Policy on the Protection and Processing of Personal Data for Third Parties
TABLE OF CONTENTS
1. Definitions
2. Legal Basis
3. Scope
4. Registration with the Data Controllers Registry (VERBIS)
5. Classification of Personal Data
a. Personal Data
b. Special Categories of Personal Data
6. Duty to Inform and Provide Information (“Information Duty”)
7. Conditions for Processing Personal Data (“Processing Conditions”)
a. Personal Data
b. Special Categories of Personal Data
8. General Principles in the Processing of Personal Data (“General Principles”)
a. Compliance with the Law and the Principle of Good Faith
b. Being Accurate and, Where Necessary, Up to Date
c. Processing for Specific, Explicit and Legitimate Purposes
d. Being Relevant, Limited and Proportionate to the Purpose of Processing
e. Retention for the Period Prescribed by Legislation or Required for the Purpose of Processing
9. Purposes of Processing Personal Data
10. Personal Data of Candidate Employees
11. Visitor Data
a. Visitor Entry/Exit Physical Premises Records
b. Internet Access Provided to Visitors
12. Personal Data of Suppliers / Subcontractors / Business Partners
13. Use of Security Cameras
14. Transfer of Personal Data
a. Recipient Groups
b. Domestic Transfer of Personal Data
c. Transfer of Personal Data Abroad
15. Data Security Policy
16. Data Subject’s Rights and Exercise of These Rights
17. Reference
18. Entry into Force
Annex 1. General Information Notice
Annex 2. Data Subject Application Form
Annex 3. Candidate Employee Information Notice
Annex 4. Visitor Information Notice
Annex 5. Supplier / Subcontractor / Business Partner Information Notice
Annex 6. Customer Information Notice
1. DEFINITIONS
Policy; This Policy on the Protection and Processing of Personal Data
KVKK; Law No. 6698 on the Protection of Personal Data
Board; Personal Data Protection Board
Authority; Personal Data Protection Authority
Data Controller; Teks-Pro Promosyon Tekstil Ürünleri San. ve Tic. Ltd. Şti. (Teks-Pro), which determines the purposes and means of processing personal data, is responsible for the establishment and management of the data recording system, and is obliged to register with the Data Controllers Registry
VERBIS; Data Controllers Registry
Personal Data; The data defined in Article 4(a) of the Policy, in compliance with the Law
Special Categories of Personal Data; The data defined in Article 4(b) of the Policy, in compliance with the Law
Processing of Personal Data; Any operation performed on personal data, such as obtaining, recording, storing, retaining, changing, reorganizing, disclosing, transferring, taking over, classifying, or preventing its use, by fully or partially automatic means or by non-automatic means provided that it forms part of any data recording system,
Data Subject; The Personal Data Owner, namely the natural person whose personal data is processed,
Third Party; All natural persons other than Teks-Pro employees,
Information; Informing the data subject in compliance with the Law regarding the processing of personal data
Explicit Consent; Consent given based on being informed about the subject matter of processing and on free will, and limited to the purpose of processing personal data
shall mean.
2. LEGAL BASIS
This Policy has been prepared based on the version of the KVKK in force as of the date of its publication.
3. SCOPE
This Policy covers all natural persons, other than Teks-Pro employees, whose personal data is processed by Teks-Pro. Accordingly, the groups of persons within the scope of the Policy are those other than employees (candidate employees, business partners, subcontractors, suppliers, contractor employees and authorized persons; visitors and other third parties). Since the KVKK regulates only natural persons, data relating to legal entities is not considered personal data and legal entities are not within the scope.
4. REGISTRATION WITH THE DATA CONTROLLERS REGISTRY (VERBIS)
Teks-Pro fulfills its VERBIS registration obligation within the scope of Article 16 of the KVKK.
5. CLASSIFICATION OF PERSONAL DATA
a. Personal Data
Any information relating to an identified or identifiable natural person is personal data.
b. Special Categories of Personal Data
Data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, attire, membership of associations, foundations or trade unions, health, sex life, criminal convictions and security measures, biometric data, and genetic data are special categories of personal data.
6. INFORMATION DUTY
Pursuant to Article 10 of the KVKK and Article 4 of the “Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform”, the data controller is obliged to inform the data subject. Within this scope, the data subject is informed by Teks-Pro, in compliance with the KVKK, on the following matters:
• The identity of the data controller and, if any, its representative,
• The purposes for which personal data will be processed,
• To whom and for what purposes the processed personal data may be transferred,
• The method and legal basis of collecting personal data,
• What the rights of the data subject are, how the data subject may submit requests regarding these rights, and the evaluation and response period for such requests.
The Information Duty may be fulfilled verbally or in writing, via audio recording, call center, or by using physical or electronic means (Communiqué on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform, Article 5). Teks-Pro fulfills its information duty by following methods appropriate to the purpose.
