GENERAL PRIVACY NOTICE
As AGEMAR GLOBAL LOJ. DEN. TUR. PAZ. VE TIC A.S. (the “Company”), acting as data controller, and in line with the importance we attach to the security of your personal data, all personal data held within our organization are processed, stored, and transferred in accordance with Law No. 6698 on the Protection of Personal Data (“KVKK”). With this awareness, as a company, we attach great importance to the processing and protection, in accordance with Law No. 6698 on the Protection of Personal Data, of the personal data of our customers, prospective customers, suppliers, supplier employees, consultants, other third parties whose personal data are processed within the scope of contractual and business relationships, supplier/subcontractor employees and authorized representatives, our company partners, and our visitors. Conscious of this responsibility, in our capacity as “Data Controller” as defined under the Personal Data Protection Law, we process your personal data as explained below and within the limits set out in the legislation.
This privacy notice has been prepared by our Company in accordance with Article 10 of the KVKK, titled “Data Controller’s Obligation to Inform”, and the Communique on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform, with respect to your personal data collected, stored, and processed by our Company.
The concepts of personal data, special categories of personal data, data processing, relevant person, and data controller used in this privacy notice are used based on the definitions set out in the KVKK.
Under the KVKK, “Personal Data” means any information relating to an identified or identifiable natural person; and “Processing of Personal Data” means any operation performed on personal data, such as obtaining, recording, storing, retaining, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying, or preventing the use of personal data, whether wholly or partly by automatic means or by non-automatic means provided that it is part of a data filing system.
Special Categories of Personal Data: Data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, association, foundation or trade union membership, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data, are special categories of personal data.
Relevant Person: Natural-person customers, employees, employee candidates, suppliers and their employees, partners, and other third-party natural persons within the scope of contracts concluded with the Institution whose personal data are processed. Our employees whose data are processed in our Company are defined as relevant persons under the Law.
Data Controller: The data controller is the person who determines the purposes and means of processing personal data and establishes and manages the data filing system in which data are systematically processed and stored. Our Company, AGEMAR GLOBAL LOJ. DEN. TUR. PAZ. VE TIC A.S., which determines the purposes and means of processing personal data relating to our employees and is responsible for establishing and managing the data filing system, is the data controller.
PURPOSES OF PROCESSING YOUR PERSONAL DATA
Within the scope of Article 4 of the Personal Data Protection Law, which sets out the General Principles, your personal data are categorized and processed for the purposes below in accordance with the principles of being processed lawfully and fairly, being accurate and, where necessary, up to date, being processed for specified, explicit, and legitimate purposes, being relevant, limited, and proportionate to the purposes for which they are processed, and being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed:
Your identity information: name, surname, date of birth, place of birth, Turkish Republic identity card information, and identity number.
Your contact information and address: residential address, business address, telephone number, mobile telephone number, e-mail address, and KEP address.
To perform business and transactions relating to signed contracts and to manage relationships with business partners, consultants, and suppliers,
To fulfil legal obligations as required or made mandatory by legal regulations and to maintain contact with natural/legal persons who have a business relationship with the Company,
To carry out procurement processes for goods and services and to manage retention and archive activities,
For the purposes of planning and carrying out corporate communication and management activities,
Your financial information (tax number, tax office, bank account number, bank IBAN number, invoice and e-invoice date, service document number, service fee, invoice registration number, payment date, and payment method), together with your identity and contact information, are processed for the purposes of creating accounting records and current account cards, carrying out finance and accounting affairs, making payments, and conducting operational processes.
Your legal transaction information is collected and processed for the purposes of fulfilling our legal obligations towards authorized and competent public institutions and organizations and courts, and for use as evidence in disputes that may arise between us.
Your visual records processed through cameras are collected and processed for the purposes of ensuring physical premises security and creating and monitoring visitor records.
TRANSFER OF YOUR PERSONAL DATA TO THIRD PARTIES AND PURPOSE OF TRANSFER
The Company acts in accordance with the regulations set out in Articles 8 and 9 of the Law regarding the transfer of personal data and with the legislative principles published by the Personal Data Protection Authority.
Within the scope of Article 5 of the Law, the Company may transfer data subjects’ data without obtaining explicit consent in the following cases:
ARTICLE 5 – (1) Personal data may not be processed without the explicit consent of the person concerned.
