At _____________________, we attach great importance to the privacy and security of your personal data. In this context, processing and storing all personal data belonging to all individuals associated with _____________________, including our customers and business partners who benefit from our products and services, in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK”) is one of our priorities. In line with our title as "Data Controller" under the KVKK and our awareness of this responsibility, we would like to inform you as follows regarding the purposes of processing your personal data, the methods and reasons for collecting your data, your rights regarding the processing of your personal data, and the application procedures and principles for exercising these rights: a. What is Personal Data? Which Personal Data do we collect? Personal data refers to any information that can be associated with you, primarily including personal information relating to your identity (name, surname, Turkish Republic identity number, etc.), as well as address and telephone information, vehicle and license plate information, family status information, IP address, bank account information (“Personal Data”), and a special type of this, Special Categories of Personal Data, refers to sensitive personal data such as your race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and clothing, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data (“Special Categories of Personal Data”). The explanations we have made on this page regarding your Personal Data also cover your Special Categories of Personal Data. In this context, as _____________________, we collect Personal Data of our customers, business partners, employees, job applicants, platform (our internet/mobile sites and applications) users, visitors, subcontractors and similar authorized personnel and employees of institutions with whom we have business relationships, in accordance with the KVKK (Personal Data Protection Law) when necessary. We can detail the Personal Data we collect as follows:
Identity Data: This includes personal identification data such as name, surname, Turkish Republic identity number, and photocopy of identity card, collected from our customers, business partners, employees, job applicants, platform (our internet/mobile sites and applications) users, visitors, and authorized personnel and employees of subcontractors and similar business partners. Contact Data: This includes data that enables communication with the individual, such as telephone number, address, email address, and IP address, collected from our customers, business partners, employees, job applicants, platform (our internet/mobile sites and applications) users, visitors, and authorized personnel and employees of subcontractors and similar business partners. Family Member Data: This includes data about the family members and relatives of the individual, collected from our employees, job applicants, and authorized personnel and employees of subcontractors and similar business partners, in accordance with relevant legislation and/or to protect the legal and other interests of our Company or the individual concerned. Financial Data: This includes data such as salary, wage information, and bank account information that we collect from our employees, job applicants, customers, business partners, subcontractors, and authorized personnel and employees of similar organizations with whom we have business relationships, according to the legal relationship our company has established with the data subject. Personal Data: This includes all types of personal data collected from our employees, job applicants, subcontractors, and employees of similar organizations with whom we have business relationships, which form the basis for the personal rights of individuals who are in an employment relationship with our company. Physical Space Security Data: This includes personal data such as security and camera recordings obtained from our customers, business partners, employees, job applicants, visitors, and authorized personnel and employees of subcontractors and similar business partners, upon entry to and during stay within the physical space. Communication and Complaint Management Data: This includes personal data obtained from our customers, business partners, platform (our internet/mobile sites and applications) users, visitors, and authorized personnel and employees of subcontractors and similar business partners during the processes of receiving and evaluating all kinds of requests or complaints directed to our company. Special Categories of Personal Data: This includes health data, biometric data (voice and video recordings), religious affiliation, and information about associations and unions, as specified in Article 6 of the KVKK (Personal Data Protection Law), which we collect from our customers, business partners, employees, job applicants, visitors, and authorized personnel and employees of subcontractors and similar business partners. Other Data: This includes data processed for technical security purposes, purchase information, cookies, and other data collected automatically from our customers, business partners, employees, job applicants, platform (our internet/mobile sites and applications) users, and authorized personnel and employees of subcontractors and similar business partners.
b. How and on what legal grounds do we collect/process your personal data? We collect your personal data automatically or non-automatically, verbally, in writing, or electronically, for the main purposes and methods listed below, and through other channels that may be added in the future. We also collect your personal data on our internet and mobile platforms (our internet/mobile sites and applications), and various social media platforms. We collect personal data through various channels, including: our social media accounts operated on behalf of _____________________; our call center managed by _____________________; other communication methods including email, short messages (“SMS”) or multimedia messages (“MMS”); contracts signed with you or your company as an authorized representative within the scope of sales and marketing activities; commercial offers; printed and electronic forms; business cards and other documents provided by you during customer visits; third parties such as _____________________ group companies, business partners, dealers and sales channels, manufacturing companies or companies supplying services/products; and various other sources including the Commercial Registry, through verbal, written or electronic means, wholly or partially automated or non-automated as part of any data recording system.
