LAW ON THE PROTECTION OF PERSONAL DATA

CLARIFICATION TEXT ON PROCESSING PERSONAL DATA

Çetinkaya Pano Saç Tablo ve Plas. San. Tic. A.Ş. Respects your privacy and prioritizes security of your data. As such, this text drawn up for informing and clarifying you the scope of the Law No. 6698 on the Protection of Personal Data (“Law”) and other relevant legislations.

Informing
the Law No. 6698 on the Protection of Personal Data was enacted on 24 March 2016, and came into force after its publication in the Official Gazette on 7 April 2016.However, pursuant to Clause 32, ‘Enforcement’, of the Law, the clauses 8, 9, 11, 13, 14, 15, 16, 17, and 18 of the Law came into effect as of 7 October 2016.

The Law is enacted for protecting, primarily, the right of privacy and civil rights and freedom of individuals during processing of personal data, and regulating obligations of real and legal entities processing personal data as well as the procedures and principles they are obliged to abide by. Therefore, this text fulfills the obligation to disclose stipulated by the Law, and “Protection of Personal Data and Consent for Sharing Personal Data” is provided to information and examination of visitors.

Processing of Personal Data

This process refers to processing your personal data and any transaction performed on data such as prevention of obtaining, recording, storing, safekeeping, changing, rearrangement, disclosure, transmit, taking over, availability, classification, or use of your personal data partially or completely automatically or non-automatically as part of any data recording system.

Reasons for Processing Your Data

Your personal data is processed pursuant to the Law, Clauses 5 and 6 for performing necessary operations in the company in order for providing you with the products and services offered by our company including but not limited to; carrying out necessary works by our relevant departments and partners in order for recommending you, our customers, such products and services suitable to your consumption and purchasing motivation; ensuring the rights of real entities by providing human resources management by our company; reaching to commercial decisions by the company, implementing and taking action for realizing the same; ensuring legal security of real entities with whom a business relation is established as well as our company regarding such relations; and similar purposes.

Your personal data may be processed by the company in the capacity of Data Controller in the following circumstances without any additional consent from you:

In cases where it is compulsory for protecting the life or bodily integrity of someone itself or someone else, who is not capable of declaring his/her consent due to physical impossibility, or whose consent has legal validity,
Where it is necessary to process personal data pertaining to contractual parties provided to be directly related to performance of a contract,
Where it is compulsory for fulfillment of our legal obligations as a data controller,
Where it was made public by the self of relevant person,
When it is necessary to process data in order for establishing, using, or protecting a right,
Provided not to harm civil rights and freedom of relevant person; it may be used for the purposes listed below based on any of the prerequisites when it is necessary to process data for the legal interest of the data controller.

Your personal data may be used for the following reasons pursuant to the Law, Clauses 4, 5, and 6:

To get into contact with you or other as part of the work,
To sent you important information and other managerial information regarding to any changes in the terms of our services, and changes in our electronic services,
To improve quality, training, and security (e.g., in regards to recorded or monitored calls to our contact numbers),
To respond to complaints, and to process requests for data access or correction,
To abide by the applicable laws and regulations, including those on anti-money laundering and anti-terror (including any in effect outside your residence country), to comply with legal processes and respond to demands of governmental and state authorities (including any from outside your residence country),
To manage our infrastructure and commercial activities as well as comply with internal policies and procedures related to those including audit, finance and accounting, billing and collection, data processing systems, data and website hosting, business continuity and records, management of documents and printing,
To determine and defend legal rights; to protect activities, rights, privacy, security, or assets of ours or our business partners, and/or those of yours or any third party, and apply available solutions or limit our damages,
To conduct market surveys and analyses, including satisfaction questionnaires,
To facilitate social media sharing function,
To personalize your experiences in electronic services by providing with information and advertisements special for you.

To Where and for What Purposes any Processed Data may be Transmitted

Your personal data that are obtained may be transmitted to our business partners, competent authorities, and authorized real entities in order to ensure legal and commercial security of our company and those doing a business relation with our company; perform by our departments such works necessary for making you use of any products and services provided by our company; propose you any product and service provided by our company by personalizing them according to your taste, usage habits, and needs; and for the purposes of ensuring the determination and application of the company’s commercial and business strategies as well as performing the human resources policies of our company, in the scope of the terms and conditions of data processing stipulated by the provisions of Clause 8 and 9 of the Law on Protection of Personal Data.

Method and Legal Grounds for Gathering Personal Data

Your personal data is gathered by our company by various means and based on different legal grounds for performing our commercial activities. Any of your personal data gathered based on such legal grounds may be processed and transmitted for the purposes stated in this text in the scope of the terms and conditions of processing personal data stipulated under Clauses 5 and 6 of the Law on Protection of Personal Data.

Any request of yours regarding to the rights of Owners of Personal Data under the Law on Protection of Personal Data, Clause 11, when submitted to our company by means of the methods regulated hereunder in this Clarification Text, will be concluded, free of charge, as soon as possible not more than thirty days by our company depending on the nature of request. In text context, owners of personal data have the rights;

To learn whether personal data is processed,
To request related information if personal data is processed,
To learn the purpose of processing personal data and whether they are used properly for such purposes,
To know any third party, in and out of country, to where personal data is transmitted,
In case that any personal data is deficiently or erroneously processed, to demand correction thereof, and request informing the procedures performed to any third party to where personal data is transmitted,
Despite having processed in accordance with the provisions of the Law on Protection of Personal Data and other applicable legislations; in case the reasons requiring the processing personal data cease to exist, to demand deletion or erasure of personal data, and request to inform any procedure performed accordingly to any third party relevant personal data is transmitted to,
To appeal any outcome resulted against himself/herself as result of analyses of any processed data exclusively via automatic systems,
To claim damages incurred due to illegal processing of personal data.

