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General KVKK Information Notice

Turgut Müteahhitlik Sanayi ve Ticaret Anonim Şirketi

INFORMATION NOTICE ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

(the “Information Notice”)

1. General Definition

Under the Law, personal data means any information relating to an identified or identifiable natural person. Special Categories of Personal Data, which constitute a particular type of personal data, refer to data concerning race, ethnic origin, political opinion, philosophical belief, religion, sect, other beliefs, appearance and clothing, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data.

Processing of personal data means any operation performed on personal data, whether wholly or partly by automated means or by non-automated means provided that it forms part of a data filing system, such as obtaining, recording, storing, retaining, altering, rearranging, disclosing, transferring, receiving, making available, classifying or preventing the use of such data.

2. Data Controller

Your personal data may be processed by Turgut Müteahhitlik Sanayi ve Ticaret Anonim Şirketi (the “Data Controller”) acting as data controller, within the scope explained below pursuant to Personal Data Protection Law No. 6698 (the “Law”).

3. Collection, Legal Grounds and Purposes of Processing Personal Data

Your personal data may be collected orally, in writing or electronically, by automated or non-automated means, in accordance with the Law. The methods of collection may vary depending on the services provided by the Data Controller and the Data Controller’s commercial activities.

The personal data collected may be processed, in accordance with the fundamental principles prescribed by the Law and within the personal data processing conditions (legal grounds) specified in Articles 5 and 6 of the Law and indicated below, by Turgut Müteahhitlik Sanayi ve Ticaret Anonim Şirketi for the purposes set out below. The following tables provide details of your personal data, how it is collected, the personal data that we may process and the purposes for which it is processed.

A. GROUPS OF INDIVIDUALS

Collection and Processing Purposes of Personal Data (Groups of Individuals)Method of Obtaining DataPurposes of Processing Personal Data
Shareholder/Partner
Employee
Intern
Job Applicant
Recipient of Products or Services
Document Management Software
Hard Disk
Information Technology Data Filing System
Excel Software
Software Application
Accounting Software
Monitoring and Conducting Legal Affairs
Conducting Goods / Services Procurement Processes
Conducting Goods / Services Production and Operational Processes
Conducting Contract Processes
Conducting Management Activities
Conducting Storage and Archiving Activities
Conducting Occupational Health / Safety Activities
Other - Ensuring Workplace Security
Fulfilling Obligations Arising from Employment Contracts and Legislation for Employees
Conducting Activities to Ensure Business Continuity
Planning Human Resources Processes
Providing Information to Authorised Persons, Institutions and Organisations
Conducting Activities in Compliance with Legislation
Managing Employee Fringe Benefits and Other Benefits
Managing Job Applicants’ Application Processes
Conducting Assignment Processes
Conducting Finance and Accounting Affairs
Conducting / Auditing Business Activities
Implementing Remuneration Policy
Conducting Job Applicant / Intern / Student Selection and Placement Processes
Legal Grounds
Legitimate Interests of the Data Controller
Signing a Contract
Fulfilment of a Legal Obligation
Express Provision in the Laws

B. OTHER GROUPS OF INDIVIDUALS

Collection and Processing Purposes of Personal Data (Groups of Individuals)Method of Obtaining DataPurposes of Processing Personal Data
Natural Person Acting as a Subcontractor’s Representative
Mediator
Lawyer
Financial Adviser
Provider of Products or Services
Natural Persons Who Are Parties to Enforcement Proceedings
Subcontractor’s Employee
Document Management Software
Hard Disk
Accounting Software
Excel Software
Conducting Goods / Services Procurement Processes
Conducting After-Sales Support Services for Goods / Services
Conducting Goods / Services Sales Processes
Conducting Goods / Services Production and Operational Processes
Conducting Contract Processes
Monitoring and Conducting Legal Affairs
Conducting Finance and Accounting Affairs
Conducting Activities to Ensure Business Continuity
Fulfilling Obligations Arising from Employment Contracts and Legislation for Employees
Conducting Activities in Compliance with Legislation
Conducting Occupational Health / Safety Activities
Providing Information to Authorised Persons, Institutions and Organisations
Legal Grounds
Signing a Contract
Legitimate Interests of the Data Controller
Fulfilment of a Legal Obligation
Express Provision in the Laws

4. Recipients of Your Personal Data and Purposes of Transfer

Your personal data may be transferred by the Data Controller to the domestic and overseas recipient groups listed below for the specified purposes, limited to the purposes stated above, in accordance with the fundamental principles prescribed by the Law and within the personal data transfer conditions specified in Articles 8 and 9 of the Law.