We process your Personal Data, which we collect in accordance with the methods above, based on one or more of the following legal grounds: Your explicit consent, Processing permitted by the laws and regulations in force in the Republic of Turkey, Being necessary for the protection of your or another person's life or physical integrity when you are unable to express your consent due to factual impossibility, Being necessary for the performance of the contract we have entered into with you or your company, Processing your Personal Data is necessary for the fulfillment of our legal obligations, Your Personal Data has been made public by you, Being necessary for the exercise or protection of our legal or contractual rights as _____________________, Processing your Personal Data is necessary for our legitimate interests, provided that it does not harm your fundamental rights and freedoms. As _____________________, we retain all Personal Data we process in accordance with the periods mandated by the KVKK (Personal Data Protection Law) and other legislation, and in any case, as long as the above legitimate purposes do not cease to exist, by taking all necessary administrative and technical measures.
c. For What Purposes Do We Process Your Personal Data? We process your Personal Data, depending on its nature, for the following general purposes: Fulfillment of contracts concluded by _____________________, provision, production, sale, delivery and installation of products and services offered, development of products and services and conducting necessary studies and evaluations to enable you to benefit from them, performing after-sales maintenance and repair operations Monitoring and fulfilling obligations arising from consumer legislation and responding to consumer applications Monitoring, evaluating and providing support services for requests and complaints of relevant persons such as customers and consumers, consumer satisfaction management and the implementation of planning, statistics and satisfaction surveys within this scope Conducting quality assessment and improvement studies to provide better and more reliable products and services and to ensure sustainability, auditing suppliers, subcontractors and similar persons with whom we have business relationships Conducting advertising and marketing activities for products and services offered by _____________________ and providing information on promotions, campaigns, offers, events and similar matters and new products and services, conducting corporate communication activitiesExecution of marketing and CRM (Customer Relationship Management) activities Organization of corporate communication and other events and invitations within this scope, providing information about them, conducting market research studies Improvement of the digital platforms we offer to our customers, consumers and business partners and compilation of statistics such as the number, type, frequency of visits, behavior, geographical location of users in order to provide efficient and personalized experiences to platform users, providing personalized content, campaigns and advertisements according to the interests and needs of platform (internet and mobile site and applications) users, using cookies for this purpose _____________________ . Ensuring the legal and commercial security of individuals with whom the company has a business relationship (Planning of administrative operations related to communication conducted by our company, ensuring the physical security and control of company locations, evaluation and audit processes of business partners/customers/suppliers (authorized persons or employees), legal compliance process, etc.) Exercise of legal rights, use of transaction history information as evidence in case of dispute after the termination of the legal relationship _____________________ Determination and implementation of commercial, legal and business strategies _____________________ Implementation of human resources, accounting/finance policies Planning, auditing and execution of information security processes Compliance with domestic and international legislation, provision of information requested by public institutions and organizations, fulfillment of reporting obligations.
d. Transfer of Personal Data and Processing of Personal Data by Third Parties The Company may transfer personal data to a third natural or legal person in accordance with the KVKK (Personal Data Protection Law) regulations. In this case, the Company ensures that the third parties to whom it transfers data also comply with this Policy. In this context, necessary protective provisions are added to the contracts concluded with the third party. Transfer of personal data to third parties located in Turkey; Personal data may be transferred by the Company to third parties located in Turkey without seeking explicit consent in the exceptional cases specified in KVKK articles 5.2 and 6.3, or otherwise with the explicit consent of the Data Subject (KVKK articles 5.1 and 6.2). Transfer of personal data to third parties located abroad; Personal data may be transferred by the Company to third parties located abroad without explicit consent in the exceptional cases specified in Articles 5.2 and 6.3 of the Personal Data Protection Law (KVKK), or otherwise with the explicit consent of the Data Subject (KVKK Articles 5.1 and 6.2). However, the following conditions must be met with regard to the foreign country to which the data will be transferred: The foreign country to which the personal data is transferred must be classified by the Board as a country with adequate protection. If the foreign country to which the transfer will take place is not on the Board's list of safe countries, the Company and the Data Controllers in that country must obtain permission from the Board by providing a written commitment that adequate protection will be ensured.