Pursuant to the Law on Protection of Personal Data, Article 13, § 1; You may submit your requests for making use of your rights above in writing or by other means set forth by the Council for Protection of Personal Data to the address of Çetinkaya Pano Saç Tablo ve Plas. San. Tic. A.Ş. at Selahattin Eyyübi Mahallesi Piri Reis Caddesi No:6 Kıraç/Istanbul in person, or transmitting via electronic mail address info@cetinkayapano.com, or sending your petitions stating your requests to Çetinkaya Pano via a notarized land post.

CLARIFICATION TEXT FOR CLOSED CIRCUIT CAMERA RECORDING SYSTEM

1– REGARDING TO IDENTIFICATION OF DATA CONTROLLER

This Clarification Text is drawn up for clarifying the data owners about the procedures and principles in relation to any personal data gathered by means of closed circuit recording systems utilized in the buildings and premises of Çetinkaya Pano Saç Tablo ve Plastik San. Tic. A.Ş. (herein after to be referred as ‘Company’) pursuant to the Law No. 6698 on Protection of Personal Data (‘the Law’).

2- PROCESSED PERSONAL DATA

It contains images of individuals appearing in the angle of view of cameras as well as the particulars of vehicle license plate of those driving into the Company building.

3- PURPOSE OF PROCESSING PERSONAL DATA

Any personal data gathered is processed, in the scope of the terms and conditions of processing personal data as stipulated under Clause 5 of the Law, in order to ensure legal, technical, commercial, and business security of any individual doing business with the Company, and the security of Company building and premises, employees, customers, suppliers, and the fixed assets of the company, and determination of any plausible illegalities as well as obtaining evidence thereof. As such, all the cameras are in recording around the clock seven days a week.

4- PARTIES THAT PERSONAL DATA MAY BE TRANSMITTED TO AND THE PURPOSE THEREOF

Your personal data may be shared with competent authorities, institutions, and organizations upon taking administrative and technical security measures for the above-mentioned reasons pursuant to above-mentioned regulations and other legislations.

5- METHOD AND LEGAL GROUNDS FOR GATHERING PERSONAL DATA

Personal data is gathered by means of camera systems mounted on Company building and premises. Camera monitoring activities are carried out as part of the company security policy. Any gathered personal data is processed as part of legal interests of the data controller in the scope of the terms and conditions of processing personal data stipulated under Clauses 5 and 6 of the Law.

6- SAFEKEEPING PERIOD

Camera recordings are kept safe by the Company for 28 days, and destroyed when the purpose of processing thereof is cease to be, and/or the safekeeping period prescribed for processing the same is expired pursuant to the legislation.

7- RIGHTS OF OWNERS OF PERSONAL DATA SET FORTH UNDER CLAUSE 11 OF THE LAW

Owners of personal data have the rights listed below, pursuant to Clause 11 of the Law No. 6698 on Protection of Personal Data;

1) To learn whether personal data is processed,

2) To request related information if personal data is processed,

3) To learn the purpose of processing personal data and whether they are used properly for such purposes,

4) To know any third party, in and out of country, to where personal data is transmitted,

5) To request correction of personal data processed deficiently or erroneously,

6) To request deletion or destruction of personal data according to the conditions stipulated under Clause 7 of the Law,

7) To request informing any transaction performed according to the above paragraphs (5) and (6) to any third party to which personal data are transmitted,

8) To appeal any outcome resulted against him/her as result of analyses of any processed data exclusively via automatic systems,

9) To claim damages incurred due to illegal processing of personal data.

METHOD OF FILING AN APPLICATION TO DATA CONTROLLER

Any individual, whose personal data is processed in relation to the closed circuit camera system, are required to file an application first to the data controller in order to make use of his/her rights pertaining to personal data. No complaint may be filed directly to the Council for Protection of Personal Data pursuant to Clause 14 of the Law. Individuals are obliged to apply to our company first being the data controller in order to make use of their rights pertaining to personal data. Pursuant to the Law, Article 13, § 2, your applications submitted to us will be answered, free of charge, in thirty days as of the date of delivery of relevant request to us depending on the nature of request. Our responses to you will be delivered to you in writing or via electronic medium pursuant to the provisions of Clause 13 of the Law. However, in case the Council for Protection of Personal Data stipulates a fee, we will charge a fee according to the tariff set forth by the Council of Protection of Personal Data.

Accordingly, by including your identity and address particulars in a clear and eligible form in your application to our company, you may apply;

By delivering as an originally signed document to our address “Selehaddin Eyyübi Mahallesi Piri Reis Cadde No: 6/1 Esenyurt/Istanbul” in person or via a Notary Public,
To our electronic mail address, ik@cetinkayapano.com, with secure electronic signature or mobile signature.

For further information on the procedures and principles to be followed during applications, please read the “Communiqué on Procedures and Principles of Applying to Data Controller” of the Council of Protection of Personal Data.