KVKK

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ.

Personal Data Processing and Protection Policy

Purpose and Scope of the Policy

Personal Data Protection Law No. 6698, following the recognition of the protection of personal data as a constitutional right in 2010, came into force in 2016. It is a legal safeguard developed to preserve the principle of privacy of private life during the processing of personal data and to prevent harm to fundamental rights and freedoms, setting out the procedures and principles on this matter.

Pursuant to Article 16 of Law No. 6698 ("KVKK" or "the Law"), data controllers who are obliged to register with the Data Controllers' Registry have an obligation to prepare a personal data protection and processing policy in accordance with their personal data processing inventory.

This Personal Data Protection and Processing Policy ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. concerning the protection and processing of personal data that we hold in our capacity as data controller, in accordance with Law No. 6698 and other relevant legislation ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. has been prepared for the purpose of determining the procedures and principles to be applied.

 

DEFINITIONS

Registry; It is the registry of data controllers maintained by the Personal Data Protection Authority.

Explicit Consent; consent given based on information and disclosed with free will regarding a specific matter. Personal Data: any information relating to an identified or identifiable natural person. Processing of Personal Data: any operation carried out on data, such as obtaining, recording, storing, retaining, altering, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, whether wholly or partly by automated means or by non-automated means provided that it forms part of any data recording system. Destruction: the deletion, erasure or anonymisation of personal data. Deletion of personal data is the process of rendering the data completely unusable. Erasure of personal data is the process of rendering the data inaccessible, unrecoverable and reusable by no one in any way.

The data recording system is a recording system in which personal data is processed structured according to specific criteria.

 

Subjects Defined by the Personal Data Protection Law and Regulation

 

Data controller, is the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

Relevant User, are the persons who process personal data within the data controller's organisation or in line with the authority and instructions received from the data controller, excluding the person or unit responsible for the technical storage, protection and backup of the data.

Target Group, it is the category of natural or legal persons to whom personal data is transferred by the data controller.

Data subject, is the natural person whose personal data is processed.

Inventory, It is an inventory in which data controllers detail the personal data processing activities they carry out depending on their business processes -- by associating them with the purposes and legal grounds of personal data processing, the data category, the recipient group to which data is transferred, and the group of data subjects -- and explain the maximum retention period necessary for the purposes for which the personal data are processed, the personal data foreseen to be transferred to foreign countries, and the measures taken regarding data security.

The reason for imposing the obligation to prepare an inventory; Ensuring compliance with the Law in all processes connected to data controllers' activities, in other words enabling the easy detection of whether there is any unlawful personal data processing under the Law. Put differently, it is a kind of self-audit by the data controller regarding the compliance of personal data processing activities with the Law.

 

Regulation on the Deletion, Destruction or Anonymisation of Personal Data

 

ARTICLE 5 – (1) Pursuant to Article 16 of the Law, data controllers who are obliged to register with the Data Controllers' Registry are required to prepare a personal data retention and destruction policy in accordance with their personal data processing inventory.

According to the Regulation on the Registry of Data Controllers ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. at minimum in inventory, as follows;

 

• Data category,
• The purposes and legal grounds for processing personal data,
• Recipient / recipient groups to whom data is transferred,
• Categories of data subjects,
• The maximum retention period necessary for the purposes for which the personal data is processed,
• Personal data intended for transfer to foreign countries,
• The technical and administrative measures taken for data security are included.

 

CONDITIONS FOR PROCESSING PERSONAL DATA

 

The processing of personal data is defined in Article 3 of the Law. Accordingly, as the data controller, ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. we consider the processing of personal data to be any operation carried out on data, such as obtaining, recording, storing, retaining, altering, rearranging, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data, whether wholly or partly by automated means or by non-automated means provided that it forms part of any data recording system.

The conditions for processing personal data are set out in Article 5 of the Law, and accordingly we lawfully process personal data when at least one of the following circumstances applies.

