KVKK
UTS DANISMANLIK MARKETING SERVICES POLICY OF PROTECTION AND
PROCESSING OF PERSONAL DATA
1- INTRODUCTION:
Protection of personal data, UTS Dan. Paz. Speed. (“Turkbox”
in short) Turkbox is among the Values and Policies it attaches importance to
in corporate terms.
This Policy on Protection and Processing of Personal Data
(Briefly Policy) sets forth the principles to be adopted and taken into
consideration at the point of application regarding the processing and
protection of personal data in accordance with TURKBOX's Personal Data
Protection Law No. 6698 ("KVK Law") and other relevant legislation.
With this Policy, TURKBOX undertakes to act in accordance
with this Policy and the procedures to be applied in relation to the processing
and retention of all personal data belonging to all related persons in
accordance with the Personal Data Protection Law No. 6698.
2- PURPOSE OF THE POLICY:
The purpose of this Policy is to determine the principles
regarding the methods and processes for the protection of personal data in
order to comply with the KVK Law.
In this context, TURKBOX will make the necessary
arrangements for compliance with the Policy and will ensure the continuity of
compliance with the Policy by periodically operating internal control
mechanisms for compliance and will take all necessary administrative and
technical measures in terms of processing and protecting personal data.
3- SCOPE OF THE POLICY:
This Policy covers the Personal Data collected, processed or
shared with TURKBOX during its activities, including the employees, customers,
website visitors, mobile application users of TURKBOX, it is applied to the
said activities and if required by the KVK Regulations or In cases deemed
necessary by TURKBOX's data controller representative or the Committee, it can
be changed with the approval of the board of directors.
4- DEFINITIONS:
Personal Data means any information that allows TURKBOX to
determine the identity of a Relevant Person, either directly or indirectly, by
itself or by combining it with other information held or controlled by TURKBOX.
Special Qualified Personal Data includes information about
the race, ethnicity, political opinion, philosophical belief, religion, sect or
other beliefs, dress, association, foundation or union membership, health,
sexual life, criminal conviction and security measures, and biometric and means
data about their genetic information.
Personal Health Data means all kinds of health information
regarding an identified or identifiable natural person.
Data Processing means all kinds of operations performed on
Personal Data, including collecting, saving, storing, preserving, changing,
reorganizing, disclosure, transferring, taking over, making available,
classifying or preventing their use.
Related Person Personal Data means all real persons
processed by or on behalf of TURKBOX.
Explicit Consent means the consent given by free will after
being informed about a specific subject.
Destruction means the deletion or destruction of Personal
Data.
Anonymized Data means making Personal Data not to be
associated with an identified or identifiable natural person in any way, even
after the data controller or any other person who will make the Related Person
identifiable uses all reasonable and usual methods.
Data Processor refers to the natural or legal person who
processes Personal Data on his behalf based on the authority given by the data
controller. In each concrete case, who the Data Processor is should be
evaluated separately.
Data Supervisor means 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. The data
supervisor may be TURKBOX or, from time to time, a third person authorized by
TURKBOX or on behalf of TURKBOX. In each concrete case, who is the data
controller should be evaluated separately.
Board means the Personal Data Protection Board.
5- PRINCIPLES TO BE APPLIED IN THE PROCESSING OF PERSONAL
DATA:
Personal data will be processed by TURKBOX verbally, in
writing or electronically by automatic or non-automatic methods, and it will be
acted in accordance with the Constitution and KVK Law for processing personal
data.
In addition, certain principles will be adhered to in the
processing of personal data. In this context;
a. Personal data will be processed by TURKBOX in accordance
with the law and honesty rules and in accordance with the principles of
proportionality and proportionality, as much personal data as necessary.
b. Personal data will be processed by TURKBOX for specific,
clear, legitimate and legal purposes. TURKBOX clearly announces these purposes
before the Personal Data of Data Owners are obtained.
c. TURKBOX provides personal data only for the periods
stipulated by the laws and
or maintains it as needed for the purpose for which it was
processed. In this context, if a period of time is specified for the storage of
personal data in the relevant legislation, this period will be respected, if a
period is not specified, personal data will be kept for the period required for
the purpose for which they are processed. However, this period can be kept
longer in order to comply with the obligations specified in the legislation or
to protect legitimate business interests.
TURKBOX is responsible for the destruction of all data in
accordance with the legislation in the event that the purpose of collecting
this data disappears and the legal retention periods expire, regarding Personal
Data in physical and electronic data recording systems.
All transactions regarding the deletion, destruction and
anonymization of Personal Data will be recorded and the said records will be
kept for at least three (3) years, excluding other legal obligations.
D. TURKBOX; It takes the necessary measures to ensure that
the Personal Data it processes are accurate and up to date when necessary.
6- PROCESSING OF PERSONAL DATA:
Personal data will be processed after the data subject is
informed and upon the explicit consent of the data owner. Within the framework
of the Obligation of Disclosure, the data owner will be notified of their
rights before obtaining explicit consent, and the explicit consent will be
obtained in accordance with the KVK Regulations.