7. CONDITIONS FOR PROCESSING PERSONAL DATA (PROCESSING CONDITIONS)
In terms of processing, the conditions below are complied with together with the “GENERAL PRINCIPLES”.
a. Personal data cannot be processed without the DATA SUBJECT’S EXPLICIT CONSENT. However, as listed under Article 5 of the KVKK, personal data may be processed without seeking the data subject’s explicit consent if one of the following conditions exists:
i. Explicitly provided for by laws
ii. Being mandatory for the protection of the life or physical integrity of the person or another person who is unable to give consent due to actual impossibility or whose consent is not legally valid
iii. Being necessary for the establishment or performance of a contract, provided that it is directly related to the contract and personal data of the parties to the contract is processed
iv. Being mandatory for the data controller to fulfill its legal obligation
v. Being made public by the data subject
vi. Being mandatory for the establishment, exercise, or protection of a right
vii. Being mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject
b. Special categories of personal data cannot be processed without the DATA SUBJECT’S EXPLICIT CONSENT. However, pursuant to Article 6 of the KVKK, in the absence of explicit consent, special categories of personal data may be processed, provided that adequate measures determined by the Board are taken, in the following cases:
i. Special categories of personal data, other than data relating to health and sex life, may be processed without the data subject’s explicit consent in cases stipulated by law.
ii. Special categories of personal data relating to health and sex life may be processed only by persons under an obligation of confidentiality or by authorized institutions and organizations, for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, and the planning and management of health services and their financing.
8. GENERAL PRINCIPLES IN THE PROCESSING OF PERSONAL DATA (GENERAL PRINCIPLES)
In terms of processing, the general principles below are complied with together with the “PROCESSING CONDITIONS”.
a. Compliance with the Law and the Principle of Good Faith
Data processing activities are carried out by Teks-Pro in compliance with the law and the principle of good faith, and data is processed accurately and, where necessary, up to date, for specific, explicit and legitimate purposes, and in a manner that is relevant, limited and proportionate to the purpose.
b. Being Accurate and, Where Necessary, Up to Date
Necessary measures are taken to ensure that processing activities are accurate and, where necessary, up to date.
c. Processing for Specific, Explicit and Legitimate Purposes
Teks-Pro clearly sets out the purpose of processing activities and carries out processing to the extent required by the purpose and in connection with it.
d. Being Relevant, Limited and Proportionate to the Purpose of Processing
Processing activities are carried out only in a manner suitable for achieving the purpose of processing, and no processing is performed for purposes unrelated to achieving the purpose or for purposes that are not needed, or for potential future purposes.
e. Retention for the Period Prescribed by Legislation or Required for the Purpose of Processing
Personal data subject to processing is retained by Teks-Pro for the period specified in the relevant legal regulations under the KVKK provisions or for the period required by the purpose of processing. In this scope:
i. First, it is determined whether the retention period is legally stipulated.
ii. If a period is stipulated, it is complied with.
iii. If no period is stipulated, personal data is retained for the period necessary for the realization of the purpose of processing.
iv. Upon the expiration of the period stipulated in legal regulations or the disappearance of the reasons requiring processing, personal data is destroyed by Teks-Pro through an appropriate method of destruction (deletion / destruction / anonymization) in line with Teks-Pro destruction periods or upon the data subject’s application.
9. PURPOSES OF PROCESSING PERSONAL DATA
a. Provided that it does not contravene legal principles and rules and on the condition of compliance with the rules in this Policy, personal data is processed for the following purposes:
• Ensuring Compliance of Activities with Legislation
• Providing Information to Authorized Persons, Institutions and Organizations
• Conducting Management Activities
• Conducting Contract Processes (All)
• Planning Human Resources Processes
• Following Up and Conducting Legal Affairs
• Conducting Communication Activities
• Conducting OHS (Occupational Health and Safety) Activities
• Conducting Internal Audit / Disciplinary Processes
• Ensuring the Security of Data Processing Activity Operations Carried Out as the Data Controller
• Conducting Candidate Employee / Intern / Student Application, Selection and Placement Processes
• Fulfilling Obligations Arising from Employment Contracts and Legislation for Employees
• Conducting Fringe Benefits and Interests Processes for Employees
• Work and Residence Permit Procedures for Foreign Personnel
• Conducting Assignment Processes
• Conducting Wage Policy
• Conducting Talent / Career Development Activities
• Conducting Audit / Ethics Activities
• Conducting Training Activities
• Conducting Access Authorization Processes
• Conducting Finance and Accounting Affairs
• Conducting Business / Planning / Production / Operation Processes and Ensuring Continuity
• Conducting Logistics Activities
• Conducting Procurement Processes for Goods / Services
• Conducting Promotional Activities for Goods / Services
• Conducting Sales – Marketing Processes for Goods Subject to Production
• Conducting After-Sales Support Services for Goods Subject to Production
• Following Up Requests / Complaints
• Conducting Emergency Management Processes
• Conducting Information Security Processes
• Ensuring and Monitoring the Security of Movable Property and Resources
• Ensuring and Monitoring Physical Premises Security
• Conducting Retention and Archiving Activities
• Creating and Monitoring Visitor Records
10. PERSONAL DATA OF CANDIDATE EMPLOYEES
a. Fulfillment of the Information Duty
At the beginning of the candidacy process, as a requirement of being the data controller, Teks-Pro informs the candidate employee about which data will be processed for which purposes during the candidacy process, for how long the data will be retained, and about the rights under Article 11 of the KVKK as a data subject.
