PURPOSE AND SCOPE OF THE POLICY

 

In order to comply with the Law on the Protection of Personal Data No. 6698 (“KVKK”) published in the Official Gazette dated 07.04.2016 and numbered 29677 and the relevant legal regulations, the procedures and principles adopted and to be implemented by our Company are regulated by this Policy, within the scope of the disclosure obligation of the data controller. 

Regarding your personal data processed by our company; Your personal data processed, the principles of processing personal data, the purposes and conditions of personal data processing, the transfer of your personal data in the country and abroad, the destruction of your personal data and the practices and principles regarding your rights over your processed personal data are given to you below.

Natureza (hereinafter referred to as “Natureza” or “Company”), to comply with the KVKK and other relevant regulations, and to comply with the procedures and processes specified in this Policy in terms of processing, use, destruction, transfer and other matters in accordance with the Law and other regulations. will behave appropriately.

III. PRINCIPLES OF PROCESSING PERSONAL DATA

 

Our company carries out personal data processing activities within the framework of the principles and principles listed below in accordance with Article 4 of the KVKK, which regulates the procedures and principles regarding the processing of personal data.

Compliance with Law and Integrity

Our company processes your personal data in accordance with KVKK and other laws and regulations that are obligatory to comply with the work done.

Being Accurate and Up-to-Date

If the personal data provided by the data owner is not changed without permission and untrue, and when there is a change in the processed data, our company takes the necessary procedures and takes technical and administrative measures to update the personal data, if requested by the data owner.

Processing for Specific, Explicit and Legitimate Purposes

Your personal data processed by our company are processed in accordance with the processing purpose notified to you and within the framework notified.

Connected, Limited, and Measured for the Purpose of Processing

Our company does not process personal data that does not overlap with its activities, is not required within the framework of the company’s activities, and exceeds the purpose of processing.

Retention for the Time Required for the Purpose of Processing or Envisioned in the Relevant Legislation

Your data, which is processed within the framework of KVKK, other relevant laws and regulations, is kept for the periods stipulated in the relevant legislation or required to be kept due to the nature of the processed personal data.

 

PERSONAL DATA PROCESSING CONDITIONS AND EXCEPTIONAL CIRCUMSTANCES

 

– General personal data to be processed within the framework of company activities;

a) Provided that the explicit consent of the data owner is obtained, or
b) which are expressly stipulated in the laws,
c) Obligatory for the protection of the life or physical integrity of the person or another person who is unable to express his consent due to actual impossibility or whose consent is not legally valid,
d) Provided that it is directly related to the establishment or performance of a contract, the processing of the personal data of the parties to the contract is required.
e) Obligatory for the data controller to fulfill its legal obligation
f) Made public by the person concerned,
g) Data processing is mandatory for the establishment, exercise or protection of a right,
h) Provided that it does not harm the fundamental rights and freedoms of the data subject, it may be processed without the explicit consent of the data owner, if there is one of the situations where data processing is mandatory for the legitimate interests of the data controller.

– Personal data of special nature to be processed within the framework of company activities;

a) It will not be processed unless the explicit consent of the data owner is received,
b) Except for sensitive personal data related to health and sexual life, it can be processed without the explicit consent of the data owner in cases stipulated by the laws,
c) Special quality data regarding health and sexual life may be processed without the explicit consent of the data owner for the purposes of protecting public health, performing preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing.

    1. ENSURING THE SECURITY OF PERSONAL DATA


      As Natureza, we fulfill the necessary technical and administrative measures within the framework of the necessary technological infrastructure to ensure the security of your personal data, which we process within the framework of company activities, in accordance with the KVKK and relevant legislation; In this regard, we carry out the necessary audits by taking precautions against data breaches, unauthorized access, data loss, unauthorized alteration of data and other threats. In this context, we identify current risks and threats, train our employees and carry out awareness activities, determine policies and procedures regarding personal data security, ensures data minimization, creates necessary confidentiality agreements with data processors; we use firewalls and up-to-date anti-virus programs to ensure cyber security, configure our existing software and hardware, perform software updates and audits; We ensure the security of physical and electronic environments containing personal data, and we take the necessary measures to prevent your data security from being breached by unauthorized persons with key management, access logs, user account management, infiltration control and encryption methods.

    2.  

      VII. PERSONAL DATA PROCESSING PURPOSE

       

    3. Your personal data is processed for the purposes of fulfilling company activities and legal obligations and limited to these.