• The presence of the explicit consent of the data subject,
• Being expressly provided for by law,
• Where it is necessary for the protection of the life or bodily integrity of the person themselves or of another, in cases where the person is unable to give consent due to actual impossibility or whose consent is not deemed legally valid,
• Where the processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of that contract,
• Being mandatory for the data controller to fulfil its legal obligation,
• Having been made public by the data subject themselves,
• Data processing being mandatory for the establishment, exercise or protection of a right,
• Provided that no harm is caused to the data subject's fundamental rights and freedoms, the processing of data may be necessary for the legitimate interests of the data controller. The conditions for processing personal data, that is, the grounds of lawfulness, are set out exhaustively in the Law and cannot be extended.
• In our capacity as data controller ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. we process data by fulfilling the conditions listed above.

 

I. EXPLICIT CONSENT

As the data controller ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. in carrying out a data processing activity, we first assess whether it can rely on one of the other data processing conditions, and if none of these apply, we resort to obtaining the explicit consent of the data subject.

 

II. BEING EXPRESSLY STIPULATED BY LAW

One of the conditions for data processing is that it is expressly foreseen by law. A provision in laws stating that personal data may be processed will constitute a data processing condition. For example, keeping personnel files of employees as required by the relevant legislation; taking suspects' fingerprints pursuant to Article 5 of the Police Duties and Powers Law No. 2559 (PVSK) due to a criminal investigation by law enforcement; and the processing by the Ministry of Justice of data relating to individuals' criminal convictions pursuant to the Criminal Records Law No. 5352 fall within this scope.

 

III. ACTUAL IMPOSSIBILITY

Where it is necessary for the protection of the life or bodily integrity of the person themselves or of another, in cases where the person is unable to give consent due to actual impossibility or whose consent is not deemed legally valid, the personal data of the data subject may be processed.

 

IV. BEING NECESSARY FOR THE ESTABLISHMENT AND PERFORMANCE OF A CONTRACT

Provided that it is directly related to the establishment or performance of a contract, where processing the personal data of the parties to the contract is necessary, the personal data of the data subjects may be processed limited to this purpose.

 

V. BEING MANDATORY FOR THE DATA CONTROLLER TO FULFIL ITS LEGAL OBLIGATION

The personal data of the data subject may be processed where processing is mandatory for the data controller to fulfil its legal obligation.

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. the obtaining and processing of data such as an employee's bank account number, dependants, whether their spouse is employed, and social security number in order to pay employees' salaries can be given as an example of this situation.

As an employer, submitting information belonging to my employees or patients for the review of the relevant public officials during a tax audit may also be considered within this scope.

 

VI. PERSONAL DATA HAVING BEEN MADE PUBLIC BY THE DATA SUBJECT

Personal data that has been made public by the person themselves -- in other words, disclosed to the public in any way -- may be processed. An example of this would be a person publicly announcing their contact details so that they can be contacted in certain circumstances. Disclosure can also be said to occur when employees' workplace phone numbers and corporate e-mail addresses are shared openly for third-party access on corporate websites. However, for personal data to be considered public, the person to whom it belongs must want it to be public. In other words, for disclosure to take place, an intention to make it public must exist.

In principle, these grounds do not treat a person's personal data being in a place visible to everyone as making it public; rather, they accept that the person has made the data they shared public only for that purpose.

 

VII. PROCESSING OF PERSONAL DATA BEING MANDATORY FOR THE ESTABLISHMENT OR EXERCISE OF A RIGHT

The personal data of the data subject may be processed where it is mandatory for the establishment, exercise, or protection of a right.

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. the retention of documents such as invoices, contracts and letters of guarantee for these purposes until the end of the statute of limitations against possible legal proceedings, after the contracts we have concluded have ended, shall be assessed within this scope.

 

VIII. WHERE 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

Personal data may be processed where processing is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

In some cases, data processing may take place on the grounds of the data controller's legitimate interest. For example, processing our employees' personal data -- provided it does not harm their fundamental rights and freedoms -- in order to arrange their promotions, salary increases or social benefits, or to be used as a basis for the distribution of duties and roles during the restructuring of the business, is considered within the scope of the data controller's legitimate interest.