A. GROUPS OF INDIVIDUALS

Recipients of Personal Data and Purposes of TransferRecipients
GROUPS OF INDIVIDUALSDOMESTICOVERSEAS
Shareholder/Partner
Employee
Intern
Job Applicant
Recipient of Products or Services
Authorised Public Institutions and Organisations

Purpose of Transferring Personal Data
DOMESTICOVERSEAS
Providing Services to the Data Subject
Court Order
Payment Transactions
Signing a Contract
Commercial Purpose
Monitoring the Data Controller’s Legal Affairs and Transactions
Legal Obligation
Operational Transactions
Contract

Legal Grounds
DOMESTICOVERSEAS
Existence of Other Processing Conditions Arising from the Law
Legitimate Interest
Necessary for the Fulfilment of Obligations and Commitments
Legitimate Interest of the Data Controller
Legal Regulation
Existence of a Contract

B. OTHER GROUPS OF INDIVIDUALS

Recipients of Personal Data and Purposes of TransferRecipients
GROUPS OF INDIVIDUALSDOMESTICOVERSEAS
Natural Person Acting as a Subcontractor’s Representative
Mediator
Lawyer
Financial Adviser
Provider of Products or Services
Natural Persons Who Are Parties to Enforcement Proceedings
Subcontractor’s Employee
Authorised Public Institutions and Organisations

Purpose of Transferring Personal Data
DOMESTICOVERSEAS
Court Order
Monitoring the Data Controller’s Legal Affairs and Transactions
Legal Obligation
Payment Transactions

Legal Grounds
DOMESTICOVERSEAS
Legitimate Interest
Legitimate Interest of the Data Controller
Necessary for the Fulfilment of Obligations and Commitments
Existence of Other Processing Conditions Arising from the Law
Legal Regulation

5. Your Rights as a Personal Data Subject under Article 11 of the Law

Pursuant to Article 11 of the Law, we inform you that, as data subjects, you have the following rights:

  • To learn whether your personal data is being processed,
  • To request information if your personal data has been processed,
  • To learn the purpose of processing your personal data and whether it is used in accordance with that purpose,
  • To know the third parties to whom your personal data is transferred domestically or overseas,
  • To request the rectification of incomplete or inaccurate personal data and to request that the action taken in this context be notified to third parties to whom your personal data has been transferred,
  • To request the erasure or destruction of personal data when the reasons requiring its processing cease to exist, even if it has been processed in accordance with the Law and other relevant legal provisions, and to request that the action taken in this context be notified to third parties to whom your personal data has been transferred,
  • To object to a result arising against you through the analysis of the processed data exclusively by automated systems,
  • To claim compensation for damage suffered due to the unlawful processing of your personal data.

If you submit your requests concerning your rights to us using the methods specified below, your request will be concluded free of charge as soon as possible, depending on its nature, and within thirty days at the latest.

To exercise your rights, after completing and signing the data subject application/request form, a sample of which is available at turgutas.com.tr or may be obtained in person from the Data Controller’s address, you may submit that form or your petition bearing your original signature, prepared to exercise your rights, as follows:

  • You may deliver it in person to the secretariat at Ekrem Orhon Mah. 1 Nolu Karanfil Sk. No:2/1 Merkez/ Rize (the Data Controller’s address), together with documents establishing your identity,
  • You may send it to the above address through a notary public or by registered mail with acknowledgement of receipt,
  • If you have a registered electronic mail (KEP) address, you may send it to [email protected] with a secure electronic signature.

Thank you for reading this Information Notice.

Turgut Müteahhitlik Sanayi ve Ticaret Anonim Şirketi

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