      In line with this,

      Regarding Personal Data of Customer, Prospective Customer and Business and Solution Partners

      –       To be able to provide more effective service with our suppliers and business partners; to carry out legal and financial processes,

      –       Ensuring workplace safety, commercial security and economic security,

      –       Within the scope of audits, auditing the compliance of business activities carried out by authorized private law real and legal persons,

      –        Including images in corporate social media accounts regarding the organization and other activities of our company,

      –       Management of necessary work flow processes by our relevant departments in order to fulfill and improve the service offered by our company,

      – Sending electronic commercial messages for campaign/promotion/information/product and/or service promotion/advertising in accordance with the 6563 Law on the Regulation of Electronic Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages,

      –        Your identity information, contact information, financial identity information and other personal data provided to us and/or requested by us for the purposes of fulfilling the obligations arising from the law and the contract can be processed in electronic and physical environments.

      In terms of Security Camera Application in the Workplace

      –       Within Natureza; In accordance with the provisions of the Occupational Health and Safety Law No. 6331, the Labor Law No. 4857 and the secondary legislation, security cameras are monitored at the entrance to the workplace in order to protect the life and property of the employees, to ensure the safety of the workplace and to carry out disciplinary and legal processes within the framework of these purposes. In the area where the monitoring is performed, it is informed that the monitoring is done with the camera warning letter.

      –         The security camera has been positioned within the framework of the employer’s legitimate interest and ensuring safety in the workplace, by considering the limit of proportionality.

      Regarding Personal Data of Employee Candidates

      By sending job applications and resumes to the relevant department, checking suitability for the job and starting the interview process,

      Determining and examining whether you provide the sufficient and necessary qualifications for the job you are applying for, at the time of job application, during the job application process and during any process to be made during the job application,

      Searching for your references and getting references about you,

      If the job interview is positive at the end of the job application process, you can be placed in your job at the workplace,

      Regarding Personal Data of Employees

      –  Ensuring internal order, workplace peace and security

      –  The processing of personal data of employees in order to fulfill legal obligations such as creating and keeping the personnel file, and sharing them with auditor public institutions and organizations and authorized private law real or legal persons during workplace audits,

      –  Using programs approved by the Company within the scope of the commercial and other activities of the Company,

      –  Including visuals in our corporate social media accounts regarding the organization and other activities of our company,

      –  The use of methods of determining entry-exit times and other electronic surveillance methods in order to ensure the safety of the workplace and employees, and to protect the safety of life and property,

      –  Sharing the personal data of the employees with the private insurance company with which the business partner is made, in case it is necessary to obtain private health insurance for the employees and to establish any other right,

      –  Personal data belonging to the employees who are temporarily assigned to perform services within the relevant customer within the scope of the maintenance/repair services provided to the customers can be shared with the relevant customers upon request by the customer,

      –  Making the necessary organization for the provision of activities such as fairs, seminars, training, conferences, excursions, social events, accommodation and transportation services by the Company and/or third parties on behalf of the Company, performing visa procedures, informing about the developments about the Company, To be able to communicate with their relatives, to gain motivation (such as gifts, promotions), promotion of company activities, advertisement and other purposes, recording personal data of employees by the Company and transferring them to third parties in the country or abroad,

      –  In order to carry out the procedures related to the performance of the services offered to the employees, to the extent that the relevant personal data of the employees can be transferred to the third parties with whom the Company has a contractual relationship,

      –  Processing general and special quality personal data of employees within the scope of documents and documents that must be kept within the scope of OHS activities, sharing them with the workplace doctor and OHS Specialist,

      –  Registering the GSM line, credit card or vehicles allocated to the employee within the scope of the employer’s management right,

      –  Sharing personal information about the companies that we work with for the purpose of renting a car and the employees who will use the vehicles,

      –  Recording fuel consumption and HGS information in terms of the use of vehicles allocated to the Employee by the Company for the purpose of carrying out the work, according to the nature of the work performed,

      –  Your identity information, CV information, personal information, health information provided to us and/or requested by us in line with the purposes and methods of keeping the correspondences made with the corporate e-mail account allocated to the use of the employee and the e-mail files containing these correspondences recorded in the cloud system available abroad. your information, bank account information, contact information and other personal data can be processed in electronic and physical environments.

