LETTER OF INFORMATION CONCERNING PROTECTION AND PROCESSING OF PERSONAL DATA

TEKPAN TEKNİK ELK. KUMANDA PANO SAN. VE TURİZM TİC. A.Ş

LETTER OF INFORMATION CONCERNING

PROTECTION AND PROCESSING OF PERSONAL DATA

A. PURPOSE OF THE PROTECTION AND PROCESSING OF PERSONAL DATA POLICY

We, Tekpan Teknik Elk. Kumanda Pano San. Ve Turizm Tic. A.Ş. (“Company”) Would Like To Provide You With Information Concerning For What Purpose Personal Data Will Be Processed, To Whom Such Processed Personal Data May Be Transmitted And For What Purpose, Method And Legal Reason Of Collecting Personal Data And Your Other Rights As Provided For In The Article 11 Of The Protection Of Personal Data Act No. 6698 (“PDPA”) Under The Article 10 Entitled “Clarification Obligation Of Data Controller” And The Article 11 Entitled “Right Of The Relevant Person” Of PDPA By This “Letter Of Information” In Our Capacity As The Data Controller As Per PDPA:

In Our Capacity As The Data Controller, We Process, Record, Transmit, Share And Store Your Personal Data In The Manner We Describe Below And Within The Framework Of The Limits As Stipulated By The Regulations.

Our Company Reserves Its Right To Update This Letter Of Information Concerning The Protection Of Personal Data” At Any Time Within The Framework Of Any Modifications That May Be Made In The Formal Regulations In Effect.

B. COLLECTION AND PROCESSING OF PERSONAL DATA AND PURPOSES OF PROCESSING THEM:

Your Personal Data Are Collected And Processed By Verbal, Written And Electronic Methods Due To The Activities Of Our Company Which Operates In The Areas As Specified In Detail In The Articles Of Incorporation Of The Company Or Any Contracts Executed By Our Company. Your Personal Data Will Be Used To Be Able To Provide You With The Services Related To The Subjects Of Activity Of Our Company And Improve The Quality Of Such Services, To Perform The Sales, Marketing And Other Operations Of Our Company And To Comply With Our Obligations Of Data Storage, Reporting And Clarification. Further, Your Personal Data May Also Be Used Within The Scope Of The Works To Be Performed For The Improvement Of The Quality Of Services We Provide You With As Well As For Our Sales And Marketing Operations. 

Your Personal Data Will Not Be Used For Any Purposes Other Than Those Mentioned Above Except With Your Explicit Consent Nor Shared With Or Transmitted To Any Third Parties Except In Case Of Legal Obligations And With Governmental Organisations And Institutions.

Our Company May Only Be Shared With Our Affiliates At Home Or Abroad And With Our Directly Or Indirectly Related Subsidiaries And Joint Ventures Or Any Public Organisations And Institutions Authorised To Claim Such Data Due To Any Legal Obligations And, Provided That Any Sufficient Measures Are Taken, With Any Organisations, Suppliers, Authorised Resellers/dealers/business Partners With Which We Are Bound By Contracts As Required By Our Operations  at Home Or Abroad In Order To Provide Our Customers With Value-added Services, Opportunities And Means Upon The Explicit Consent Of Our Customers Or In Cases As Stipulated In The Regulations By Which We Are Bound And In Any Other Cases As Stipulated In The Subparagraph (2) Of The Paragraph (f) Of The Article 5 Of PDPA.

While Your Personal Data May Vary On The Basis Of The Services, Products Or Commercial Activities Of Our Company, They May Also Be Collected By Verbal, Written Or Electronic Ways Via Such Means As Automatic Or Non-automatic Methods, Offices, Branch Offices, Dealers, Call Centre, Website, Social Media Channels, Mobile Applications And The Like. As Long As You Make Use Of The Products And Services Of Our Company, Your Personal Data May Be Processed By Establishing And Updating The Same.

Moreover, Your Personal Data May Be Processed, In Order To Use The Service Of Our Company

  1. whenever You Call Our Call Centre Or Log In To Our Website;
  2. whenever You Visit Our Company, Website Or Social Media Channels;
  3. whenever You Attend Any Trainings, Seminars Or Organisations As Held By Our Company.

