PERSONAL DATA PROTECTION AND PROCESSING POLICY
CONTENTS
1.Introduction
2.Objective
3.Scope
4.Definitions
5.Data Controller's Purpose of Processing Personal Data
6.Principles of Personal Data Processing
7.Conditions of Personal Data Processing
8.Ensuring the Security of Personal Data
9.Data owner Rights and Application Process
10.Data Retention Periods and Destruction Method
11.Data Processed Person Group and Data Categories
12.Transfer of Personal Data
13.Camera Monitoring Activities in Buildings and Facilities
14.Enforcement
1. Introduction
In order to comply with Law No. 6698 on the Protection of Personal Data and related legal regulations, The procedures and principles adopted and to be implemented by our company are regulated by this policy within the scope of the data controller's obligation to disclose.
2. Objective
As Özen Mensucat Boya Terbiye İşletmeleri A.Ş (Özen Mensucat), the security of your personal data is important to us and we take care to protect it. Our aim is to inform you about the principles of processing personal data, the purposes and conditions of personal data processing, the transfer of your personal data, the destruction of your personal data and the practices and principles regarding your rights on your personal data processed by our company.
3. Scope
It is related to all personal data of employees, sub-employers, sub-employer employees, suppliers, supplier employees, job applicants, interns, customers, third parties and visitors, which are processed automatically or non-automatically provided that they are part of any data recording system.
4. Definitions
Explicit Consent: Consent on a specific subject, based on the information and expressed with free will.
Anonymization: Making personal data impossible to be associated with an identified or identifiable natural person under any circumstances, even through matching with other data.
Personal Data: Any information relating to an identified or identifiable natural person.
Processing of Personal Data: Any operation performed on personal data such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying or preventing the use of personal data by fully or partially automatic means or by non-automatic means provided that it is part of any data recording system.
Personal Data Owner: The real person whose personal data is processed.
Private Personal Data: Personal data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership to associations, foundations or trade unions, health, sexual life, criminal conviction and security measures, and biometric and genetic data are personal data of special nature.
Data Processor: A natural or legal person who processes personal data on behalf of the data controller based on the authorization granted by the data controller.
Data Controller: 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.
5. Purpose of the Data Controller in Processing Personal Data
Özen Mensucat processes Personal Data for the following purposes:
- Execution of employee rights and personnel procedures,
- Execution of candidate employee recruitment processes,
- For the execution of intern rights and personal transactions,
- Execution of corporate governance and communication activities,
- Execution of corporate sustainability activities,
- Execution of relations with suppliers and subcontractors,
- Conducting internal audit and legal procedures,
- Request and complaint management,
- Providing information to competent persons or organizations arising from legal regulations and instructions,
- Creation and follow-up of visitor records,
- Ensuring the safety of the company and its employees,
In the event that the processing activity carried out for the above-mentioned purposes does not meet any of the conditions stipulated under Law No. 6698, Özen Mensucat obtains explicit consent from the data owners regarding the relevant processing process.
6. Principles of Personal Data Processing
Özen Mensucat carries out personal data processing activities within the framework of the principles and principles listed below in accordance with Article 4 of the Protection of Personal Data Law (KVKK).
- To process Personal Data in accordance with the Personal Data Protection Law and other laws and regulations that must be complied with due to the work performed,
- To process your personal data processed by our Company in accordance with the processing purpose notified to you and within the notified framework,
- Not to process personal data that do not overlap with the activities of our company, are not required within the framework of company activities and exceed the purpose of processing,
- To preserve your data processed within the framework of the Personal Data Protection Law and other relevant laws and regulations for the periods stipulated in the relevant legislation or required to be kept due to the nature of the personal data processed,
- To take all necessary measures for the protection of personal data,
- To act in accordance with the relevant legislation and the regulations of the Personal Data Protection Board in transferring personal data to third parties in line with the requirements of the purpose of processing,
- To show the necessary sensitivity in the processing and protection of private personal data.
7. Conditions of Personal Data Processing
Depending on the service, product or commercial activity provided by Özen Mensucat or the content of the contract established between you and us, the nature of your personal data collected may vary and may be collected verbally, in writing or electronically by automatic or non-automatic methods, factory, offices, warehouse, website, social media channels, mobile applications and similar means.
Your collected personal data will be processed within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Personal Data Protection Law. Accordingly, your personal data will be processed for one of the legal reasons that it is directly related to the establishment or execution of a contract between Özen Mensucat and you and that the processing of personal data belonging to your parties is necessary or expressly stipulated by law, that it is mandatory for the data controller to fulfill its legal obligation or that it has been made public by the person concerned, or that data processing is mandatory for the establishment, exercise or protection of a right, or that data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.