e. Your Rights and Application Procedure e.1. Your Rights Regarding Your Personal Data _____________________ . We would like to inform you that you have the following rights regarding your data processed within our company and its affiliates: To learn whether your Personal Data is being processed, To obtain information about your Personal Data if it is being processed, To learn the purpose of the processing of your Personal Data and whether your Personal Data is being used in accordance with its purpose, To learn who the third parties are to whom the data is transferred, if any, domestically or internationally, and what data is transferred, To request the correction of your Personal Data if it is incomplete or inaccurate, To request that the correction, deletion or destruction of your Personal Data be notified to the third parties to whom your Personal Data has been transferred, To request the deletion or destruction of your Personal Data if the reasons requiring the processing of your Personal Data cease to exist or if your Personal Data becomes outdated, To object to a result that is detrimental to you arising from the analysis of your Personal Data exclusively through automated systems, To demand compensation for damages if you suffer damage due to the unlawful processing of your Personal Data.
e.2. Application You can submit your requests regarding your Personal Data by filling out the application form linked below: Delivering it to the consulting office at our company address, which is included in the Data Controller Identity Information section, or by sending a notification via a Notary Public to the same address, or via registered electronic mail. _____________________ will process the requests directed to it as soon as possible, and at the latest within 30 (thirty) days, free of charge, depending on the nature of the request. If there is a cost due to the fulfillment of your requests, we may only request the fees in the tariff determined by the Personal Data Protection Board. _____________________ may accept or reject the requests by explaining the reason, and we may communicate this answer to the person making the request in writing or electronically. If the request is accepted, we, as _____________________, are obliged to immediately fulfill the request.
e.3. Complaint
If your requests are rejected by _____________________, if you are not satisfied with the answer given by _____________________, or if no answer is given, you may file a complaint with the Personal Data Protection Board within 30 (thirty) days from the date you are notified of the answer, or within 30 days from the end of the 30 (thirty) day period if no answer is given.
f. Data Controller Identity Information
The expression _____________________ used in this text is issued for the _____________________ subsidiary established in Turkey and whose details are given below, and is addressed to the data subjects of the company specified below, for which the company is the data controller:
Address:
Telephone:
Email:
Application Form Under the Personal Data Protection Law (KVKK)
In accordance with the Law No. 6698 on the Protection of Personal Data ("KVKK"), personal data owners, defined as data subjects ("Applicant" hereinafter referred to as "Applicant"), are granted the right to make certain requests regarding the processing of their personal data in Article 11 of the KVKK. In accordance with the first paragraph of Article 13 of the KVKK; applications regarding these rights to our Company, which is the data controller, must be submitted to us in person, in writing in Turkish, and through the following methods determined by the Personal Data Protection Board ("Board").
Below is information on how to submit written applications to us. In accordance with the Communiqué on the Procedures and Principles for Applications to the Data Controller (dated 10/03/2018 and numbered 30356 in the Official Gazette), the following information must be included in applications: Information to be Filled in During Application: Name, surname, and signature if the application is in writing, Turkish Republic identity number for Turkish citizens, nationality, passport number, or identity number if available for foreigners, Residential or business address for notification purposes, Email address, telephone and fax number for notification purposes, if any, Subject of the request, Additionally, relevant information and documents should be attached to the application. If you wish to make an application regarding your personal data, you must complete the following application form in full. This application form has been prepared to determine your relationship with our Company, to fully identify any personal data processed by our Company, and to ensure that your application is answered correctly and within the legal timeframe. To eliminate legal risks that may arise from unlawful and unfair data sharing, and especially to ensure the security of your personal data, our Company reserves the right to request additional documents and information (such as a copy of your national identity card or driver's license) for identity and authorization verification. Our Company does not accept responsibility for any claims arising from inaccurate or outdated information or unauthorized applications submitted through this form. In accordance with Article 13, paragraph 2 of the Personal Data Protection Law, your applications will be answered in writing free of charge within a maximum of thirty days from the date your request is received, depending on the nature of the request.
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