SINPAS HOLDING CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA
This Information and Clarification Form has been prepared within the scope of processing and transferring the "Personal Data" of real persons regulated by the Law on Protection of Personal Data No. 6698 (“KVK Law”). Within the scope of the Law No. 6698, any up-to-date information about you that you have shared with our company will be considered as "Personal Data". The security of your personal data is of great importance to us, and your personal data will be stored in accordance with the conditions stipulated by the legislation, in the safest possible way and for the period required by legal obligations, in accordance with the legislation.
a) Data Controller and Representative
In accordance with the Law No. 6698 on the Protection of Personal Data (“KVK Law”), your personal data may be processed by Sinpaş Holding (shortly Sinpaş) as the “Data Controller” within the scope of the following:
b) For What Purpose Your Personal Data Can Be Processed
Your personal data collected may be processed within the personal data processing conditions and purposes specified in Articles 5 and 6 of Law No. 6698 with the purpose of fulfillment of the obligations of our company and real and legal persons who have a business relationship with our company, informing about updates, reminding and fulfilling legal obligations with the establishment and performance of contracts to be made with you, engaging in various advertising and marketing activities, execution and follow-up of finance, accounting and legal affairs, follow-up of your requests and complaints - follow-up of contract processes and/or legal requests, receiving your opinion with surveys and voting within the scope of planning and execution of customer satisfaction activities, determining suitable products, projects and services for you, customizing and developing them, providing effective customer service, notifying you of changes in legislation, internal company policies or making other notifications that concern you, birthday celebration, inclusion in sweepstakes or contests, giving gifts and any other similar activity in your favor, realization of promotions and campaigns, informing you by e-mail, SMS and fax, informing you about the campaigns, to send you printed newsletters, magazines, articles on campaigns, determining our visitor profiles, evaluating requests, demands and complaints and executing our company's human resources policies, answering your requests and questions.
c) To Whom and For What Purpose the Processed Personal Data Can Be Transferred
Your collected personal data is processed in accordance with the principles of keeping it for the period required by the relevant legislation or for the purpose for which it is processed, in accordance with the rules of law and honesty, accurately and when necessary, processed for current, specific, clear and legitimate purposes, in connection with the purpose for which they are processed, limited and measured. In addition, provided that they comply with the conditions stipulated in Articles 8 and 9 of the KVK Law and take the necessary security measures, limited to the purposes listed under item (b) of this notice, they may be shared within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law No. 6698 with our indirect/direct domestic/foreign affiliates or subsidiaries, domestic/foreign/international, public/private institutions and organizations, companies and other 3rd persons or organizations that our company receives service/support/consultancy or cooperates with or becomes a project/program/financing partner, our company's subsidiaries, affiliates, consultants, shareholders or solution partners, other group companies, Central Registry Agency and other authorized institutions and organizations, suppliers or subcontractors. On the condition of taking the necessary security measures, provided that there is adequate protection in Turkey or in the foreign country to which the personal data will be transferred,if there is not sufficient protection in the relevant foreign country, SİNPAŞ and the data controllers in the relevant foreign country may process and store it on servers located abroad or in other electronic media, provided that they undertake an adequate protection in writing and that the Board has permission.
ç) Collection Method of Your Personal Data and its Legal Reason
Your personal data, can be obtained by our Company through different channels (SİNPAŞ's headquarters, branches, agencies, sales offices or other subcontractors oroffice and other physical environments where you can communicate with business partners, call centers, websites, mobile applications and similar electronic transaction platforms, through social media or other public channels,with your participation in training, conferences and similar environments they will organize, through the method of investigation or other group companies or other people and organizations they have contracted with, in written, oral, audio or video recording or other physical or electronic media, etc.). Your personal data may be collected, processed, transferred and stored for the purposes specified in articles (b) and (c) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVK Law. Your Personal Data is stored for the period required by legal obligations or for the period allowed in the relevant legislation, in accordance with the legislation.
d) Your Rights as a Personal Data Owner
As personal data owners, if you submit your requests regarding your rights to our Company through the methods set out below, our Company will conclude your request free of charge as soon as possible and within thirty days at the latest, depending on its nature. However, if a fee is stipulated by the Personal Data Protection Board, the fee in the tariff determined by our Company will be charged.In this context, personal data owners have the following rights;
• Learning whether personal data is processed,
• If personal data has been processed, requesting information about it,
• Learning the purpose of processing personal data and whether they are used in accordance with the purpose,
• Requesting correction of personal data in case of incomplete or incorrect processing and requesting notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
• Requesting the deletion or destruction of personal data in the event that the reasons requiring processing are eliminated, although it has been processed in accordance with the provisions of the KVK Law and other relevant laws, and requesting the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
• Requesting the deletion or destruction of personal data in the event that the reasons requiring processing are eliminated, although it has been processed in accordance with the provisions of the KVK Law and other relevant laws, and requesting the notification of the transaction made within this scope to the third parties to whom the personal data has been transferred,
• Objecting to the emergence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,
• Requesting the compensation of the damage in case of loss due to unlawful processing of personal data.
In accordance with paragraph 1 of Article 13 of the KVK Law, you can send your request in writing to our Company to exercise your above-mentioned rights. By filling out the form at www.sinpas.com.tr, including your request containing your explanations about your
right that you request to exercise from the rights specified in Article 11 of the KVK Law, you can send a wet-signed copy of the form, addressed to SINPAS Customer Relations Department, "Dikilitaş Mah. Yenidogan Sok. Sinpaş Plaza No:36 Dikilitaş-Beşiktaş/İSTANBUL ” by hand with the documents identifying your identity or through a notary public.
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