 

 

 

FUNDAMENTAL PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA

 

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. the following fundamental principles are adopted in order to ensure and maintain compliance with personal data protection legislation:

There are fundamental principles relating to the processing of personal data that are recognised in international instruments and reflected in the practice of many countries. In Article 4 of the Law, the procedures and principles relating to the processing of personal data are regulated in parallel with Convention No. 108 and European Union Directive 95/46/EC.

Accordingly, the general (fundamental) principles listed in the Law for processing personal data are as follows:

• Compliance with the law and the rules of good faith,
• Being accurate and, where necessary, kept up to date,
• Being processed for specific, explicit and legitimate purposes,
• Being relevant, limited and proportionate to the purpose for which they are processed,
• Being retained only for the period stipulated in the relevant legislation or required for the purpose for which they are processed. The principles relating to the processing of personal data must lie at the heart of all personal data processing activities, and all such activities must be carried out in accordance with these principles.

 

A) The Principle of Compliance with the Law and the Rules of Good Faith

 

Compliance with the law and the principle of good faith refers to the obligation to act in accordance with the principles established by laws and other legal regulations in the processing of personal data.

In our capacity as data controller, in accordance with the principle of compliance with the rule of good faith, ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİIn striving to achieve our goals in data processing, we always take into account the interests and reasonable expectations of the data subjects. As a principle, we also act in a way that prevents outcomes the data subject would not expect and should not have to expect. In accordance with the said principle, we also aim for the data processing activity in question to be transparent for the data subject and, in our capacity as data controller, ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. we always act in accordance with the obligations to inform and warn.

 

B) Principle of Being Accurate and Up to Date When Necessary 

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. we are aware that we bear an active duty of care to ensure that personal data is accurate and, where necessary, up to date. Accordingly, we always keep open the channels that will ensure the data subject's information is accurate and up to date.

 

C) The Principle of Being Processed for Specific, Explicit and Legitimate Purposes

• The principle that the purposes of processing personal data must be specific, legitimate and explicit;
• That personal data processing activities are clearly understandable by the data subject,
• Determining on which legal processing condition personal data processing activities are based,
• It ensures that the personal data processing activity and the purpose for which it is carried out are set out in sufficient detail to establish clarity.

 

Accordingly ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. we show a high level of sensitivity in complying with the principle of clarity and transparency in the legal transactions and texts in which the purposes of personal data processing are explained (explicit consent, disclosure, responding to the data subject's applications, application to the data controllers' registry), and we keep the use of technical-legal terminology to a minimum so that these legal texts can be easily understood by everyone when presented to the other party.

Acting in accordance with this principle is also important in terms of compliance with the principle of good faith.

 

D) Principle of Being Relevant, Limited and Proportionate to the Purpose of Processing

 

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. We ensure that the data processed is suitable for achieving the specified purposes, and we avoid unnecessarily processing personal data that is not related to or not needed for achieving the purpose. At this point, we process personal data at the minimum level in order to serve the specified purpose.

Likewise, data is not processed with a view to meeting needs that may arise subsequently. In addition, the data processed shall be limited only to the personal data necessary to fulfil the purpose. ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. as a principle, once sufficient data to fulfil the purpose has been obtained, it refrains from processing data that is not necessary for any purpose beyond that.

 

E) Principle of Being Retained for the Period Stipulated in the Relevant Legislation or Required for the Purpose of Processing

 

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. retains personal data for a period appropriate to the purpose for which they are processed, as a requirement of the “purpose limitation principle”. As also stated in Article 12 of the Law, the data controller is obliged to take all necessary technical and administrative measures to ensure an appropriate level of security in order to prevent the unlawful processing of personal data, prevent unlawful access to personal data, and ensure the preservation of personal data. In this regard, ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. we are aware that we are obliged to take administrative and technical measures.

In our capacity as data controller, in accordance with the principle of purpose limitation for the storage of personal data, ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. in addition to the retention periods specified, there are also retention periods we have set within the scope of the relevant legislation to which we are subject. Accordingly, as the data controller ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. where legislation prescribes a retention period for the relevant personal data, we comply with that period; where no such period is prescribed, we retain the data only for as long as necessary for the purpose for which it was processed.