 

Your Personal Data Which We Have Obtained From You Upon Your Consent Or Which Have Been Obtained As A Requirements Of Legal Compliance Reasons As Stipulated In The Laws Of The Republic Of Turkey May Be Processed By Our Company And Its Related Companies/corporations As Well As By Any Other Natural Persons And/or Legal Entities As Designated In The Section (C) Below So That

(i) Our Business Units May Perform Any Works Required To Enable You To Make Use Of Any Services And Products Provided By Our Company;

(ii) Any Products And Services Offered By Our Company May Be Proposed To You By Customising The Same In Accordance With Your Liking, Habits Of Use And Requirements;

(iii) Legal And Commercial Security Of Our Company And All Parties Who Have Business Relations With Our Company May Be Insured (administrative Operations Implemented For Communication By Our Company, Provision Of Physical Security And Control Of The Locations As Owned By Our Company, Assessment Processes Of Business Partners/customers/suppliers (authorised Personnel Or Employees Thereof), Legal Adaptation Period, Financial Affairs, Etc.);

(iv) Services Offered By Our Company May Be Made Better Quality And Our Quality Policy May Be Improved;

(v) You May Be Made Aware Of And Make Use Of Any General And Special Campaigns, Promotions, Launching, Reductions And Other Similar Advantages Offered By Our Company;

(vi) Data Obtained About Your Personal Data, Preferences, Transactions And Browsing Time In Any Relevant Media May Be Processed In Order To Be Able To Provide You With Any Information And Services You Require Whenever You Log In Using Your User Name And Password In Order To Receive Services Rom The Mdia Offered By Our Company;

(vii) We Will Be Able To Provide You With Notices Related To Any Loyalty Cards Issued And/or To Be Issued By Our Company And Its Related Companies/corporations As Well As The Website Memberships To Our Company And Its Related Companies/corporations (renewal, Expiry, Etc.), And So That We May Provide You With Information About Any Communication Which May Be Established With You, Any Services And Products To Be Launched Recently And Any Modifications, Innovations, Etc. Which May Occur In Our Personal Data Policies And Membership Conditions;

(viii) We May Provide You With Information About Any Information, Events And Services Which You Will Require From Our Company;

(ix) We May Identify And Implement Commercial And Business Strategies Of Our Company;

(x) We May Ensure The Implementation Of Human Resources Policy Of Our Company; And

(xi) In Case It Is Expressly Stipulated In The Regulations Or In Order To Fulfil Any Legal Obligations As Stipulated By The Regulations If Necessary, Under The Personal Data Processing Conditions And Purposes As Stipulated In The Article 5 And 6 Of PDP Act.

C. METHOD AND LEGAL REASON OF THE COLLECTION OF PERSONAL DATA: 

Our Personal Data Are Obtained So That Any Products And Services Offered By Our Company May Be Offered Within The Identified Legal Framework And So That, In This Context, Our Company May Be Able To Fulfil Its Contractual And Legal Obligations In A Complete And Correct Manner In Order To Maintain Our Operations And On The Basis Of Compliance With The Regulations As Well As With The Company Policies.

Your Personal Data Collected As Per The Legal Reasons As Described Above Are Processed, Recorded, Transmitted, Shared And Stored For The Purposes As Specified In Detail In The Section (B) Of This Letter Of Information Within The Scope Of The Personal Data Processing Conditions And Purposes As Stipulated In The Article 5 Entitled “Processing Conditions Of Personal Data” And The Article 6 Entitled “Processing Conditions Of Personal Data Of Special Nature” Of The Protection Of Personal Data Act.

D. PROCESSING OF DATA OF SPECIAL NATURE: 

As Per The PDP Act, Such Data As Those Concerning Race, Ethnic Origin, Political Opinion, Religion, Creed Or Other Faiths, Raiment, Membership To Associations, Foundations Or Labour Unions, Health, Sexual Life, Criminal Conviction And Safety Measures As Well As Biometric And Genetic Data Of People Are Personal Data Of Special Nature. Our Company Further Takes Any Measures Identified By The Protection Of Personal Data Committee At The Sufficient Level In The Processing Of The Personal Data Of Special Nature. Our Company Will Only Process Data Of Special Nature Of People By Obtaining The Consent Of The Relevant Person And Only To Serve The Purpose Of Collection Thereof So That It May Provide Better Services.

