PERSONAL DATA PROTECTION AND PROCESSING POLICY AND INFORMATION NOTICE
CONTENTS
- Introduction
- Purpose
- Scope
- Purposes of Personal Data Processing by the Data Controller
- Principles of Personal Data Processing
- Conditions for Processing Personal Data
- Ensuring the Security of Personal Data
- Rights of the Data Subject and Application Procedure
- Retention Periods and Destruction Method
- Groups of Data Subjects and Data Categories
- Transfer of Personal Data
- Camera Monitoring Activities in Buildings and Facilities
- Effective Date
Introduction
Under Article 20 of the Constitution of the Republic of Türkiye, everyone has the right to request the protection of personal data concerning them. In accordance with this constitutional right, this Personal Data Protection Policy has been prepared by Çakırbaylar Tekstil Turizm Nak. San. ve Tic. Ltd. Şti. (“Çakırbay Tekstil”) as Data Controller in order to securely manage and protect the personal data processed in relation to employees, job applicants, interns, suppliers and their employees, subcontractors and their employees, customers, third parties and visitors.
Çakırbay Tekstil takes the administrative and technical measures required under Law No. 6698 on the Protection of Personal Data (“KVKK”) and secondary legislation.
Purpose
The main purpose of this Policy is to ensure the security of personal data processed lawfully, by automated means or by non-automated means provided that they form part of a data recording system, through appropriate administrative and technical measures, particularly for employees and for natural persons with whom the company has legal or commercial relations.
Scope
This Policy covers all personal data processed by Çakırbay Tekstil relating to employees, customers, subcontractors, subcontractor employees, suppliers, supplier employees, job applicants, interns, third parties, visitors and other natural persons in a business relationship with the company.
Purposes of Personal Data Processing by the Data Controller
Personal data may be processed for carrying out corporate sustainability activities; managing supplier and subcontractor relations; conducting recruitment processes; carrying out internal audit and legal processes; corporate management and communication; managing requests and complaints; providing information to authorized persons or institutions as required by law; and creating and monitoring visitor records. Where none of the processing conditions under Law No. 6698 applies, explicit consent is obtained from the data subject.
Principles of Personal Data Processing
- Processing lawfully and fairly.
- Keeping data accurate and, where necessary, up to date.
- Processing for specified, explicit and legitimate purposes.
- Processing in a manner relevant, limited and proportionate to the purpose.
- Retaining data only for the period prescribed by law or required for the purpose.
- Informing data subjects and establishing mechanisms for exercising their rights.
- Taking appropriate measures for storage and security.
- Complying with applicable legislation and Personal Data Protection Board rules when transferring data to third parties.
- Applying enhanced care to special categories of personal data.
Conditions for Processing Personal Data
Personal data is processed where processing is expressly provided for by law; necessary for the establishment or performance of a contract; necessary for compliance with a legal obligation; made public by the data subject; necessary for the establishment, exercise or protection of a right; necessary for the legitimate interests of Çakırbay Tekstil provided that fundamental rights and freedoms are not harmed; or necessary to protect the life or physical integrity of the data subject or another person where consent cannot be expressed due to actual impossibility or legal incapacity.
Ensuring the Security of Personal Data
Çakırbay Tekstil takes technical and administrative measures appropriate to current technology and practice to ensure lawful processing and secure storage of personal data. Systems used for processing are supervised by information technology specialists; technical measures are periodically reviewed and reported to senior management; employees receive awareness and training; business processes, data inventories, processor roles and responsibilities are identified; contractual confidentiality and data-processing obligations are implemented; access authorizations and matrices are restricted and reviewed; anti-virus systems, firewalls, security scanning, lawful backup processes and access logging are used. Employees and business partners are informed that personal data may not be disclosed, used or shared unlawfully or outside its intended purpose, and contractual safeguards are applied to subcontractors and suppliers.
Rights of the Data Subject and Application Procedure
Under Article 11 of Law No. 6698, data subjects may learn whether their personal data is processed; request information if it has been processed; learn the purpose of processing and whether it is used accordingly; learn the third parties to whom data is transferred in Türkiye or abroad; request correction of incomplete or inaccurate data; request deletion or destruction where the legal conditions are met; object to a result arising against them through analysis exclusively by automated systems; and claim compensation for damage resulting from unlawful processing.