If there is no valid reason to retain data any longer, that data will be erased, destroyed or anonymised. As mentioned above, personal data cannot be retained on the assumption that it may be used again in future or for any other reason.

Furthermore, in its capacity as data controller ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. In accordance with Article 16 of the Law, when applying for registration with the registry, we determine the maximum period required for the purpose of processing personal data by taking Article 9 of the Regulation on the Data Controllers Registry into account, and the required periods are published in our legal documents.

 

CONDITIONS FOR PROCESSING SPECIAL CATEGORIES OF PERSONAL DATA

 

Special categories of personal data are data that, if disclosed, could lead to discrimination against or the victimisation of the data subject. For this reason, ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. we are aware that data of this nature must be protected far more strictly than other personal data with regard to its protection and processing. Indeed, the law attaches special importance to this data and introduces a different regulation concerning it. The Law recognises these as special categories of personal data, or sensitive data. Special categories of personal data may be processed with the data subject's explicit consent or in the limited cases set out in the Law.

In accordance with the law ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. we process special categories of personal data by obtaining the explicit consent of the data subject.

However, under the Law, the processing of special categories of personal data is also possible without the explicit consent of the data subject in the following cases:

• Special categories of personal data other than health and sexual life, only in cases stipulated by law,
• Personal data relating to health and sexual life may only be processed, by persons under an obligation of confidentiality or by authorised institutions and organisations, for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, and the planning and management of health services and their financing.

 

 

PERSONAL DATA CATEGORIES

 

A) Identity Information:

Personal data containing information about a person's identity; documents such as a driving licence, identity card and passport containing information such as first name and surname, national ID number, nationality, mother's and father's name, place of birth, date of birth and gender, as well as information such as tax number, social security number, signature and vehicle plate.

 

B) Contact Information

Contact information; personal data such as phone number, address, e-mail address and fax number.

C) Physical Premises Security Information

Personal data relating to records and documents obtained upon entry to and during stay within physical premises; such as camera recordings, fingerprint records, and records taken at security checkpoints, etc.

 

D) Professional Experience

Personal data containing information about the previous jobs, experience, careers and CVs of employees, as well as the certificates and courses they have completed, during the stages of conducting and completing the job application processes of candidates and of employees.

 

E) Financial Information

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİPersonal data processed in relation to information, documents and records showing any financial outcome created within the scope of the legal relationship between [the company] and the data subject, along with personal data such as bank account number, IBAN number, credit card information, financial profile, asset data and income information.

F) Personnel

This DATA category comprises personal data contained in documents such as payroll information, employment entry/exit records, unemployment registration documents, workplace accident reports, releases, and staff leave forms.

 

G) Special Categories of Personal Data

The data specified in Article 6 of the Personal Data Protection Law (for example, health data including blood type, biometric data, religion, and association membership information).

 

H) Criminal Convictions and Security Measures

Information regarding criminal record and security measures

 

I) Family Members and Next-of-Kin Information

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. within the framework of operations carried out by business units, ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ.personal data concerning the family members (for example, spouse, mother, father, child) and relatives of the data subject, in order to protect the legal interests of the company and the data subject.

 

J) Customer Transactions

Personal data belonging to the customer / the person purchasing the product or service, including tax number and invoice, cheque and promissory note information.

 

K) Marketing

Shopping history information, survey, cookie records, information obtained through campaign activities, etc.

 

L) Transaction Security

IP address information, website login-logout information, password and passcode information, etc.

 

M) Location

Location data of your current place, etc.

 

N) Risk Management

Information processed for managing commercial, technical and administrative risks, etc.

 

O) Legal Processing

Information in correspondence with judicial authorities and information contained in case files, etc.

