DISCLOSURE STATEMENT
As a data controller located at [Bostancı Mahallesi Yazmacı Tahir Sk. No:49/3 Kadıköy İstanbul], this Privacy Notice aims to fulfill our obligation to inform you under the Personal Data Protection Law (“Law”).
The matters we are obliged to inform you about under the obligation to inform are as follows:
Processing of Your Personal Data
Processing of personal data means any operation or set of operations performed on personal data, such as collection, recording, storage, preservation, modification, reorganization, disclosure, transfer, assumption, making available, classification, or prevention of use, whether or not by automated means or as part of a data recording system, whether or not fully or partially automated.
Data Controller and Representative
In accordance with the Law, your personal data may be processed by the Company as the data controller within the scope explained in this notice. The Company is responsible for determining the purposes and means of processing the personal data recorded in its database and for establishing and managing the data recording system.
Reasons for Processing Your Data
Your personal data is processed by the Company for the purposes of ensuring that products and services can be provided to you, carrying out necessary operational activities within the Company, taking necessary steps for the Company to make, implement, and carry out commercial decisions, ensuring the legal security of the natural persons with whom we establish business relationships and the Company’s legal security arising from these relationships, and, without limitation, for similar purposes in accordance with Articles 5 and 6 of the Law.
Your Personal Data may be processed by the Company in its capacity as the Data Controller in the following cases without requiring your explicit consent:
- a) When expressly provided by laws;
- b) When it is mandatory for the protection of the life or physical integrity of the data subject or another person, and the data subject is unable to express their consent due to physical or legal impossibility or is not subject to legal validity of consent.
- c) When processing the personal data of the parties to the contract is necessary, provided that it is directly related to the performance of the contract.
ç) When it is mandatory for us to fulfill our legal obligations as the data controller;
- d) When the data subject has made the data public.
- e) When processing is mandatory for the establishment, exercise, or protection of a right
- f) When 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 subject, it may be used for the purposes specified below based on any of the conditions.
To Whom and for What Purpose the Processed Personal Data May Be Transferred
Your collected personal data may be transferred to our business partners, suppliers, shareholders, legally authorized public institutions, and private individuals for the purposes of ensuring the legal and commercial security of the Company and the persons with whom the Company has a business relationship; enabling our business units to carry out the necessary work to allow you to benefit from the products and services offered by the Company; customizing and recommending the products and services offered by the Company according to your preferences, usage habits, and needs; determining and implementing the Company’s commercial and business strategies; and ensuring the implementation of the Company’s human resources policies, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Personal Data Protection Law.
Method and Legal Basis for Collecting Personal Data
Your personal data is collected by the Company through various channels and based on different legal grounds for the purpose of carrying out our commercial activities. Your personal data collected for this legal reason may also be processed and transferred for the purposes specified in paragraphs (b) and (c) of this notice within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law.
Rights of the Data Subject under Article 11 of the Personal Data Protection Law
As data subjects, if you submit your requests regarding your rights to the Company using the methods set out below in this Privacy Notice, the Company will complete the request as soon as possible and no later than thirty days, free of charge, depending on the nature of the request. However, if the Personal Data Protection Board prescribes a fee, the fee determined by the Company in the tariff will be charged. In this context, data subjects have the right to learn whether their personal data is being processed, request information about the processing of their personal data if it has been processed, learn the purpose of the processing of personal data and whether it is being used in accordance with that purpose, learn the third parties to whom personal data is transferred domestically or abroad, request the correction of incomplete or inaccurate processing of personal data and request that the action taken be notified to the third parties to whom the personal data was transferred, request the deletion or destruction of personal data when the reasons requiring its processing no longer exist, even though it has been processed in accordance with the Personal Data Protection Law and other relevant legal provisions, and request that the action taken be notified to the third parties to whom the personal data was transferred, object to a result produced against the data subject solely through the analysis of processed data by automated systems, and request compensation for damages suffered due to the unlawful processing of personal data.
In accordance with paragraph 1 of Article 13 of the Personal Data Protection Law, you may submit your request to exercise the rights specified above to the Company in writing or through other methods determined by the Personal Data Protection Board. Since the Personal Data Protection Board has not determined any method at this stage, you must submit your application to the Company in writing in accordance with the Personal Data Protection Law. In this context, the channels and procedures for submitting your applications to the Company under Article 11 of the Personal Data Protection Law are explained below.
You may submit these rights in writing or through registered electronic mail (KEP) (the KEP address is [•]), secure electronic signature, mobile signature, or the email address previously notified to the Company and registered in the Company’s system (In this context, you can reach the Company via the [•] email address) or through software or an application developed for the purpose of the application.