b. Special Categories of Personal Data
Unless required by the nature of the job and legal obligations, Teks-Pro does not process the candidate employee’s special categories of personal data (health, membership of associations/foundations/trade unions, criminal conviction data, sex life, race, ethnic origin, political opinion, philosophical belief, sect, religion or other beliefs, attire, biometric data, genetic data).
However:
i. If special categories of personal data are subject to processing due to the nature of the job or legal obligation, or because they are included in the resume submitted by the candidate employee, then such data may be processed only to the extent and within the limits required by the nature of the job or legal obligations.
ii. Reference Information Provided by the Candidate Employee
Reference information provided by the candidate employee includes identity, contact, and professional experience information of the reference person indicated by the candidate. This information may be processed only for the purpose of conducting reference checks for the candidate employee.
iii. For these cases, explicit consent is obtained from the candidate employee.
c. Retention Period
&emps; i. If the candidate employee’s candidacy process is not completed and employment is not provided, i.e., the candidate does not start working at Teks-Pro, the candidate employee’s personal data is destroyed within two months (at the latest during the first routine destruction process following the end of the two-month period).
ii. If the candidate employee is employed, i.e., starts working at Teks-Pro, then the processing of personal data continues under the procedure for processing employees’ personal data, and personal data is retained thereafter for the period specified in the relevant legislation or required for the purpose for which it is processed.
d. Candidate employee data is not shared by Teks-Pro with unrelated third parties and is not transferred abroad.
11. PERSONAL DATA OF VISITORS
a. Visitor Entry/Exit Physical Premises Records
For the purposes of ensuring and monitoring physical premises security, the security of movable property and resources; conducting emergency processes; conducting occupational health and safety processes; and providing information to authorized institutions and organizations when necessary; in compliance with legal regulations, Teks-Pro carries out personal data processing activities for monitoring visitors’ building entry/exit and internal unit transitions regardless of the reason for the visit.
Necessary warnings are visibly placed at premises entrances to inform visitors.
b. Internet Access Provided to Visitors
For the purposes of conducting information security processes, ensuring the security of processing activities carried out by the data controller, and providing information to authorized institutions and organizations when necessary; in compliance with legal regulations, internet access (via guest connection) may be provided to visitors upon request during their presence at the workplace.
In such cases, log records relating to the visitor’s internet access are recorded in accordance with Law No. 5651 on the Regulation of Publications on the Internet and Combating Crimes Committed Through Such Publications and the mandatory provisions of secondary legislation issued under this Law; these records are processed only upon request by authorized public institutions and organizations or for the purpose of fulfilling legal obligations.
Visitor data is shared with the supplier company providing security services to Teks-Pro and with public/judicial authorities upon their request. Visitors’ personal data is not shared with unrelated third parties and is not transferred abroad.
12. SUPPLIER / SUBCONTRACTOR / BUSINESS PARTNER DATA
a. As a requirement of being the data controller, Teks-Pro informs the parties with whom it has a business relationship, regarding which personal data will be processed for which purposes, how long the data will be retained, and the rights under Article 11 of the KVKK as a data subject, in relation to the establishment, continuation and termination of the business relationship processes. In addition, Teks-Pro obtains undertakings from these parties to fulfill their legal commitments imposed by the KVKK.
b. Personal data of the data subjects in this group is not shared with unrelated third parties by Teks-Pro. Personal data may be shared, to the extent and frequency required by the business/contractual relationship between the parties, with Teks-Pro’s professional advisors, accountants and financial advisors, auditors, companies providing information technologies and archiving services, occupational health and safety institutions and experts from whom services are received for the fulfillment of legal obligations, institutions with which Teks-Pro has a commercial, administrative or contractual relationship, banks, public/judicial authorities, and other third parties domestically or abroad.
c. Personal data of the data subjects in this group is retained by Teks-Pro for the period specified in the relevant legislation or required for the purpose for which it is processed.
