KVKK

CLARIFICATION TEXT ON THE LAW ON THE PROTECTION OF PERSONAL DATA

1. Information Text on Protection and Processing of Personal Data

1.1. In order to protect the fundamental rights and freedoms of individuals, especially the privacy of private life, in the processing of personal data and to determine the obligations of natural and legal persons who process personal data, we, as YATIRIRIM UK LIMITED, as Data Controller, provide information in accordance with Article 10 of the Law titled ’Obligation of Data Controller to Inform“ regarding the Personal Data Protection Law No. 6698 (KVKK) published in the Official Gazette dated 7 April 2016 and numbered 29677.

1.2. YATIRIRIM UK LIMITED has been prepared in order to ensure that the personal data of our citizens are processed in accordance with the Constitution of the Republic of Turkey and the international conventions on Human Rights to which our country is a party and the relevant legislation, especially the Law No. 6698 on the Protection of Personal Data (KVKK), and to ensure that the relevant persons whose data are processed can effectively exercise their rights. All personal data shared with our company can be processed in accordance with the law, in connection with our activities and service purposes and in a measured manner.

2. Definitions

2.1. The concepts of personal data, sensitive personal data and data processing used in the clarification text are used in accordance with the definitions made in the KVKK. In the KVKK;

2.1.1. Personal Data Protection Law (“KVKK”): Law No. 6698 on the Protection of Personal Data, which entered into force after being published in the Official Gazette on 7 April 2016,

2.1.2. Personal Data: Any information relating to an identified or identifiable natural person,

2.1.3. Data Processor: The natural or legal person who processes Personal Data on behalf of the Data Controller based on the authorisation granted by the Data Controller,

2.1.4. 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,

2.1.5. Processing of personal data: The concept refers to all kinds of operations performed on personal data, such as obtaining, recording, storing, retaining, modifying, reorganising, 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 they are part of any data recording system

3. Principles of Processing Personal Data

3.1. Personal data belonging to the data subject specified in Article 4 of the KVKK; in accordance with the law and good faith, accurate and, where necessary, up-to-date, for specific, clear and legitimate purposes; connected, limited and measured for the purpose for which they are processed; in accordance with the rules of retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed, the data controller will be processed by the Company for the following purposes.

4. Purpose of Processing Your Personal Data

4.1. Your personal data in accordance with Articles 4, 5 and 6 of the KVKK;
4.1.1. In accordance with the law and good faith,
4.1.2. In connection with, limited to and proportionate to the purposes of processing,
4.1.3. Accurate and up-to-date,
4.1.4. It will be processed for certain explicit and legitimate purposes and for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

4.2. Your personal data may be used by our business units to carry out the necessary work to benefit you from the products and services offered by our company; to recommend the products and services offered by our company to you; planning and / or execution of market research activities for the sales and marketing of products and services; planning and / or execution of after-sales support services activities; follow-up of contract processes and / or legal requests, ensuring the legal, technical and commercial business security of the relevant persons in business relations; ensuring the execution of our company's human resources policies, making an evaluation if you apply for a job, fulfilling our legal and legal obligations if you become our employee; Ensuring quality follow-up; follow-up of the products supplied; for the purpose of security and identification of your identity when you visit our business; contacting you if you request information from our company; execution of this contract if you purchase products; Planning, auditing and execution of information security processes; Creation and management of information technology infrastructure; Follow-up of financial and/or accounting affairs; Follow-up of legal affairs; Planning and execution of business activities; Planning and execution of corporate communication activities; For the purposes of determining and implementing the commercial and business strategies of our company, personal data specified in Articles 5 and 6 of Law No. 6698. and 6. of the Law No. 6698 for the purposes of determining and implementing our Company's commercial and business strategies. In addition to the obligations stipulated by the Labour Law and Labour and Social Security legislation and other legislation in force, the data of our employees may be processed by our Company or real or legal persons with whom our Company cooperates or authorised by our Company within the scope of our human resources policy or for operational reasons such as increasing the level of performance and employee satisfaction and ensuring occupational safety and occupational peace.