 

DISCLOSURE TO DATA SUBJECTS

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. In accordance with Article 10 of the Personal Data Protection Law and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform, we carry out the necessary processes to ensure that data subjects are informed while their personal data is being collected. In this context, ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. the disclosure statements provided to data subjects contain the information listed below:

(1) As the data controller ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. Ltd. address and contact details

(2) ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. which personal data of the data subjects will be processed by whom and for what purpose,

(3) To whom and for what purpose the processed personal data may be transferred,

(4) The method and legal grounds for collecting personal data,

(5) The rights of the data subject, namely;

• To learn whether their personal data is being processed,
• To request information regarding their personal data if it has been processed,
• Learning the purpose of processing personal data and whether it is used in accordance with that purpose,
• Knowing the third parties to whom personal data is transferred domestically or abroad,
• To request the correction of personal data if it has been processed incompletely or incorrectly, and to request that this action be notified to third parties to whom the personal data has been transferred,
• To request the erasure or destruction of personal data within the framework of the prescribed conditions, and to request that this action be notified to third parties to whom the personal data has been transferred,
• To object to any outcome adverse to the individual resulting from the analysis of the processed data solely through automated systems,
• Requesting compensation for damages in the event of loss due to unlawful processing of personal data

 

 

RESOLUTION OF DATA SUBJECTS' REQUESTS BY ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ.

 

Data subjects' requests regarding their personal data ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ.in the event that they submit it in writing or by other methods determined by the KVK Board, ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. Any requests submitted to us by the data subject in order to exercise, in accordance with Article 13 of the Law, any of the rights set out in Article 11 of the Law, in our capacity as data controller, are concluded within thirty (30) days at the latest, and the data subject is informed accordingly.

Data subjects must submit their requests concerning their personal data in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller.

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. Within the scope of ensuring data security, it may request information in order to determine whether the applicant is the owner of the personal data that is the subject of the application. Furthermore, in order to ensure that the data subject's application is concluded in a manner appropriate to the request, it may pose questions to the data subject regarding their application.

 

ENSURING THE SECURITY AND CONFIDENTIALITY OF PERSONAL DATA BY ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ.

 

ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. all necessary measures, according to the nature of the data to be protected, are taken as far as possible to prevent the unlawful disclosure of, access to, transfer of personal data, or any other security deficiencies that may arise.

In this context ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. all necessary (i) administrative and (ii) technical measures are taken by, (iii) an audit system is established within the organisation, and (iv) in the event of unlawful disclosure of personal data, action is taken in accordance with the measures stipulated in the KVK Law

(1) To Ensure Lawful Processing of Personal Data and to Prevent Unlawful Access to Personal Data ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. Administrative Measures Taken by;

• ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. trains its employees on the legislation regarding the protection of personal data and ensures their awareness.
• In cases where personal data is subject to transfer, ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. clauses are included in the contracts concluded with the parties to whom personal data is transferred, stating that the party receiving the personal data will fulfil its obligations to ensure data security.
• ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. the personal data processing activities carried out by are examined in detail, and in this context the steps needed to ensure compliance with the personal data processing conditions stipulated in the KVK Law are identified.
• ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. It identifies the practices that must be implemented to ensure compliance with the Personal Data Protection Law and regulates these practices through internal policies.

 

(2) To Ensure Lawful Processing of Personal Data and to Prevent Unlawful Access to Personal Data ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. Technical Measures Taken by;

• Technology-appropriate technical measures are taken to prevent access to the systems and locations where personal data is stored, and the measures taken are updated periodically.
• ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİAccess and authorisation technical processes are designed and implemented in line with the legal compliance requirements at the business-unit level.
• Relevant software and systems, including software and hardware comprising virus protection systems and firewalls, have been installed.
• ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. our employees have been trained on the technical measures taken in this regard.
• ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. obtains undertakings from its employees that they will not disclose the personal data they learn to others in violation of KVKK provisions and will not use it outside the purpose of processing. This undertaking shall continue even after they leave their employment.
• ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. provisions requiring the necessary security measures to be taken for the protection of personal data have been added to the contracts concluded with the parties to whom personal data is transferred.
• Regarding the protection of personal data and ensuring its confidentiality, ERGUVAN GIDA, CAM, ELEKTRONİK, İNŞAAT, TEKSTİL, PLASTİK SANAYİ VE PAZARLAMA İTHALAT İHRACAT LTD. ŞTİ. the administrative and technical measures we have taken are described in more detail in our "Personal Data Retention and Destruction Policy".