In addition, this data will be processed in the following cases,
- In case of coordination, execution, quality control and evaluation of the works and communication regarding the goods and services provided / to be provided to Özen Mensucat by you or the company you represent, and quality control and evaluation of the service/contract performance,
- If financial and accounting records can be kept and payment transactions are realized,
- In case of communication between suppliers, business partners, external service providers and customers,
- In case of support from supplier employees,
- In the event that legal obligations such as ensuring and auditing occupational health and safety in Özen Mensucat factories and buildings are fulfilled,
- Provided that it does not harm the fundamental rights and freedoms of the data owner if it is obligatory to carry out personal data processing activities for the legitimate interests of Özen Mensucat
Your processed personal data will be retained for the period specified in the relevant legislation or for the maximum period required for the purpose for which they are processed and the legal lapse of time.
8. Ensuring the Security of Personal Data
In accordance with the Personal Data Protection Law and the relevant legislation, we fulfill the technical and administrative measures deemed necessary for the protection and security of your personal data that we process within the framework of our Company's activities within the framework of the necessary technological infrastructure. In this direction, we take measures against data breach, unauthorized access, data loss, unauthorized modification of data and threats and carry out the necessary audits. In this context, we identify existing risks and threats, conduct awareness activities by training our employees, determine policies and principles regarding personal data security, ensure personal data minimization, create the necessary confidentiality agreements with data processors, use firewalls and up-to-date anti-virus programs to ensure cyber security, We configure our existing software and hardware, perform software updates and audits, ensure the security of physical and electronic media containing personal data, and take necessary measures to prevent unauthorized breaches of your data security through key management, access logs, user account management, penetration control and encryption methods.
9. Data Owner's Rights and Application Process
The rights of ÖZEN MENSUCAT in accordance with Article 11 of Law No. 6698 on personal data shared with the company within the scope of the purposes specified in this policy and the methods of processing personal data are listed below:
And has the following rights
- Learn whether personal data is being processed,
- Request information if their personal data has been processed,
- To learn the purpose of processing personal data and whether the data is used in accordance with its purpose,
- To know the third parties to whom personal data are transferred domestically or abroad,
- To request correction of personal data in case of incomplete or incorrect processing,
- To request the deletion or destruction of personal data within the framework of the conditions stipulated in Law No. 6698,
- By analyzing the processed data exclusively through automated systems; to object to the emergence of a result to the detriment of the person himself/herself,
- In case of damage due to unlawful processing of personal data, to demand compensation for the damage
In order to use the rights listed above, you can contact our company by using the "Application Form" on our website http://www.ozenmensucat.com.tr and the methods specified in this form.
The requests of the owner of the personal data submitted in accordance with the above-mentioned application will be finalized by ÖZEN MENSUCAT free of charge within thirty days at the latest, depending on the nature of the request.
10. Data Retention Periods and Destruction Method
Personal data processed within the framework of our Company's activities are stored within the framework of the purpose of processing and for the periods necessary to ensure this purpose; for the retention period stipulated within the framework of the relevant legislation. Data that loses its function, whose retention period has expired, and which is requested to be destroyed by the data owner, if possible within the framework of the legislation, are destroyed by using the appropriate method of deletion, destruction or anonymization of personal data listed in Article 7 of the Personal Data Protection Law. Anonymization of personal data is the process of making personal data impossible to be associated with an identified or identifiable natural person under any circumstances, even if the personal data is matched with other data.
Records kept on camera surveillance are deleted every 3 months.
11. Group of Persons whose Data is Processed and Data Categories
ÖZEN MENSUCAT processes the data of the persons listed below within the scope of this policy. These persons are real persons such as company employees, job applicants, interns, suppliers, supplier employees, sub-employers, sub-employer employees, customers, third parties and visitors.
Özen Mensucat processes the identity, communication, family and affinity, criminal record, visual, education, residence, finance, personal and health data of persons who work on the basis of an employment contract and whose personal data are obtained through business relations in accordance with the Labor Law No. 4857. Processes the identity, communication, criminal record, visual, residence, financial, personal and health information of the real persons employed by the subcontractors who are employed by the subcontractors in a part of the main work or auxiliary works and the employees employed by the suppliers with whom a supplier agreement is signed for the purpose of service supply within the scope of Law No. 4857 identity, contact, visual, signature and financial information of subcontractors and suppliers, Identity, communication, criminal record, visual, financial, personal and health information of real persons doing internship within the scope of the Vocational Education Law No. 3308, Identity, contact, education, residence information of employee candidates who have applied for a job by any means or who have opened their CV and related information to our company's review, identity, contact and financial information of its customers with whom it has commercial relations, identity information of third parties not covered by this policy, such as family members, relatives and former employees, the identity and visual information of real persons in the position of visitors who have entered the physical premises owned by the company for various purposes.
12. Transfer of Personal Data
Özen Mensucat transfers personal data in cases specified in Articles 8 and 9 of Law No. 6698. Apart from these, personal data is not shared with third parties or legal entities in any way or used for commercial purposes for any non-operational reason.
