PERSONAL DATA PROCESSING AND PROTECTION POLICY
1- PURPOSE
… As XXX (“COMPANY”, “Company”), residing at the address of …, this Information Text (“Information Text”) has been prepared within the scope of the Personal Data Protection Law No. 6698 in order to fulfill the obligation stipulated by the KVKK, considering the importance we attach to fundamental human rights and the superior value of personal data.
In accordance with the KVKK, as the Data Controller, the COMPANY, as the Data Controller, informs its employees, candidate employees, supplier employees, visitors and third parties whose personal data will be processed as follows and informs them as follows within the scope specified in Article 10 of the KVKK.
2- DEFINITIONS
| Explicit Consent |
It refers to the consent based on information and expressed with free will regarding a specific subject. |
| Company |
… refers to the XXX company located at address. |
| Cookie |
They are small files saved on users' computers or mobile devices that help store preferences and other information on the web pages they visit. |
| Relevant User |
Persons who process personal data within the data controller organization or in accordance with the authorization and instructions received from the data controller, excluding the person or unit responsible for the technical storage, protection and backup of data. |
3- PURPOSES OF PROCESSING YOUR PERSONAL DATA,
PERSONAL DATA WE PROCESS, COLLECTION METHODS AND LEGAL REASONS
i. Purposes of Processing
Your personal data will be used to fulfill the purposes specified in the COMPANY articles of association, in accordance with the limits stipulated in the KVKK and in accordance with the … Law (legislation concerning the data controller). The purposes of processing are as follows;
a. Fulfilling the obligations regarding the activities and auditing stipulated by the … Law,
b. Establishing rights arising from xxx activity within the scope of the … Legislation,
c. Carrying out the necessary work by the relevant units for you to benefit from the services offered by our Company,
ç. Contacting you for the purpose of promoting our Company and its activities through the communication channels you have shared with us,
d. Providing personnel in the areas the company needs, fulfilling rights and obligations within the scope of legislation regulating business life, primarily the Labor Law No. 4857, the Occupational Health and Safety Law No. 6331 and the Social Insurance and General Health Insurance Law No. 5510,
e. Carrying out activities such as paying salaries, providing daily allowances, making revolving fund payments, etc. regarding personnel, making internal correspondence,
f. Providing information and documents to authorized
The KVKK lists the conditions for processing personal data in the second paragraph of its 5th article. If the purposes for which personal data is processed by a data controller can be assessed within the framework of the personal data processing conditions listed in the KVKK, that data controller can process personal data in accordance with the law. In this context, in cases where the purposes for processing personal data pursued by the Company can be assessed within the scope of the personal data processing conditions regulated in the KVKK, the Company carries out personal data processing activities. The Company does not engage in any personal data processing activities that do not fall within the scope of the personal data processing conditions.
The personal data processing conditions included in the KVKK are as follows; (When writing the data processing conditions in the disclosure text, the conditions appropriate to the data controller's processing processes should be determined and these conditions should be indicated in the text.)
The explicit consent of the relevant person,
It is clearly provided for in the laws,
It is mandatory for the protection of the life or physical integrity of the person who is unable to express his/her consent due to a de facto impossibility or whose consent is not legally valid, or of another person,
It is necessary to process personal data belonging to the parties to the contract, provided that it is directly related to the establishment or performance of a contract,
It is mandatory for the data controller to fulfill its legal obligation,
It is made public by the data owner himself/herself,
Data processing is mandatory for the establishment, exercise or protection of a right,
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 data owner.
The basic processing condition for special personal data is also explicit consent, and the Company does not fundamentally aim to process special personal data. However, your special personal data that we need to process due to our activities or that you have given your explicit consent to are also processed within the framework of the legislation in a measured manner.
The conditions listed in the KVKK for the processing of special personal data are as follows;
The explicit consent of the relevant person.
It is necessary for the protection of the life or physical integrity of the person who is unable to give his/her consent due to a physical impossibility or whose consent is not recognized as legally valid, or of another person,
It is related to the personal data made public by the relevant person and is in accordance with the will to make it public,
It is necessary for the establishment, exercise or protection of a right,
It is necessary for the protection of public health, preventive medicine, medical diagnosis, treatment and care services and the planning, management and financing of health services by persons or authorized institutions and organizations under the obligation of confidentiality,
It is necessary for the fulfillment of legal obligations in employment, occupational health and safety, social security, social services and social assistance,
It is necessary for the foundations, associations and other non-profit organizations or formations established for political, philosophical, religious or union purposes to comply with the legislation and purposes to which they are subject, to be limited to their fields of activity and not to be disclosed to third parties provided that; it is directed to current or former members and affiliates or persons who are in regular contact with these organizations and formations
(This section should be written as shown above for the date 01.06.2024 and later; and as follows for the period before this date.)
