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PERSONAL DATA PROCESSING AND PROTECTION POLICY 2022-05-05
EK-SA INS. EMLAK TURZ. VE TİC.LTD.ŞTİ
Clarification Text Regarding the Processing of Personal Data
A. PURPOSE OF PERSONAL DATA PROTECTION AND PROCESSING POLICY:
EK-SA INS. EMLAK TURZ. VE TİC.LTD.ŞTİ. (“Company”), in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”), with this “Information” letter we have prepared as the Data Controller, the 10th and “Related Person's Obligation to Inform the Data Controller” in the KVKK. Within the framework of article 11 titled “Rights of the Republic of Turkey”; We would like to inform you about the purpose for which your personal data will be processed, to whom and for what purpose your processed personal data can be transferred, the method and legal reason for the collection of your personal data, and your other rights listed in Article 11 of the KVKK:
In the capacity of Data Controller, we process, record, transfer, share and store your personal data as explained below and within the limits ordered by official legislation.
Our company reserves the right to update this "Information Text on the Protection of Personal Data" at any time within the framework of the changes that can be made in the current official legislation.
B. COLLECTION, PROCESSING AND PROCESSING PURPOSE OF PERSONAL DATA:
By our company, which operates in the fields specified in detail in the Company's Articles of Association, due to the said activities; Your verbal, written or electronic personal data is collected and processed due to both the regulations of the Tourism and Revenue Administration and other relevant institutions and the contracts we have concluded. Your personal data will be used to provide services related to the activities of our company and to increase the quality of these services, to carry out sales, marketing and other activities of our company, to comply with information storage, reporting and informing obligations. In addition, your personal data may also be used within the scope of studies such as CRM (Customer Relationship Management) applications to be made for sales and marketing activities, as well as increasing the quality of service we offer you.
Your personal data will not be used for purposes other than the above-mentioned purposes without your express consent, and will not be shared or transferred to third parties, except for legal obligations and official institutions/organizations.
Our company, your personal data in question only; KVKK art. In other cases stipulated in 5/f.2, we can use this data with our domestic or foreign affiliates, direct or indirect affiliates and joint ventures, or as required by a legal obligation, in order to provide value-added services, opportunities and opportunities to our customers and to increase the service quality. It can be shared with public institutions or organizations that are authorized to request it, and with the institutions, suppliers, authorized dealers/dealers/business partners with whom we have contracted in accordance with our activities, provided that adequate measures are taken.
Although your personal data may vary depending on the services, products or commercial activities provided by our Company; It can be collected verbally, in writing or electronically through automatic or non-automatic methods, offices, branches, dealers, call center, website, social media channels, mobile applications and similar tools. As long as you benefit from our company's products and services, your personal data can be processed by being created and updated.
In addition, with the intention of using the services of our Company;
a. When you use our call center or website,
b. When you visit our company, our website or our social media channels/media,
c. Your personal data may be processed when you attend trainings, seminars or organizations organized by our company. Your personal data obtained from you with your consent or due to other legal compliance reasons stated in the laws of the Republic of Turkey; (i) Our business units can carry out the necessary work to benefit you from the products and services offered by our company; (ii) Suggesting the products and services offered by our company to you by customizing them according to your tastes, usage habits and needs; (iii) Ensuring the legal and commercial security of our Company and the people who have a business relationship with our Company (Administrative operations for communication carried out by our Company, ensuring the physical security and control of the Company's locations, business partner/customer/supplier (authorized or employees) evaluation processes, legal compliance process, financial affairs, etc.); (iv) To improve the services offered by our company and to improve our quality policy, (v) To be informed about and benefit from the general and special campaigns, promotions, promotions, discounts and similar advantages offered by our company;
(vi) To be able to process the data obtained together with your personal data, preferences, transactions and browsing time in the relevant channels when you log in with your user name and password in order to receive services from the channels offered by our company, in order to provide you with the information and services you have requested; (vii) To make notifications (renewal, expiration, etc.) regarding all kinds of loyalty cards issued and/or to be issued by our Company and its related companies/organizations and website memberships of our Company and its related companies/organizations, and any communication that may be established with you, To inform about new services and products to be offered, changes, innovations and similar issues in personal data policies and membership conditions; (viii) To inform you about the information, events and services you will request from our company; (ix) Determination and implementation of our company's commercial and business strategies; (x) Ensuring the execution of our company's human resources policies and; (xi) Fulfilling a legal obligation determined by the legislation, if it is expressly stated in the legislation or if necessary
Within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVK Law, for the purposes of our Company and its related companies/organizations and other real and/or legal persons specified in Article (C) below.
C. METHOD AND LEGAL REASON FOR COLLECTING PERSONAL DATA:
Your personal data is obtained in all kinds of verbal, written or electronic media, in line with the purposes specified in the above articles, in order to present our products and services as a Company within the determined legal framework, and in this context, for our Company to fully and accurately fulfill its contractual and legal responsibilities. Your personal data collected for this legal reason is processed, recorded, transferred, shared and stored for the purposes specified in article (B) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVK Law.
D. PROCESSING OF SPECIAL DATA:
According to the KVK Law, data related to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric data. and genetic data are special categories of personal data. Our company also takes the necessary precautions determined by the Personal Data Protection Board in the processing of sensitive personal data. In order to provide better service, our company will process the private data of individuals only with the consent of the relevant person and only to serve the purpose of collection.
E. TO WHOM AND FOR WHAT PURPOSES THE PROCESSED PERSONAL DATA MAY BE TRANSFERRED:
Your collected personal data, in order to serve the purposes specified in Article (B), EK-SA
INS. EMLAK TURZ. VE TİC.LTD.ŞTİ and ALWAYS ORGANİZASYON DANIŞMANLIK OTO KİRALAMA TUR. SINGING. A.Ş, as well as our shareholders, business partners, suppliers, legally authorized public institutions and private individuals, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law.
F. TRANSFERRING PERSONAL DATA ABROAD:
Our company has the authority to transfer personal data abroad within the conditions determined by the Personal Data Protection Board in the KVK Law, in accordance with the other conditions in the law and after obtaining the explicit consent of the person for this purpose.
G. RIGHTS OF THE PERSONAL DATA OWNER STATED IN ARTICLE 11 OF THE KVK LAW:
We accept that, within the scope of the KVK Law, the data subject has the right to be informed and approved before the processing, recording, transfer, sharing and storage of his personal data, and that he has the right to determine the fate of the data after the data is processed, recorded, transferred, shared and stored. In this context, if you submit your requests regarding your rights as personal data owners to our Company through the methods set out below in this "Information Text on the Processing of Personal Data", our Company will conclude the request free of charge within thirty days at the latest, depending on the nature of the request.
Pursuant to the Communiqué on Application Procedures and Principles to the Data Controller published by the Personal Data Protection Board, regarding your requests regarding your rights as personal data owners.
I. If your application will be answered in writing, up to ten pages will not be charged. A transaction fee of 1 Turkish Lira may be charged for each page over ten pages.
ii. If the response to the application is given in a recording medium such as a CD or flash memory, the fee that may be requested by our Company as the data controller cannot exceed the cost of the recording medium.