13. USE OF SECURITY CAMERAS
For the purposes of ensuring and monitoring physical premises security; ensuring and monitoring the security of movable property and resources; conducting emergency processes; conducting information security processes; conducting occupational health and safety processes; and providing information to authorized institutions and organizations when necessary; in compliance with legal regulations, Teks-Pro records images via security cameras of visitors, employees and other data subjects regardless of the reason for the visit, and such records are securely stored in physical or electronic environments for 21 days.
In areas where image recording is carried out, visible warnings are placed to inform data subjects that image recording is being conducted.
14. TRANSFER OF PERSONAL DATA
a. Recipient Groups
Personal data may be transferred to the following recipient groups, in order to fulfill requirements arising from legislation and the purposes set out in this Policy, within the framework of the processing conditions and general principles in the KVKK and other legal regulations, and by taking necessary security measures:
• Natural persons or private law legal entities
• Shareholders
• Business Partners
• Suppliers / Contractors / Subcontractors
• Authorized Public Institutions and Organizations
b. Domestic Transfer of Personal Data
In transferring personal data, actions are taken in compliance with the decisions and regulations set forth in the KVKK and adopted by the Board. Personal data and special categories of personal data belonging to the data subject are not transferred to other natural persons or legal entities without the data subject’s explicit consent.
However;
Personal data may be transferred in the presence of the circumstances set out in Article 6(a) of this Policy, and for special categories of personal data, in the presence of the circumstances set out in Article 6(b) of this Policy. (This also corresponds to KVKK Article 8 by reference to Articles 5 and 6.)
c. Transfer of Personal Data Abroad
Personal data may be transferred abroad as well, whether processed domestically or to be processed and retained abroad. In transferring personal data abroad, actions are taken in compliance with the decisions and regulations set forth in the KVKK and adopted by the Board. Personal data cannot be transferred abroad without the data subject’s explicit consent.
However;
• If personal data falls under the circumstances set out in Article 6(a) of this Policy, and for special categories of personal data, under Article 6(b) of this Policy, AND IN ADDITION,
• If adequate protection exists in the country to which the data will be transferred, OR
• If adequate protection does not exist, provided that the data controllers in Türkiye and in the relevant foreign country undertake in writing to provide adequate protection and the Board’s authorization is obtained,
then personal data may be transferred abroad without seeking the data subject’s explicit consent.
Countries where adequate protection exists will be determined and announced by the Board; as of the publication date of this Policy, such a list has not yet been published.
Pursuant to Article 9 of the KVKK, provisions in other laws regarding the transfer of personal data abroad are reserved.
15. DATA SECURITY POLICY
As the data controller, Teks-Pro takes all necessary technical and administrative measures appropriate to the nature of the relevant data to ensure an adequate level of security, in order to prevent unlawful processing of personal data, prevent unlawful access to personal data, and ensure the retention of personal data. Teks-Pro conducts and/or has conducted the necessary audits to ensure the implementation of the KVKK and related legislation and this Policy. In this scope, where non-compliance is detected, Teks-Pro takes measures and actions to eliminate the non-compliance, and also initiates the necessary disciplinary and/or legal and/or administrative processes before the Board against those who caused the non-compliance.
16. DATA SUBJECT’S RIGHTS AND EXERCISE OF THESE RIGHTS
a. The data subject’s rights and the method of exercising these rights are defined under Article 11 of the KVKK. Accordingly, the data subject’s rights are as follows:
• a) To learn whether personal data is processed,
• b) To request information if personal data has been processed,
• c) To learn the purpose of processing personal data and whether they are used in accordance with this purpose,
• ç) To know the third parties to whom personal data is transferred domestically or abroad,
• d) To request the correction of incomplete or inaccurate personal data,
• e) To request the deletion or destruction of personal data within the framework of the conditions stipulated in the KVKK,
• f) To request notification of the transactions carried out pursuant to (d) and (e) to third parties to whom personal data has been transferred,
• g) To object to the occurrence of a result against the person by analyzing the processed data exclusively through automated systems,
• ğ) To request compensation for damages in case of loss due to unlawful processing of personal data,
b. In order to meet access requests for exercising the data subject’s rights, the necessary application channel is available on this page. This page contains the application method, the data controller representative registered in VERBIS, other required legal disclosures, and a sample form. Applications may be made by following the information and form details on this page.
c. Until a method is determined by the Board, applications must be submitted in writing.
d. During the application, the data subject must clearly indicate which right is being exercised and, if any, submit supporting information and documents by registered mail with return receipt to Teks-Pro at “Namık Kemal Mh. Değirmen Sk. No:53 Ümraniye 34762 Istanbul, Türkiye”, or via a notary, or by email to info@tekspro.com.tr.
e. Upon receipt of the application, as the data controller, Teks-Pro or its representative finalizes the request free of charge within 30 days at the latest, depending on the nature of the request; or, if the conditions in the fee schedule to be published by the Board are met, against the fee specified in that schedule.