To exercise these rights, data subjects may use the “Application Form” available at https://www.cakirbaytekstil.com and the methods specified in that form. Applications will be concluded free of charge within no later than thirty days depending on the nature of the request, subject to statutory exceptions.
Retention Periods and Destruction Method
Personal data is retained for the periods prescribed by applicable law, legislation and the company’s Personal Data Retention and Destruction Policy. If no specific period is prescribed, data is retained for the period required by business practices and the company’s commercial activities, then deleted, destroyed or anonymized. Data may be retained after the original processing purpose has ended where necessary as evidence in a potential legal dispute, to assert a related right or to establish a defense; in such cases access is limited to that legal purpose. At the end of the retention period, appropriate technical destruction methods are used. Camera recordings are deleted every 30 days.
Groups of Data Subjects and Data Categories
The Policy covers employees, job applicants, interns, suppliers and supplier employees, subcontractors and subcontractor employees, third parties and visitors. Depending on the relationship and applicable law, processed categories may include identity, contact, location, family/relationship, criminal record, visual, education, financial, personnel, health, biometric and signature data. Only categories relevant to the particular business relationship and legal basis are processed.
Transfer of Personal Data
In accordance with Articles 8 and 9 of Law No. 6698, personal data may be transferred, where legally permitted and necessary, to senior officials and authorized personnel of Çakırbay Tekstil, legally authorized public persons, institutions and organizations, and legally authorized private-law persons. Çakırbay Tekstil states that it does not transfer the personal data processed under this Policy abroad.
Applicable legislation on the processing and protection of personal data takes precedence. In the event of inconsistency between legislation and this Policy, current legislation applies. The Policy may be updated in line with legal changes and company policies, and updated versions are announced on the website. The website uses cookies intended to monitor online visitors’ site usage habits.
Camera Monitoring Activities in Buildings and Facilities
Camera monitoring is carried out in accordance with the Law on Private Security Services, relevant legislation, Law No. 6698 and the company’s Camera Monitoring Policy in order to protect company security and the health and safety of persons. Data subjects are informed in accordance with Article 10 of Law No. 6698, and recordings are not shared with anyone other than authorized persons, institutions or organizations.
Effective Date
This Policy implemented by Çakırbaylar Tekstil Turizm Nak. San. ve Tic. Ltd. Şti. entered into force on 25 November 2023.
PERSONAL DATA PROTECTION AND PROCESSING INFORMATION NOTICE
As Data Controller, Çakırbaylar Tekstil Turizm Nak. San. ve Tic. Ltd. Şti. carries out the processes required to inform data subjects at the time personal data is obtained, in accordance with Article 10 of Law No. 6698 and the Communiqué on the Procedures and Principles to Be Followed in Fulfilling the Obligation to Inform.
The company’s Personal Data Protection and Processing Policy and information notices explain the company identity, processing purposes, possible recipients and transfer purposes, collection methods and legal grounds, and data subject rights. Personal data of employees, job applicants, interns, suppliers and their employees, subcontractors and their employees, third parties and visitors is processed lawfully and fairly; accurately and, where necessary, up to date; for specified, explicit and legitimate purposes; and in a relevant, limited and proportionate manner. Appropriate administrative and technical measures are implemented.
Personal data is processed for corporate sustainability, management of supplier and subcontractor relations, recruitment, internal audit and legal processes, corporate management and communication, request and complaint management, statutory disclosures to authorized persons or institutions, and visitor registration and monitoring. Where the conditions prescribed by Law No. 6698 are not met, explicit consent is obtained.
General and special-category personal data may be transferred to authorized persons, institutions and organizations in accordance with Article 8 of Law No. 6698 and subject to necessary security measures. The company states that it does not transfer personal data abroad.
Data subjects may exercise the rights listed in Article 11 of Law No. 6698 using the “Application Form” on https://www.cakirbaytekstil.com. Applications made in accordance with the procedure will be answered within no later than thirty days according to the nature of the request.
The website uses cookies intended to monitor online visitor usage habits. The current Turkish notice also states that the personal data of website visitors is not otherwise processed.
Çakırbaylar Tekstil Turizm Nak. San. ve Tic. Ltd. Şti.
Address: Tekstil OSB Mah. 120. Cd. No: 500, 64000 – Merkez/UŞAK
E-mail: info@cakirbaytekstil.com
Tel: 0 276 231 39 78