Özen Mensucat does not transfer personal data processed under this policy abroad.
The relevant legal regulations in force regarding the processing and protection of personal data are primarily applied. In case of any incompatibility between the legislation in force and the policy, Özen Mensucat accepts that the legislation in force will be applied.
This policy may be amended or updated in line with new legal regulations and company policy. The new policy text reflecting all these changes and updates is announced to the relevant persons via the website.
13. Camera Surveillance Activities in Buildings and Facilities
Özen Mensucat camera surveillance activities are carried out to ensure the security of the company and the health and safety of other persons. Data owners are informed about the camera surveillance activities carried out by Özen Mensucat in accordance with Article 10 of Law No. 6698. Camera recordings are not shared with anyone other than authorized persons, institutions or organizations.
14. Enforcement
This policy to be implemented by Özen Mensucat entered into force on 24/12/2019.
ÖZEN MENSUCAT BOYA TERBİYE İŞLETMELERİ A.Ş.
CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA
As Özen Mensucat Boya Terbiye İşletmeleri A.Ş (hereinafter referred to as Özen Mensucat), the security of your personal data is important to us and we take care to protect it. Özen Mensucat, in its capacity as Data Controller, carries out the necessary processes to ensure that data subjects are informed during the acquisition of personal data in accordance with Article 10 of the Protection of Personal Data Law No. 6698 and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform.
Özen Mensucat processes the personal data of real persons such as company employees, job applicants, interns, supplier employees, subcontractors, subcontractor employees, customer employees, guardians and visitors, which are processed automatically or non-automatically provided that they are part of any data recording system, in accordance with the law and good faith, accurately and, where necessary, up-to-date, for specific, clear and legitimate purposes, in a purpose-related, limited and measured manner, and takes all administrative and technical measures in this context.
As the Data Controller, we fulfill all our responsibilities under the Protection of Personal Data Law as follows.
A) For what purposes is your personal data collected and processed?
Your collected personal data is processed for the following purposes within the personal data processing conditions and purposes specified in Articles 5 and 6 of the Protection of Personal Data Law Conducting commercial and corporate sustainability activities, Realization of the work projects and transactions carried out by Özen Mensucat units in this context, Providing information to third real or legal persons with whom a business relationship is entered into in order to carry out these activities, management of relations with suppliers and subcontractors, execution of personnel procurement processes, internal audit activities and execution of legal procedures, corporate governance and communication activities, and request and complaint management, Providing information to authorized persons or organizations arising from the legislation, creation and follow-up of visitor records. During the processing activities carried out for these purposes, explicit consent is obtained from the data subjects if they do not meet any of the conditions stipulated in Law No. 6698.
B) With whom and for what purposes are your personal data held within Özen Mensucat shared?
Özen Mensucat transfers the general and special categories of personal data of the personal data owner to authorized persons, institutions and organizations in accordance with the regulations stipulated in Article 8 of Law No. 6698 and by taking the necessary security measures. Özen Mensucat does not transfer personal data abroad. Apart from these, it is not shared with third parties or legal entities in any way, it is not used for commercial purposes for any reason other than activity, and it is not sold.
C) By which methods is your personal data collected and what is the legal basis for collection?
Your personal data is obtained in all kinds of verbal, written or electronic media, in line with the above-mentioned purposes, in order for Özen Mensucat to fulfill its contractual and legal obligations in a complete and accurate manner. Your personal data collected for this legal reason may also be processed and transferred for the purposes specified in sections (A) and (B) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Protection of Personal Data Law.
D) What are the Rights of Personal Data Subjects under the Protection of Personal Data Law?
As personal data owners, according to Article 11 of Law No. 6698, if you submit your requests regarding your rights to Özen Mensucat as stated in this Clarification Text, your request will be returned free of charge within thirty days at the latest. However, if the transaction requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board will be charged by Özen Mensucat. In this context, as the personal data owner;
● Learn whether personal data is being processed,
● Request information if their personal data has been processed,
● To learn the purpose of processing personal data and whether they are used for their intended purpose,
● To know the third parties to whom personal data are transferred domestically or abroad,
● To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
● Although it has been processed in accordance with the provisions of the Protection of Personal Data Law and other relevant laws, in the event that the reasons requiring its processing disappear, to request the deletion or destruction of personal data and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
● To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
● In case of damage due to unlawful processing of personal data, you have the right to demand compensation for the damage.
In order to use your rights mentioned above, you can fill out the form at www.ozenmensucat.com.tr and bring your request, which includes the necessary information identifying your identity and your explanations regarding your right you request to use, to the address "Çerkezköy Organize Sanayi Bölgesi Karaağaç Mahallesi 13. Sokak No:6 Kapaklı/TEKİRDAĞ" in person or send it through a notary public or you can send a signed copy of the form to [email protected] from your registered e-mail address with secure electronic signature.
It is submitted to the information of the public.
Best regards
Click for the Application Form