For this period to start, requests must be sent to the data controller representative in writing or by other methods determined by the Board, and must also be accompanied by documents verifying and evidencing the identity of the data subject.
The data controller representative may request information from the data subject to determine whether the applicant is the personal data owner, and may ask questions to clarify the matters in the application.
f. A data subject whose application is rejected, whose response is found insufficient, or who does not receive a response in due time has the right to file a complaint with the Board within 30 days from the date of learning the response and in any case within 60 days from the application date.
g. The Data Subject’s Application May Be Rejected in the Following Cases:
• Processing of personal data by anonymizing it for purposes such as research, planning and statistics as official statistics,
• Processing of personal data made public by the data subject,
• The information requested by the data subject being publicly available,
• The data subject making requests that require disproportionate effort,
• Processing of personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to ensure national defense, national security, public security, public order, or economic security,
• Processing of personal data by judicial authorities or enforcement offices in relation to investigation, prosecution, trial or enforcement proceedings,
• Processing of personal data being necessary for preventing a crime or for a criminal investigation,
• Processing of personal data being necessary for the execution of supervisory or regulatory duties and disciplinary investigation or prosecution by authorized public institutions and organizations and professional organizations having the status of public institutions, based on the authority granted by law,
• The existence of indications based on concrete reasons that the data subject’s request would hinder the rights and freedoms of others,
17. REFERENCE
This Policy is implemented together with the POLICY ON THE PROCESSING OF PERSONAL DATA FOR TEKS-PRO EMPLOYEES and the PERSONAL DATA RETENTION AND DESTRUCTION POLICY, and other policies in force within Teks-Pro.
In cases not regulated in this Policy, the provisions of the related policies shall apply to the extent that provisions exist and are appropriate.
18. ENTRY INTO FORCE
This Policy enters into force on the date of its publication by Teks-Pro.
Annex 1. General Information Notice
Annex 2. Data Subject Application Form
Annex 3. Candidate Employee Information Notice
Annex 4. Visitor Information Notice
Annex 5. Supplier / Subcontractor / Business Partner Information Notice
Annex 6. Customer Information Notice
Appendix 1 – General Information Notice
Appendix 2 – Data Subject Application Form
To apply,
– Click on the button below and download the Relevant Person Application Form to your computer
– The form must be completed
– It must be sent by registered post with return receipt requested to the postal address provided in Appendix 4 – VISITOR INFORMATION NOTICE, or via notary public, or by email to the email address provided.
Appendix 3 – Prospective Employee Information Notice
As Teks-Pro Promosyon Tekstil Ürünleri San. ve Tic. Ltd. Şti. (Teks-Pro), in our capacity as the data controller, for the purpose of fulfilling the requirements of your employment relationship / employment contract with us and our legal obligations, and in connection with this purpose, we hereby inform you that your personal data will be recorded, stored, retained, reorganized, shared with authorized institutions and transferred to third parties under the conditions stipulated by the KVKK, and may be processed in the ways listed under the KVKK.
1. WHAT PERSONAL DATA OF YOURS IS PROCESSED?
| Criminal record | Enforcement proceeding files, file/debt details, writ responses, payment information | All data included in your resume (CV) (including your references) |
| Address information | Internal promotion evaluation processes and promotion records | Fingerprint records |
| Name-Surname | Administrative leave records | Performance and career development information |
| Family declaration forms (family/relative information) and population registry samples | Rest/medical leave reports | Timesheets and performance reports |
| Advance payment records | Work computer IP addresses and web browsing activity | Health insurance policies |
| Candidacy process records | Interview process records and evaluation notes | Health reports |
| Bank and payment information | Company car location records | Weekly/daily working time records |
| Payrolls | Employment contract | SSI (SGK) records |
| Records regarding notifications of changes in working conditions | Work phone location records | Delivery records for delivered documents, vehicles, equipment, work clothes, etc. |
| Absenteeism records | Employment entry/exit declarations | Compensation records |
| Diploma, certificate, professional qualification, education and skills records | Blood type information | Turkish ID No.; Passport No.; SSI (SGK) No. |
| Records regarding disciplinary processes (complaints, minutes, defense statements, disciplinary sanctions, etc.) | CCTV footage | Phone number |
| Date and place of birth | Accident records | Discharge certificate; military service records |
| Training participation, evaluation, exam, result records, etc. | Copy of identity card | Meeting records |
| Driver’s license blood type and other records included therein | KVKK explicit consent form / information form | Records regarding salary, bonus, etc. fringe benefits |
| E-mail address | Marital status | Annual leave, excused leave records |
| Termination notices | Occupational disease records | Records and documents contained in the personnel file |
| Photograph | All other data included as standard in official identity documents such as national ID cards (including religion and blood type, as contained by default due to the format of such documents) | Documents provided by you |
2. WHAT ARE THE PURPOSES OF PROCESSING YOUR PERSONAL DATA?
Your personal data may be processed for purposes and legal grounds such as, but not limited to, those stated below.