The explicit consent of the relevant person is present,
It is clearly provided for in the laws for special personal data other than health and sexual life,
Personal data related to health and sexual life can only be processed for the following purposes:
Protection of public health,
Preventive medicine,
Medical diagnosis,
Carrying out treatment and care services,
Planning and management of health services and their financing,
Persons or authorized institutions and organizations under the obligation of confidentiality may process the explicit consent of the relevant person without seeking the explicit consent of the relevant person.
One or more personal data processing conditions that make a personal data processing activity lawful may exist at the same time.
In order to achieve our purposes, the data we have specified above must be processed. While identity information is being transferred to our company, data that is not actually within the scope of our processing purposes may also be transferred to us. Within the scope of administrative and technical measures, we delete and/or anonymize the data in question at the end of the periods stipulated in the legislation.
4- TRANSFER OF PERSONAL DATA
Your personal data is shared with authorized public institutions and organizations, judicial authorities, enforcement authorities, security units and suppliers from whom contracted products and or services are purchased for the purposes and through the means specified in this Information Text. The table showing the parties with whom sharing is made is as follows:
| SHARED PARTIES |
SHARING EXAMPLES |
| Legally Authorized Public/Private Institution or Organization |
Data can be shared with official institutions and organizations such as the Ministry of Treasury and Finance, Internal Audit Coordination Board, Court of Accounts, Judiciary and Execution authorities, other public and foundation companies, companies located abroad for international programs, and notaries. |
| Supplier/Business Partner/Consultant |
Data can be shared with consultants, organizations and parties from whom the company receives services complementary to its activities and cooperates, limited to the purposes of the activities they carry out. These companies with which sharing is made are shown below. |
| Transferred Parties |
Transferred Data Types |
| (Detailed information can be entered in this section, taking into account the conditions of the concrete case, in line with the needs and demands of the data controller.) |
The company does not transfer any data that does not concern its purposes. For example; even if we obtain your consent, information about your vehicle license plate is not shared with any 3rd party, including the persons and institutions shown above. The exception to this determination is if the transfer of the data in question is made mandatory by legislation, or if it is mandatory for a criminal investigation, or if it is requested by an official authority based on legislation and with a justification.
5-RIGHTS OF THE RELATED PERSON
Within the scope of KVKK
i. To learn whether your Personal Data has been processed,
ii. To request information about your Personal Data if it has been processed,
iii. To learn the purpose of processing your Personal Data and whether it is used in accordance with its purpose,
iv. To know the third parties to whom your Personal Data has been transferred domestically or abroad,
v. To request correction of your Personal Data if it has been processed incompletely or incorrectly,
vi. To request the deletion or destruction of your Personal Data within the framework of the conditions stipulated in the KVKK legislation,
vii. To request notification of the transactions made within the scope of articles v. and vi. to the third parties to whom your Personal Data has been transferred,
viii. You have the right to object to the emergence of a result against you by exclusively analyzing the processed data through automated systems,
ix. If you suffer damage due to the unlawful processing of your Personal Data, you have the right to request compensation for this damage.
How Can You Exercise Your Rights?
You can download the “application form” using the link http://xxx/bilgiformu and fill it out in accordance with your request/complaint, and send the form to us at kvkk.xxx@xxx.com or you can physically fill out the form and send it to “…” via cargo/mail.
If you submit your request to us using one of the methods shown above, your request will be evaluated within 30 days at the latest in accordance with Article 13/2 of the KVKK and you will be informed about the subject. If your request is accepted, the necessary procedures will be carried out immediately by the data controller COMPANY.
As a rule, requests are met free of charge, however, if fulfilling the request requires a cost, the COMPANY may request a fee in accordance with the provision in Article 7 of the “Communiqué on the Procedures and Principles of Application to the Data Controller”; “If the application of the relevant person is to be responded to in writing, no fee will be charged for up to 10 pages. A processing fee of 1 TL may be charged for each page over 10 pages. If the response to the application is given on a recording medium such as CD or flash memory, the fee that may be requested by the data controller shall not exceed the cost of the recording medium.”
6- DATA CONTROLLER AND CONTACT PERSON
As stated in this Information Text, the COMPANY is the data controller in accordance with the KVKK.
i. Data Controller Information
Full Name: XXX
Short Name: COMPANY
Address: XXXX
İ. Website : https://www.xxx.tr/tr
ii. Contact Person
Name: :
Surname :
Title :
E-mail :
Phone :
7- CHANGE
i. Change 1 : No changes have been made to the document yet.
Change Details :