In cases where it is foreseen to process personal data
without explicit consent within the scope of KVK regulations (Article 5.2 and
6.3 of the KVK Law), TURKBOX will be able to process personal data without
obtaining the explicit consent of the data owner. In this context:
a. If clearly stipulated in the laws,
b. If the processing of personal data is mandatory for
TURKBOX to fulfill its legal obligation,
c. Provided that it is directly related to the
establishment, implementation, performance or termination of a contract, it is
necessary to process personal data belonging to the parties to the contract,
D. If processing of personal data without express consent is
mandatory for the establishment, use or protection of a right,
to. In case data processing is mandatory for the legitimate
interests of TURKBOX, provided that it does not harm the fundamental rights and
freedoms of the data owner,
f. In the event that the life or body integrity of the data
owner and / or a person other than the data owner who is unable to disclose his
consent due to actual impossibility or whose consent is not legally valid,
g. If the personal data is made public by the data owner,
Personal data can be processed by TURKBOX without explicit
consent.
7- PROCESSING SPECIAL QUALITY PERSONAL DATA:
TURKBOX, people's race, ethnic origin, political opinion,
philosophical belief, religion, sect or other beliefs, costume and dress,
association, foundation or union membership, health, sexual life, criminal
conviction and security measures and biometric and genetic data. processes
sensitive personal data with the explicit consent of the data subject.
Special quality personal data other than health and sexual
life can be processed without the explicit consent of the relevant person in
cases stipulated by the law.
Special quality personal data regarding health and sexual
life are only disclosed by persons under confidentiality obligation or
authorized institutions and organizations for the purpose of protecting public
health, conducting preventive medicine, medical diagnosis, treatment and care
services, planning and managing health services and financing. can be processed
without seeking consent. For example, processing reports and documents
regarding the persons employed under this status in the workplace within the
scope of the obligation to employ disabled people.
TURKBOX carries out the necessary actions to take the
measures determined by the Board in the processing of special quality data.
8- TRANSFER OF PERSONAL DATA:
Personal Data only if the presence of one of the cases where
consent is sought Outdoor enumerated in section Processing of Personal Data of
Public presence or consent to the transfer of contact data can be transferred
to third parties in Turkey.
In the transfer of Personal Data to third parties abroad, in
addition to the conditions listed above;
• The foreign country to which the Personal Data is
transferred should provide sufficient protection or;
• In the event that there is not enough protection in the
relevant foreign country, TURKBOX and the data controllers in the relevant
foreign country undertake in writing that sufficient protection is provided and
the Board's permission
conditions must be found.
9- DELETING, DESTRUCTION OR ANONYMOUS DATA OF PERSONAL DATA:
Although TURKBOX has been processed in accordance with the
provisions of the Law and other relevant laws, personal data are deleted,
destroyed or anonymized, either ex officio or upon the request of the person
concerned, in the event that the reasons for processing disappear.
Personal data are deleted and destroyed in a way that cannot
be reused and recovered.
carried out. Accordingly, the data are deleted from tools
such as documents, files, CDs, floppy disks, hard disks in which they are
recorded in a way that cannot be recycled.
10- LIABILITY TO ENLIGHTEN THE PERSONAL DATA OWNER:
TURKBOX will enlighten the persons whose data will be
processed during the acquisition of personal data in accordance with Article 10
of the KVK Law on how their data will be processed. The minimum issues that
should be included in the information are listed in the KVK Law:
1. Identity of the company and its representative as the
data controller,
2. The purpose for which personal data will be processed,
3. To whom and for what purpose the processed personal data
can be transferred,
4. Methods and legal reasons for collecting personal data,
5. Rights of personal data owner
a. Learning whether any of your Personal Data / Personal
Data is processed,
b. Requesting information regarding the processing
activities of your Personal Data / Personal Data,
c. Learning the purposes of processing your Personal Data /
Personal Data,
D. In case your Personal Data / Personal Data has been
transferred to a third person / institution and / or organization in the
country or abroad, learning these persons / institutions and / or
organizations,
to. Requesting correction / updating of your Personal Data /
Personal Data if it is incomplete or incorrectly processed,
f. To request the deletion or destruction of your Personal
Data / Personal Data in the event that the reasons requiring the processing of
your Personal Data / Personal Data are eliminated or TURKBOX does not have a
legal basis or legitimate interest to process such data,
g. Object to the negative consequences that may arise as a
result of the processing of your Personal Data / Personal Data through
automated systems and,
h. If you suffer damage due to the illegal processing of
your Personal Data / Personal Data, to request compensation for this damage
In cases where data owners want to exercise their rights,
they can deliver their requests to the e-mail address below, which may change
from time to time, with a secure electronic signature, or to the postal address
below, which may change from time to time, with documents identifying their
identity and a wet-signed petition or a notary public. can send via.
Data Supervisor: UTS Consulting Marketing Services
E-mail: info@Turkbox.com.tr
Postal: Cevizli Mah KIR sok Yonca Sitesi No: 25 L Blok D: 9
Maltepe / Istanbul
Depending on the nature of the request, TURKBOX will
finalize the relevant request as soon as possible and within thirty days at the
latest, free of charge. In case the transactions subject to the request require
a cost, it is possible to request a fee and expense on the tariff determined by
the Personal Data Protection Board in accordance with Article 13 of the
Personal Data Protection Law No. 6698.
As a result of the evaluation, TURKBOX can accept the
applications and take the necessary actions, as well as reject the applications
by e-mail or mail with a justification. The personal data owner can make a
complaint to the KVK Board within 30 days if the application is rejected, the
response is insufficient or the application is not responded in time.
11- CHANGES TO BE MADE IN THE POLICY AND EFFECTIVE DATE:
The provisions of this Policy can be changed by being
published on the internet sites in accordance with the provisions of the
legislation if deemed necessary by TURKBOX. If any of these provisions are
changed, the relevant changes will become effective on the date the change is
published.
This Policy has been published and entered into force on
January 2020.