• Fulfilling the purpose required for the performance of the employment contract, in particular;
– Proving the employment relationship and performance of mutual obligations under the employment contract
– Recording salary and salary-related information; conducting and evidencing payroll processes
– Tracking and monitoring sick leave, excused leave and annual leave
– Tracking absenteeism
– Tracking disciplinary processes
– Tracking working hours such as start/end times and use of break periods
– Managing legal processes
– Monitoring and tracking compliance with the rules on the employee’s use of computer, internet, e-mail, phone and vehicle, in accordance with and limited to the performance of the employment contract and the performance of work for these purposes.
• Fulfilling requirements under the Labor Law, Occupational Health and Safety Law, Social Security Law and other relevant legislation, in particular;
– Complying with legally required data retention, reporting and notification obligations
– Responding to and fulfilling requests of authorized institutions and authorities such as court decisions and Enforcement Offices
– Fulfilling obligations arising from social security legislation for these purposes.
• Ensuring security within the company, in particular;
– Recording images via cameras placed in operation areas, lockers where employees’ personal belongings are stored, fire escape points, building/department entry-exit points and rest rooms, as required by physical security procedures (e.g., detection of theft, incidents/arguments in the workplace, detection of unauthorized entry, etc.) for these purposes.
• Due to the necessity arising from the performance of customer contracts, in particular;
– For the purpose of performing the contract with the customer
– For the purpose of fulfilling legal procedures required by the contract with the customer
– Evaluating the quality of services provided; providing training to employees for these purposes.
• For the purpose of company management, conducting business, and implementing company policies, in particular;
– Evaluating employees’ working methods in operations; implementing promotion processes
– Issuing powers of attorney
– Keeping accounting records; making salary and other legal payments; making mandatory private pension (BES) deductions, etc.
– Conducting information security audits
– Ensuring the operation of company systems and workplace order
– Granting authorizations for access to software and files; developing and operating software
– Internal reporting and record keeping
– Improving relationships and motivation among employees
– Managing and tracking shifts
– Tracking training processes and organizing trainings
– Increasing efficiency
– Management, improvement and organization related to social and fringe benefits
– Managing door/system entry-exit; ensuring physical workplace security
– Ensuring and auditing occupational health and safety
– Providing transportation/shuttle services
– Representing the company; maintaining contact with third parties on behalf of the company
– Detailed review of the company workforce subject to confidentiality undertakings
– Timely identification of unlawful acts
– Development and management of the software and applications used/to be used for the company by third-party companies.
3. WHAT IS THE RETENTION PERIOD FOR YOUR PERSONAL DATA?
Your personal data will be retained for the period specified in the relevant legislation or required for the purpose for which it is processed.
4. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES DOMESTICALLY
• For your security and for our company to fulfill its obligations under the laws, your personal data may be shared pursuant to:
– Labor Law,
– Occupational Health and Safety Law,
– Social Insurance and General Health Insurance Law,
– Law on the Regulation of Publications on the Internet and Combating Crimes Committed Through Such Publications,
– Law No. 6698 on the Protection of Personal Data
And, without limitation, to the extent required and permitted by other legislation, with
– Personal Data Protection Authority,
– Ministry of Finance,
– Ministry of Customs and Trade,
– Ministry of Family, Labor and Social Services,
– Social Security Institution (SGK),
– Turkish Employment Agency (İŞKUR),
– Banks
and similar relevant institutions and organizations, public and private legal entities.
(For example; employees’ personal data is shared with SGK in order to pay employee and employer premiums, and with banks in order to pay your salary.)
• Your personal data may be shared with third parties such as companies from which Teks-Pro provides/receives goods and services, HR consultancy companies, information technologies companies, professional advisors, lawyers, accountants, occupational health and safety institutions, and institutions with which Teks-Pro has a commercial, administrative or contractual relationship.
(For example, upon request of our customers to whom we provide services, personal data of employees working in the relevant operation is shared with customer companies.)
5. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES ABROAD
Your personal data may be transferred, in compliance with the KVKK, particularly where Teks-Pro has a legitimate interest that does not harm the fundamental rights and freedoms of the employee (data subject) in sharing the data, or where the performance of the contract requires it, and provided that other legal conditions are met where third parties are located in countries with adequate protection or without adequate protection.