E. TO WHOM PROCESSED PERSONAL DATA MAY BE TRANSMITTED AND FOR WHAT PURPOSE:

Your Personal Data So Collected May Be Transmitted To Our Company Tekpan Teknik Elk. Kumanda Pano San. Ve Tur. Tic. A.Ş. As Well As To Our Shareholders, Business Partners, Suppliers, Legally Authorised Public Organisations And Private Persons Within The Framework Of The Personal Data Processing Conditions And Purposes As Stipulated In The Article 8 And 9 Of The PDP Act So Hat They Will Serve The Purposes As Contained In The Section (B) Hereof.

F. TRANSMISSION OF PERSONAL DATA ABROAD: 

Our Company Is Entitled To Transmit Any Personal Data Abroad Under The Conditions As Stipulated In The PDP Act By The Protection Of Personal Data Committee In Accordance With Any Other Terms And Conditions In The Act And By Obtaining Explicit Consent Of The Person For This Purpose.

G. RIGHTS OF THE PERSONAL DATA OWNER AS LISTED IN THE ARTICLE 11 OF THE PDP ACT: 

We Agree That Under The PDP Act The Relevant Person Is Entitled To Be Provided With Information And Give His Consent Before The Processing, Recording, Transmission, Sharing And Storage Of His Personal Data And That He Is Entitled To Determine The Fate Of Such Data After The Processing, Recording, Transmission, Sharing And Storage Thereof. 

In This Context, In The Event That You Notify Our Company Of Your Requests About Your Rights As Personal Data Owners By The Methods As Listed Below In This “Letter Of Information Concerning The Processing Of Personal Data”, Our Company Will Conclude Such Request On Free Of Charge Basis Not Later Than Thirty Days, Depending On The Nature Of The Request.

As Per The Communiqué Concerning The Filing Applications With Data Controller Published By The Personal Data Protection Committee,

  1. No Costs Are Charged Up To Ten Pages If Your Application Will Be Replied In Writing. A Transaction Fee Of TRL 1,00 May Be Charged Per Page Exceeding Ten Pages. 
  2. In Case The Application Is Replied In A Storage Medium Such As A CD, Memory Stick, Etc., Then Any Fees Which May Be Charged By Our Company, In Its Capacity As The Data Controller, May Not By Any Means Exceed The Cost Of The Storage Medium.

In This Context, Data Owners Are Entitled To

  1. learning Whether Or Not Their Personal Data Have Been Processed;
  2. if Their Personal Data Have Been Processed, Requiring Information Concerning This Fact;
  3. learning The Purpose Of Processing Their Personal Data And Whether Or Not They Are Used To The Purpose;
  4. knowing Any Third Parties To Whom Their Personal Data Have Been Transmitted At Home And Abroad;
  5. in Case Their Personal Data Have Been Shortly Or Incorrectly Processed, Requiring The Same To Be Corrected And Any Third Parties To Whom Such Data Have Been Transmitted To Be Notified Of The Procedure Carried Out In This Context;
  6. requiring Their Personal Data To Be Deleted Or Destroyed Under The Terms And Conditions As Stipulated In The Article 7 Of The Act And Any Third Parties To Whom Such Data Have Been Transmitted To Be Notified Of The Procedure Carried Out In This Context;
  7. raising An Objection To Any Adverse Outcome Occurring Against The Person By Analysing The Processed Data Solely Via Automated Systems;
  8. in Case They Incur Any Loses Due To The Fact That Personal Data Are Illegally Processed, Claiming Their Loss To Be Remedied. 

In Any Event, People Would Not Have Any Other Rights Concerning The Data Anonymized In The Company. Our Company May Share Any Personal Data With Any Competent Organisations And Institutions As Per Any Business Or Contractual Relationship So That They May Be Used For Any Judicial Duty Or For Any Governmental Authority To Exercise Its Legal Powers.