5. Transfer of Personal Data

5.1. Your personal data may be transferred to our business partners, suppliers, shareholders, affiliates, legally authorised public institutions and private persons within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law No. 6698 to our business partners, suppliers, shareholders, affiliates, legally authorised public institutions and private persons for the purposes of carrying out the necessary work by our business units to benefit you from the products and services offered by our Company; customising the products and services offered by our Company according to your and your company's needs; ensuring the execution of our Company's human resources policies; ensuring the legal and commercial security of our Company and the persons who have a business relationship with our Company; determining and implementing the commercial and business strategies of our Company. and 9. of the Law No. 6698 within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9.

6. Method of Collection of Personal Data and Legal Basis

6.1. Personal data are collected, used, recorded, stored and processed by our company by verbal, written and/or electronic means by providing verbal, written and/or electronic information to personal data owners in a clear and understandable manner and obtaining their explicit consent when necessary, in accordance with the law and good faith, in connection with and limited to the legitimate purposes clearly stated above, within the framework of the principle of proportionality. In addition to this; your personal data is collected for the purpose of improving the products and services we offer and carrying out our commercial activities through different channels and based on different legal reasons within the framework of the commercial purpose of our company, such as contacting us, establishing a contractual relationship, visiting our business, transmitting your information to us for us to contact you for commercial activities, sharing information in promotional organisations. Your personal data collected for this legal reason can also be processed and transferred for the purposes specified in this Clarification Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698.

6.2. In addition, we assure that your personal data will not be processed by our company for purposes other than those specified in this disclosure document, and will not be transferred and stored to third parties in Turkey and abroad.

7. Storage and Deletion of Data:

7.1. Our Company keeps the personal data it processes for the periods specified in the legislation, and if no additional period is specified in the legislation; personal data are stored for the period required to be processed in accordance with the practices and customs of our Company's commercial life, depending on the services provided by our company while processing that data, and after this period, only for the periods required in practice to constitute evidence in possible legal disputes. After the expiration of the specified periods, the personal data in question are deleted, destroyed or anonymised.

8. Rights of the Data Subject

8.1. Data subjects may apply to the Company, acting as the data controller, for any data relating to him/her;
8.1.1. To learn whether his/her personal data is being processed,
8.1.2. To request information if his/her personal data has been processed,
8.1.3. To learn the purpose of processing personal data and whether they are used in accordance with their purpose;
8.1.4. To be informed about third parties to whom personal data are transferred domestically or abroad,
8.1.5. To request correction of personal data in case of incomplete or incorrect processing,
8.1.6. To request the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of KVKK No. 6698,
8.1.7. To request notification of the transactions made pursuant to subparagraphs (d) and (e) of Article 11 of the KVKK to third parties to whom personal data are transferred,
8.1.8. To object to the emergence of a result to the detriment of the person himself/herself by analysing the processed data exclusively through automated systems,
8.1.9. In case of damage due to unlawful processing of personal data, it has the right to demand compensation for the damage.

8.2. In order to use your rights mentioned above, you can send your written request to “www.yatirim.uk/” with the necessary information identifying your identity and your explanations regarding the right you want to use, together with the Personal Data Information retrieval and transaction request form with wet signature or to our registered e-mail address “[email protected]” by using secure electronic signature, mobile signature or the e-mail address previously notified to YATIRIM UK LIMITED by the person concerned and registered in the system of the data controller. Applications must be made in Turkish.

8.3. Applications must include name, surname and signature if the application is in writing, Turkish Republic identification number for citizens of the Republic of Turkey, nationality, passport number/ID number for foreigners, residential or workplace address for notification, e-mail address for notification, telephone or fax number, and the subject of the request.

8.4. In the application containing your explanations regarding the right you have as a personal data owner and that you will make in order to exercise your rights mentioned above and that you request to exercise; the matter you request must be clear and understandable, the subject you request must be related to your person or if you are acting on behalf of someone else, you must be specifically authorised in this regard and your authorisation must be documented, the application must contain identity and address information and documents certifying your identity must be attached to the application.

8.5. Your applications within this scope will be finalised as soon as possible and within 30 days at the latest. If the relevant person's application will be answered in writing, no fee is charged up to ten pages. A transaction fee of 1 TL may be charged for each page over ten pages. If the response to the application is given in a recording medium such as CD, flash memory, the fee that may be requested by YATIRIR UK LIMITED cannot exceed the cost of the recording medium.

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