PDPL Clarification Text
Pursuant to the Personal Data Protection Law no. 6698 (“PDPL”), our Company, in its capacity as the data controller, shall process your personal data for business related purposes and by way of using, recording, storing, updating, transferring and/ or classifying them as described below. In this respect, pursuant to the Laws and Regulations enacted to protect fundamental rights and freedoms of individuals, including the privacy of personal life and to protect personal data, our Company adopts all technical and administrative measures to ensure an adequate security level with the purpose to prevent unlawful process of your personal data, to prevent unlawful access to them and to safeguard them.
We hereby notify you that your personal data below provided by you to us may be processed in any event, and your personal data that we have gathered as follows, as the case may be, under our legal relations:
Within business or commercial relations with you;
Within the purpose that requires their process and in a manner related to that purpose, limited and proportionate manner;
Personal data provided by you shall be recorded, saved, stored, kept, edited by keeping them right and by sharing them with such agencies authorized to demand such personal data and subject to such terms and conditions set out in the Personal Data Protection Law (hereinafter referred to as the “PDPL”), it may be transferred to third parties in Turkey and abroad, classified and may be processed in the ways defined in the PDPL.
Target audience for this statement is our natural person employer customers that have a commercial deal with our Company, their employees and natural person representatives/ employees of our legal person employer customers, natural person suppliers-business partners- outsourcers and legal person suppliers-.business partners-outsourcer natural person representative,
Personal data that we process in our capacity as the data controller are given below provided that they are not exhaustive.
ID data; Name, surname
Contact data; Telephone number, e-mail
Manner of Process of Personal Data and Legal Grounds
We collect your personal data physically or electronically by way of cameras or by sending them to use in physical or environmental media from you and/ or other representatives/ employees in representation of your company/ your employees due to reasons under the applicable laws and for the legitimate interests of the Company and with the intention to perform the contract built on business deals between us and/or you and to perform our legal obligations.
Purpose of processing personal data
Your personal data may be processed by our Company for such reasons and purposes given below, including but not limited to those legal ones and obligations. Your personal data shall be stored for such duration as set out in the applicable legislation you are subject to protect our legitimate interests and as required by our scope of business.
- Drafting quotations under our commercial relation,
- Drafting contracts under our commercial relation,
- Ensuring communication under our commercial relation,
- Issuing invoices under our financial obligations,
- Management of financial affair records,
- Management of payment processes,
- Securing communication in respect to delivery of goods or transportation,
- Designation of address where goods or services are to be delivered/ performed,
- Budget management and reporting,
- Communication between supplier, business partner, outsourcers and customers
- Support from supplier employees,
- Quality control and assessment for the service/ contract performance
Disclosure of Your Personal Data to Third Parties in Turkey And Abroad
Considering your security and with the intention to perform our obligations under applicable laws, your personal data may be shared with such relevant institutions and agencies, Personal Data Protection Agency, Ministry of Finance, Ministry of Customs and Trade, Ministry of Labour and Social Security, Turkish Employment Agency (Is-Kur), Information and Communication Technologies Authority and similar public bodies in line with the entire applicable legislation, including but not limited to, Labour Code, Occupational Health and Job Safety Law, Social Insurance and General Healthcare Insurance Law, the Law on Arrangement of Online Broadcasts and Fight against Crimes committed via those Broadcasts, Turkish Code of Commerce, Personal Data Protection Law no. 6698 and Identity Reporting Law. For instance: Personal data are shared with a tax office for invoicing purposes.
Moreover we can treat your personal data as follows:
- We can send gifts to you to celebrate your special days and congratulate you. In order to send those gifts to you, we can share your personal data with third parties as required for the delivery of our gift to you (company/ platform dispatching gifts, cargo company etc), including your name and surname, address and telephone number.
- We work with third party companies in Turkey and abroad to send bulk SMS and e-mails to you with the intention to alert you about promotions and novelties in the course of our business deals. We can share your personal data required for this purpose only.
- We can share your personal data with forwarding agencies, cargo companies or couriers and similar individuals or entities in order to deliver such items, documents and similar things or products that need to be delivered under our business relation;
- With banks,
- We can transfer your personal data to companies controlling us or audit companies with the intention to audit and report budget management, current card opening, invoicing and similar accounting and financial data;
- In case it is necessary for the relevant program used for the management of accounting and financial transactions, we can process your personal data in line with the purpose of process. Your data may be saved in the data recording media of the application.
- In order to ensure that records containing your personal data are stored during the storage time, we can send related records to third party archiving companies who offer these services.
- Moreover, in order to use our right of defence. We can share your personal data with our attorneys, and provided to be in compliance with the law and procedure, in line our obligation to carry out legal demands such as court orders or evidential request.
Under Article 11 of the PDPL, you have the right to apply to our Company and to ask the following in respect of your personal data:
- To inquire if your data is processed;
- If they are processed, to demand information;
- To inquire about the purpose of process and to learn if they are used in line with the purpose of process;
- To know about 3rd parties in Turkey/ abroad to whom data are transferred;
- To demand that incomplete and/ or misprocessed data are corrected;
- To demand that data shall be deleted/ destroyed in line with terms and conditions set out in Article 7 of the PDPL;
- To ask that transactions done in line with paragraphs 5 and 6 above are to be notified to third parties;
- To object against a result that may arise against you by way of analysis done exclusively via automated systems;
- In case you sustain a loss on account of unlawful processing, to demand that your loss should be compensated.
Pursuant to the first paragraph of Article 13 of the PDPL, your request for using your rights above may be sent to our Company in writing or by way of other methods defined by the Personal Data Protection Law. Your demands in your application shall be finalized at the latest within thirty days based on the nature of your demand. However, in case the transaction requires a further cost for the Company, the Personal Data Protection Committee may charge to the Data Controller such fee as set out in the Communiqué on Application Terms and Procedures.
Additional verifications (sending messages to your registered telephone number, or calling you) may be applied by our Company to determine if the application belongs to you and this way to protect your rights.
You can personally deliver your application letter along with such data necessary to determine your ID for exercising your rights above to our head office at the address of Üçevler Mah. Küçük San. Sit. No:75-76 32.Blok 16120 Nilüfer, Bursa / Turkey, or send it to this address via notary public or by way of other methods defined by the Personal Data Protection Committee or may send an e-mail to our company e-mail address email@example.com