H. PERIODS DURING WHICH YOUR PESONAL DATA MAY BE PROCESSED: 

The Company Stores Personal Data For Any Period Of Time As Stipulated In The Relevant Regulations Or For Any Period Of Time As Required For The Purpose For Which They Are Processed. In This Context, The Company First Determines Whether Or Not Any Time Is Prescribed For The Storage Of Personal Data In The Relevant Regulations. If Any Period Is Prescribed In The Regulations, It Complies With Such Period. If No Period Is Prescribed, Then It Stores The Personal Data For The Period Of Time As Required For The Purpose For Which They Are Processed. In Accordance With The PDP Act, Your Personal Data Processed For The Purpose As Provided In This “Letter Of Information Concerning The Processing And Protection Of Personal Data” Will Be Deleted, Destroyed And Kept Being Used By Anonymization By Us When The Purpose Requiring Processing As Per The First Subparagraph Of The Paragraph (f) Of The Article 7 Of The PDP Act Ceases To Exist And/or When Any Prescription Periods During Which We Are Required To Process Your Data As Per The Regulations. Personal Data Are Not Stored By The Company For The Possibility Of Using The Same In The Future.

 

I. CASES IN WHICH OUR COMPANY MAY PROCESS YOUR PERSONAL DATA WITHOUT YOUR EXPLICIT CONSENT AS PER LAWS:

As Per The Article 5 Of PDPA, Our Company May Process Your Personal Data As Identified Above Which It Has Legally Acquired Without Requiring Your Explicit Consent In The Following Cases:

  1. Cases As Clearly Stipulated By Laws;
  2. Cases Where You Are Unable To Give Your Consent As The Data Owner Due To Physical Incapacity Or Where Your Consent Is Not Legally Validated And Where It Is Mandatory To Process Your Personal Data In Order To Protect Your Or Anyone Else’s Life Or Physical Integrity; 
  3. Cases Where Personal Data Of The Contractual Parties Should Be Processed, Provided That They Are Directly Related To The Execution Or Performance Of Any Contracts With Any Other Natural Persons And/or Legal Entities Identified In The Section (C) Hereof By Our Company And Its Related Companies/corporations;
  4. Cases Where It Is Required For Our Company To Be Able To Fulfil Any Of Its Legal Obligations;
  5. Cases Where Your Personal Data Have Been Made Public By Yourselves;
  6. Cases Where It Is Necessary To Process Personal Data In Order To Create, Exercise Or Protect Any Right;
  7. Provided That It Will Not Prejudice Any Basic Rights And Freedoms Which You Have;
  8. Cases Where Data Processing Is Necessary For The Legitimate Interests Of Our Company.

J. TO FILE ANY REQUESTS AS PER THE PROTECTION OF PERSONAL DATA ACT:

As Per The First Paragraph Of The Article 13 Of The PDP Act, You May Communicate Your Request Related To The Exercise Of Your Rights As Mentioned Above By Any Method(s) To Be Identified By The Protection Of Personal Data Committee.

As Per The PDP Act, You May Further Communicate Your Requests For Detailed Information And Claims In Writing By Completing The Form As Contained In our Website for Your Requests Concerning Your Rights As Personal Data Owners.

In Order To Exercise Your Rights As Contained In The Article 11 Of The Act No. 6698, You Can Contact Us By Sending An E-mail To info@tekpan.com.tr at All Times.

The E-mail Address At info@tekpan.com.tr must Only Be Used On Any Matters Concerning Your Personal Data And Any Requests And Notices Arriving Via Any Channels Other Than This E-mail Address Will Not Be Taken Into Consideration.

Rights Related To Personal Data May Only Be Exercised For The Data Belonging To The People’s Own. Any Requests Related To Any People Other Than The Person Who Completes The Form And Who Attaches Official Documents Evidencing His Identity Will Not Be Taken Into Consideration.

Any Forms Not Accompanied By Any Documents Evidencing Your Identity Will Not Be Taken Into Consideration. We Would Like You To Know That Even When The Requests For Data Deletion Are Satisfied, We Are Obliged To Share Such Data With Public Authorities If So Required By Such Public Authorities..

 

                                                                                    TEKPAN TEKNİK ELK. KUMANDA PANO SAN. VE TUR. TİC. A.Ş.