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ABC Policy on Protection of Personal Data

1. Purpose and Scope

Purpose of this Policy on Protection of Personal Data (“Policy”) is to set forth relevant rights and obligations relating to duly processing of any personal data processed by ABC Deterjan Sanayi ve Ticaret A.Ş. (“ABC Deterjan” or “Company”).

This policy covers any data which can be associated with an identified or identifiable natural person, and any data processing operations performed in relation to them.

 

2. Definitions

Terms used in this Policy shall have the respective meanings assigned to them below. Any terms not defined herein shall have such meanings as assigned to them under Law No. 6698 on Protection of Personal Data.

Explicit Consentmeans freely given and informed consent relating to a specific matter.

Anonymizationmeans organizing personal data in such a manner that the personal data can irreversibly no longer have personal data properties.

Lawmeans Law No. 6698 on Protection of Personal Data

Processing of Personal Datameans any operation which is performed on data such as collecting, recording, storing, retaining, altering, reorganizing, disclosing, transferring, retrieving, making accessible, classifying, or preventing use of personal data by fully or partly automated means, or otherwise by non-automated means as a part of any data recording system.

Data Subjectmeans the natural person whose personal data is processed; e.g. customers and employees.

Personal Datameans any information relating to any identified or identifiable natural person.

Boardmeans Personal Data Protection Board

Data Processormeans any natural person or legal entity that processes personal data for and on behalf of the data controller based on the authority granted by the data controller.

Data Controllermeans any natural person or legal entity that determines the purposes and means of processing of personal data, and is responsible for establishment and management of the place (data recording system) where the data is systematically stored.

 

3. Rules on Processing of Personal Data

ABC Deterjan processes data in accordance with essential rules as defined under the Law and this Policy. When the purposes necessitating processing of such data cease to exist and unless there are any legal grounds, personal data will be anonymized, deleted or destructed by a suitable method in accordance with this Policy.

ABC Deterjan shall show due care and diligence to keep personal data completely and correctly. In case of any personal data which is not complete, correct, or sufficient, ABC Deterjan will take necessary action to rectify, alter, or update such personal data.

 

4. Conditions for Processing of Personal Data

4.1Without prejudice to any other regulations under applicable legislation, ABC Deterjan can process personal data when one or more of the following conditions exist:

  1. Processing of personal data is expressly required by any law;
  2. The data subject is actually incapable of giving consent or it is necessaryin order to protect the life or physical integrity of the data subject or another person where the data subject is legally capable of giving consent;
  3. It is necessary to process the personal data of parties of a contract provided that the processing is directly related to the execution or performance of the contract;
  4. It is necessary to process any personal datafor compliance with a legal obligation which ABC Deterjan is subject to;
  5. The relevant information is revealed to the public by the data subject herself/himself;
  6. It is necessary to process any personal data for the institution, usage, or protection of a right;
  7. It is necessaryfor the legitimate interests of ABC Deterjan provided that the fundamental rights and freedoms of the data subject are not harmed.

4.2In case one or more of foregoing conditions do not exist, your personal data shall be collected by obtaining your explicit consent.

4.3Processing of Special Categories of Personal Data will require existence of one or more of following conditions. Otherwise, explicit consent of the data subject will be required for processing of special categories of personal data.

  1. Except for personal data relating to health and sexual life data, data subject’s special categories of personal data (race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, appearance and dressing, membership of association, foundation or trade-union, criminal conviction and security measures, and biometrics and genetics) can be processed as defined under laws.
  2. Special Categories of Personal data relating to health and sexual life may only be processed for purposes of protection of public health, implementation of preventive medicine, medical diagnosis, treatment, and care services, planning and management of health services and financing by persons under the obligation of secrecy or authorized institutions and organizations.

 

5. Purposes of Processing of Personal Data

5.1Pursuant to transparency and openness principles, personal data and special categories of personal data collected by ABC Deterjan shall be generally processed for such purposes including but not limited to:

  1. Fulfilment of commercial activities carried out by the Company;
  2. Performance of supply chain processes;
  3. Performance of Company operations according to Company procedures and applicable legislation;
  4. Planning and performing business operations;
  5. Planning and performing corporate management operations;
  6. Planning business continuity operations;
  7. Planning human resources processes and needs;
  8. Planning product and service sales and marketing operations;
  9. Planning product and service sales processes;
  10. Planning customer relations management processes;
  11. Following customs requests and complaints;
  12. Following customer satisfaction processes;
  13. Following contract processes and legal requirements;
  14. Planning Company’s financial risk processes;
  15. Following finance and accounting operations;
  16. Planning and performing corporate communication operations;
  17. Planning supplier and business associate management processes;
  18. Fulfilling obligations stipulated by legislations;
  19. Ensuring safety of Company premises, fixture and resources.

 

6. Transfer of Personal Data

ABC Deterjan may transfer processed by ABC Deterjan to third parties for data processing purposes. ABC Deterjan adheres to requirements of the Law for sharing personal data.

ABC Deterjan can transfer personal data to third parties based on one or more conditions requiring processing of personal data as defined under the Law.

If and when one or more conditions requiring processing of special categories of personal data, ABC Deterjan can transfer special categories of personal data to third parties provided that ABC Deterjan takes any actions and safety measures as required by the Board, and shows maximum care and diligence.

 

7. Safety of Data

Our Company takes any legal, technical and administrative measures as required to ensure safety of data, and shows maximum care and diligence to this effect.

In this scope, ABC Deterjan implements to the best of its abilities safety measures such as encryption, masking, and anonymization.

 

8. Applications by Data Subject

For evaluating rights of personal data subjects and keep personal data subject informed as required, ABC Deterjan implements required channels, internal functions, administrative and technical regulations according to Article 13 of Law on Protection of Personal Data.

If a personal data subject files a request in writing relating top his/her rights listed below, our Company will finalize the request free of charge no later than thirty days depending on the request. However, if the Board requires charging a fee according to the legislation, applicant will be charged a fee at such rate as defined by the Board. A personal data subject has the right to:

  1. learn whether or not her/his personal data has been processed;
  2. request information as to processing if her/his data has been processed;
  3. learn the purpose of processing of the personal data and whether data is used in accordance with its purpose;
  4. know the third parties in the country or abroad to whom personal data has been transferred;
  5. request rectification in case any personal data is processed incompletely or inaccurately, and request that any third parties to whom such personal data has been transferred be notified of such operation;
  6. request deletion or destruction of personal data which has been processed according to provisions of Law and other applicable legislation in case the reasons necessitating processing of such data cease to exist; and request that any third parties to whom such personal data has been transferred be notified of such operation;
  7. object to any consequence that is to her/his detriment which arises as a result of analysis of personal data exclusively through automated systems;
  8. request compensation for any damages which s/he incurs as a result of unlawful processing of personal data.

 

Requests relating to enforcement of their abovementioned rights should be filed with our Company by the personal data subject either “in writing” or by any other methods as defined by the Board.

8.1 Enforcement

This Policy enters into force on __________2018. In case of any updates of this Policy, new versions will be published on ABC Deterjan’s website