensure data security,

It trains its personnel on data security, takes the necessary commitments from its personnel and all kinds of third parties,

Despite all these precautions, if personal data are obtained by others through illegal means, this situation will be reported to the Related Person and the Board as soon as possible.

Due to the above-mentioned responsibilities and commitments, Actopharma applies the Data Security Procedure numbered PR.026 and dated 08.10.2017.


Cookie Policy

Cookies are used with (“Site”) to show personal content and advertisements to visitors, to perform analytical activities on the site and to follow visitor usage habits.

This Cookie Policy is an integral part of the Privacy Policy.

Actopharma has prepared this Cookie Policy (“Policy”) in order to explain which Cookies are used on the Site and how users can manage their preferences in this regard.


What is a Cookie (“Cookie”)?

Cookies are small text files stored by websites you visit on your device or network server via browsers. Cookies are created by servers associated with the website you visit. Thus, when the visitor visits the same site, the server can understand it.

Cookies do not contain personal data about visitors such as name, gender or address. For more detailed information about cookies, you can visit  and  .


Which Cookies Are Used?

Cookies can be categorized in terms of ownership, lifetime and purpose of use:

According to the party placing the cookie, cookies and third party Cookies are used. While cookies are created by Actopharma, third-party cookies are managed by different companies in cooperation with Actopharma.

Session cookies and persistent cookies are used, depending on the time it is active. While session cookies are deleted after the visitor leaves, permanent cookies can remain on the visitors’ devices for various periods depending on the area of ​​use.

According to the purposes of use, technical cookies, verification cookies, targeting / advertising cookies, personalization cookies and analytical cookies are used on


Why Are Cookies Used?

On, Cookies are used for the following purposes:

To perform the basic functions necessary for to work.

To analyze and to increase performance.

To increase the functionality of and to provide ease of use.

To perform personalization, targeting and advertising activities.


How Can You Manage Your Cookie Preferences?

Acto Pharma attaches great importance to the users’ ability to use their preferences on their personal data. However, preference management is not possible for some Cookies that are mandatory for the site to work. In addition, we would like to remind you that if some Cookies are turned off, various functions of the Site may not work.

Information on how to manage preferences for Cookies used on is explained below:

Visitors have the opportunity to customize their preferences for cookies by changing the browser settings they view on If the browser in use offers this opportunity, it is possible to change the preferences for Cookies through the browser settings. Thus, although it may differ according to the possibilities offered by the browser, data owners have the opportunity to prevent the use of cookies, to choose to receive a warning before the cookie is used, or to disable or delete only some cookies. Although the preferences in this subject vary according to the browser used, the general explanation is It is possible to reach at. Cookies preferences may need to be made separately for each device on which the visitor accesses

 You can use the application at to turn off Cookies managed by Google Analytics  .

To manage the personalized advertising experience provided by Google, you  can manage your  personal information and privacy information at .

In terms of cookies used by many companies for advertising activities, preferences  can be managed via your advertisements  .

To manage Cookies on mobile devices, the settings menu of the mobile device can be used.



This Policy has entered into force as of January 1, 2018.

This Policy may be updated from time to time. The most up-to-date version of the Policy is   available at .



The Relevant Person will be able to submit their requests regarding the implementation of this Policy and the Personal Data Protection Law to ActoPharma in writing through the following channels:

To communicate:

Address: Akçaburgaz Mh. 3038 Sk. No: 11 34522 Esenyurt – Istanbul – Turkey

Phone: +90 850 432 22 86