(2) Personal data may be processed without seeking the explicit consent of the person concerned if one of the following conditions exists:
- a) It is expressly provided for by law.
- b) It is necessary for the protection of the life or bodily integrity of the person who is unable to express consent due to actual impossibility or whose consent is not legally valid, or of another person.
- c) Processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract.
ç) It is necessary for the data controller to fulfil its legal obligation.
- d) The data have been made public by the person concerned.
- e) Data processing is necessary for the establishment, exercise, or protection of a right.
- f) Processing of data is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.
Your personal data may be transferred, within the scope of the Law and other legislation and for the limited purposes stated above, to the General Directorate of Security and other law enforcement authorities; all judicial authorities; your authorized representatives; attorneys; third parties from whom we receive consultancy, including tax and financial advisers; regulatory and supervisory authorities; group companies; consultants and advisers with whom we have a business relationship; suppliers of goods and services; public institutions and organizations within the scope of legal obligations arising from the activity; professional organizations; and other organizations defined by legislation.
METHOD AND LEGAL GROUND FOR COLLECTING YOUR PERSONAL DATA
Your personal data are collected in electronic and physical environments pursuant to Article 5/2-d of the KVKK, provided that they are within the scope of a business relationship, through information you provide by e-mail, WhatsApp, social media, internet, and other digital channels; information requested directly from you; your contract information; financial, legal, commercial, and fiscal information; invoice information; digital applications made through our websites; petitions and applications; legal notifications; and application information submitted to our Company under Article 11 of the KVKK, and are retained within the scope of legal periods and the requirements of the work.
Your personal data are collected and processed on the basis of at least one of the following legal grounds under the Personal Data Protection Law and, where necessary, explicit consent: Article 5/2-c: “Processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the establishment or performance of the contract”,
Article 5/2-ç of the Personal Data Protection Law: “It is necessary for the data controller to fulfil its legal obligation”,
Article 5/2-d of the Personal Data Protection Law: “The data have been made public by the person concerned”,
Article 5/2-e of the Personal Data Protection Law: “Data processing is necessary for the establishment, exercise, or protection of a right”. Our Company does not collect data without a valid purpose and a valid legal ground or without applying explicit consent where required.
YOUR RIGHTS
In accordance with Article 10 of the Personal Data Protection Law, the Company informs personal data subjects of their rights and guides them on how to exercise these rights. The rights of the relevant person set out in Article 11 of the KVKK are listed below.
Rights of the relevant person
ARTICLE 11 – (1) Everyone has the following rights by applying to the data controller regarding himself or herself:
- a) To learn whether personal data are processed,
- b) To request information if personal data have been processed,
- c) To learn the purpose of processing personal data and whether they are used in accordance with that purpose,
ç) To know the third parties to whom personal data are transferred in Turkey or abroad,
- d) To request correction if personal data have been processed incompletely or inaccurately,
- e) To request deletion or destruction of personal data within the framework of the conditions set out in Article 7,
- f) To request notification of the operations carried out pursuant to subparagraphs (d) and (e) to third parties to whom personal data have been transferred,
- g) To object to the occurrence of a result against the person himself or herself through analysis of the processed data exclusively by automated systems,
ğ) To request compensation for damage suffered due to the unlawful processing of personal data,
rights.
If you wish to exercise your right to apply:
You may submit your application in writing with a wet signature by hand delivery to our Company’s address at Kore Sehitleri Cd. Yaprak Apt. No:39 K:3 D:8 Zincirlikuyu Sisli/Istanbul; send it through a notary public; or send it to agemarglobal@hs01.kep.tr (KEP) with a secure electronic signature or through the e-mail address previously notified by you to our Company and registered in our Company’s system.agemarglobal@hs01.kep.tr
The requests included in your application will be concluded free of charge within thirty (30) days at the latest, depending on the nature of the request.
DATA CONTROLLER INFORMATION
Data Controller Company Title : AGEMAR GLOBAL LOJ. DEN. TUR. PAZ. VE TIC A.S.
Telephone Number : 0212 347 70 71
E-mail : info@agl-agemar.com
Address : Kore Sehitleri Cd. Yaprak Apt. No:39 K:3 D:8 Zincirlikuyu Sisli/Istanbul
KEP Address : agemarglobal@hs01.kep.tragemarglobal@hs01.kep.tr