6. WHAT ARE YOUR RIGHTS AS A DATA SUBJECT UNDER ARTICLE 11 OF THE KVKK?
• Pursuant to Article 11 of the KVKK, your rights regarding your personal data are as follows. For matters related to these rights, you may apply IN PERSON to our Human Resources Department as your employer, OR to the postal/e-mail address below.
a) To learn whether your personal data is processed,
b) To request information if your personal data has been processed,
c) To learn the purpose of processing your personal data and whether they are used in accordance with such purpose,
ç) To know the third parties to whom your personal data is transferred domestically or abroad,
d) To request the correction of incomplete or inaccurate personal data,
e) Pursuant to KVKK Article 7, to request the deletion or destruction of your data if the reasons requiring processing cease to exist,
f) To request notification of the transactions carried out pursuant to (d) and (e) to third parties to whom personal data has been transferred,
g) To object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems,
ğ) To request compensation for damages in case of loss due to unlawful processing,
• Your requests stated in your application will be finalized within thirty (30) days at the latest, depending on the nature of the request.
• We kindly request that you attach to your application all information and documents that may be relevant within the scope of your application.
• THE CONTACT INFORMATION YOU MAY USE FOR YOUR APPLICATIONS IS AS FOLLOWS.
Our Postal Address: Namık Kemal Mh. Değirmen Sk. No:53 Ümraniye 34762 Istanbul, Türkiye
Our E-mail Address: info@tekspro.com.tr
REV00
Appendix 4 – Visitor Information Notice
1. The Data Controller’s Identity and Contact Information is provided below.
Data Controller: Teks-Pro Promosyon Tekstil Ürünleri San. ve Tic. Ltd. Şti.
Postal Address: Namık Kemal Mh. Değirmen Sk. No:53 Ümraniye 34762 Istanbul, Türkiye
E-mail Address: info@tekspro.com.tr
2. As Teks-Pro;
Depending on the circumstances, your personal data that we request and/or that you share with us;
will be processed within the scope of the purposes requiring such processing and in a manner that is limited and proportionate to these purposes, and in connection with them.
We hereby inform you that your personal data will be recorded, stored, retained, reorganized, and shared with institutions legally authorized to request such data, and that, under the conditions stipulated by the KVKK, it will be transferred only domestically to the company providing security services to our company, and may otherwise be processed in the ways set out under the KVKK.
3. The method of collection of visitor data is as follows.
We collect your personal data via cameras installed in our premises and through information you provide to us verbally or in physical form.
4. The personal data that may be processed regarding visitors by us is as follows:
– Name – Surname / Title
– Vehicle Information
– Entry/Exit Records
– Camera Footage
– Information on your business card (if you share it)
– The organization you work for / represent / on behalf of which you visit
5. The purposes of processing visitor data are as follows.
For ensuring the safety of Teks-Pro, our visitors and our employees, and as required by physical security procedures;
– Visitor registration is carried out.
– In operation areas, fire escape points, building/department entry-exit points, and rest areas, CAMERA RECORDINGS OF EMPLOYEES AND VISITORS ARE TAKEN.
6. Your personal data is retained for the period specified in the relevant legislation or required for the purpose for which it is processed.
7. Sharing visitor data with third parties
Your data is not shared with unrelated third parties. Visitor data is shared with the supplier company providing security services to our company and, upon request of public/judicial authorities, with the relevant public/judicial authorities. Your data is not shared with third parties abroad.
8. Your rights as a data subject under the KVKK are as follows.
Pursuant to Article 11 of the KVKK regarding your personal data; BY APPLYING IN PERSON AND/OR TO THE POSTAL ADDRESS ABOVE AND/OR TO THE E-MAIL ADDRESS ABOVE
– To learn whether the Company processes your personal data and, if so, to request information about it,
– To learn the purpose of processing your personal data and whether they are used in accordance with such purpose,
– To learn whether the data is transferred domestically or abroad and to whom it is transferred,
– To request the correction of your incorrect/incomplete data and to request that recipients to whom the data has been/would have been transferred be informed,
– To request the deletion/destruction of your personal data within the framework of the conditions set out in KVKK Article 7,
– To request that third parties to whom the data has been/would have been transferred be informed about such deletion/destruction,
– To object if the results of your personal data analysis created exclusively by using an automated system are against your interests,
– To request compensation for damages if you suffer loss due to unlawful processing of your personal data YOU HAVE THESE RIGHTS!
– Your requests in your application will be finalized within thirty (30) days at the latest, depending on the nature of your request.
– The data subject must clearly specify which right is being exercised in the application and submit any relevant information/documents together with the application, if any.
– YOUR APPLICATIONS MUST BE SENT TO THE POSTAL ADDRESS ABOVE BY REGISTERED MAIL WITH RETURN RECEIPT OR VIA A NOTARY, OR TO THE E-MAIL ADDRESS ABOVE BY E-MAIL.
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Appendix 5 – Supplier / Subcontractor / Business Partner Information Notice
1. The Data Controller’s Identity and Contact Information is provided below.
Data Controller: Teks-Pro Promosyon Tekstil Ürünleri San. ve Tic. Ltd. Şti.
Postal Address: Namık Kemal Mh. Değirmen Sk. No:53 Ümraniye 34762 Istanbul, Türkiye
E-mail Address: info@tekspro.com.tr
2. As Teks-Pro;
In a manner that is related to the purpose of processing, limited and proportionate; depending on the circumstances, your personal data that we request and/or that you share with us, within the framework of the purposes requiring their processing;
We hereby inform you that such personal data will be recorded, stored, retained, reorganized, shared with institutions legally authorized to request such personal data, and transferred domestically under the conditions stipulated by the KVKK, and may otherwise be processed in the other ways listed under the KVKK.
3. The personal data that may be subject to processing within the scope of our business relationship and working practices with you is as follows:
| Identity Data | Name–surname; date of birth, place of birth, copies of national ID card, driver’s license and identity documents, and the identity data contained therein |
| Personnel Data | Personnel file data required, limited to the purpose of fulfilling our responsibilities as the principal employer within the principal employer–subcontractor relationship, such as the names, surnames and SSI (SGK) records of our subcontractors’ employees and authorized persons |
| Contact Data | Address; e-mail address, phone number, fax number |
| Financial Data | Bank account details, tax office and tax number information, payment records |
| Professional Data | Professional experience, title, education data |
| Visual and Audio Data | Photographs of natural persons, camera recordings |
| Other | Vehicle license plate and vehicle records |
| Other | All personal data related to and limited to the establishment, performance and termination of the contract |
4. As Teks-Pro, we collect your personal data in the following ways.
– From you and/or other representatives/employees of the legal entity you represent;
– By receiving personal data verbally, in physical or electronic form, and via cameras installed at Teks-Pro premises, in physical or electronic form.
5. Your personal data may be processed by Teks-Pro for the purposes and legal grounds stated below.
– Enabling the execution of the business relationship/contracts between you and Teks-Pro and fulfilling their terms and conditions,
– Performance of works related to the goods and services provided to Teks-Pro by you or the legal entity you represent,
– Ensuring communication,
– Within the scope of the business relationship/contract between you and Teks-Pro; quality control and evaluation of the service/performance/goods you provide,
– Keeping finance and accounting records and carrying out payment transactions,
– Receiving support/feedback from subcontractor/supplier employees,
– Being necessary for the implementation of Teks-Pro’s policies in force,
– Being mandatory for the legitimate interests of Teks-Pro, provided that your rights are not harmed,
– Fulfilling our legal obligations as Teks-Pro,
– Establishment, performance and termination of the contract and protection of Teks-Pro’s rights,
– Fulfilling legal obligations such as ensuring and auditing occupational health and safety.
Your personal data will be retained for the period specified in the relevant legislation or required for the purpose for which it is processed.
6. Sharing of Your Personal Data with Third Parties
Your personal data is not shared with unrelated third parties.
Your personal data may be shared, to the extent and frequency required by the business/contractual relationship between the parties, with our professional advisors, accountants and financial advisors, auditors, companies providing information technologies and archiving services, occupational health and safety institutions and experts from whom we receive services to fulfill our legal obligations, institutions with which Teks-Pro has a commercial, administrative or contractual relationship, banks, and public/judicial authorities, as well as other third parties domestically or abroad.
7. WHAT ARE YOUR RIGHTS AS A DATA SUBJECT UNDER ARTICLE 11 OF THE KVKK?
Pursuant to Article 11 of the KVKK, regarding your personal data; BY APPLYING IN PERSON AND/OR TO THE POSTAL ADDRESS ABOVE AND/OR TO THE E-MAIL ADDRESS ABOVE
– To learn whether Teks-Pro processes your personal data and, if so, to request information about it,
– To learn the purpose of processing your personal data and whether they are used in accordance with such purpose,
– To learn whether your data is transferred domestically or abroad and to whom it is transferred,
– To request the correction of incorrect/incomplete data and to request that recipients to whom the data has been/would have been transferred be informed,
– To request the deletion/destruction of your personal data within the framework of the conditions set out in KVKK Article 7,
– To request that third parties to whom the data has been/would have been transferred be informed about such deletion/destruction,
– To object if the results of your personal data analysis created exclusively by using an automated system are against your interests,
– To request compensation for damages if you suffer loss due to unlawful processing of your personal data YOU HAVE THESE RIGHTS!
– Your requests stated in your application will be finalized within thirty (30) days at the latest, depending on the nature of the request.
– The data subject must clearly specify which right is being exercised in the application and submit any relevant information/documents together with the application, if any.