      Regarding Personal Data of Subcontractors

      Processing the personnel file in order to fulfill legal obligations such as creating and keeping the personnel file and sharing it with auditor public institutions and organizations and authorized private law real or legal persons during workplace audits,

      Processing general and special personal data of subcontractors within the scope of documents and documents that must be kept within the scope of OHS activities, sharing them with workplace physicians and health officers,

      Identity information, personal information, bank account information, contact information, contact information, health information, education information, in line with the purposes and methods of determining the entry-exit times of the employees and using other electronic surveillance methods in order to ensure the safety of the workplace and employees, and to protect the safety of life and property. information and other personal data can be processed.

    4.  

      VIII. TRANSFER OF PERSONAL DATA IN DOMESTIC AND ABROAD

       

    5. Your personal data;

      To our group company, Makroteknik Elektronik ve Bilişim Ticaret Limited Şirketi, limited and in connection with this purpose, in order to develop our company’s efficiency and employment and employment policies, to ensure sustainability and to ensure coordination within the scope of business activities,

      Your personal data is transferred to Microsoft Office applications, cloud solutions, SAP applications and backup systems, whose databases are abroad, in order to administer and manage the business within the company, to carry out company business, to implement company policies, to manage and execute the work flow efficiently,

      Banks, third parties, occupational health and safety specialists, workplace physicians and health personnel in order to fulfill the obligations of the employer within the scope of the employment contract,

      Within the scope of the commercial and other activities of the company, the technical and administrative security measures required by the legislation and sector practices have been checked by the Company, and the commitments regarding this issue have been drawn up between the parties,

      In addition, in order to provide products and services, it can be transferred to our business partners, suppliers, third parties from whom service is received within the framework of company activities and abroad.

      Your personal data may be shared with relevant Ministries, directorates, Social Security Institution and other persons, as well as executive directorates or courts (at all levels and levels), upon request or when necessary in line with our legal obligations.

       

    6. DISPOSAL OF PERSONAL DATA

       

    7. Personal data processed within the framework of our company’s activities are stored within the framework of the purpose of processing and for the periods necessary to achieve this purpose and for the storage period stipulated in the framework of the relevant legislation.

      The data that has lost its function, whose storage period has expired, and which is requested to be destroyed by the data owner, if possible within the framework of the legislation, is destroyed by using the appropriate method of deletion, destruction or anonymization of the personal data listed in Article 7 of the KVKK.

      Deletion of personal data is the process of making personal data inaccessible and non-reusable for the relevant users.

      Destruction of personal data is the process of making personal data inaccessible, unrecoverable and unusable by anyone in any way.

      Anonymization of personal data means that personal data cannot be associated with an identified or identifiable natural person under any circumstances, even if it is matched with other data.

       

    8. RIGHTS OF PERSONAL DATA SUBJECT

       

    9. Regarding the personal data processed within the scope of our company’s activities, the data owner, by applying to our Company, within the framework of your rights numbered in Article 11 of the KVVK;

      a) Learning whether their personal data is processed or not,
      b) If personal data has been processed, requesting information about it,
      c) Learning the purpose of processing personal data and whether they are used in accordance with its purpose,
      d) Knowing the third parties to whom personal data is transferred in the country or abroad,
      e) Requesting correction of personal data in case of incomplete or incorrect processing,
      f) Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in the article of KVKK,
      g) Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,
      h) Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
      i) In case of loss due to unlawful processing of personal data, it has the right to demand the compensation of the damage.

       

    10. CLOSING PROVISIONS

       

    11. If you exercise your above-mentioned rights and make an application to our Company regarding the above-mentioned issues, your requests in your application will be concluded free of charge within thirty (30) business days at the latest, depending on the nature of the request. However, if the transaction requires a separate cost for the Company, the fee in the tariff determined by the Personal Data Protection Board may be requested.

      In matters related to the processing of your personal data, you must submit your application to our Company by completing and signing the application form available on the Company’s website and proving your identity in person.

      National Electronic Technologies Industry. ve Tic. Inc. Contact information

      Head Office Address: Istanbul World Trade Center A3 Blok K:13 No:403-404 Yesilkoy / Istanbul

      Head Office Phone Number: (0) 212 465 3896

      Contact Mail Address: kvkk@natureza.com

      Website address for communication: https://www.natureza.com/

       

    12. ULUSAL ELECTRONIC TECHNOLOGIES IND. VE TİC. Inc. LIGHTING TEXT ON RECEIVING CALL CENTER VOICE RECORDINGS

       

    13. This clarification text is published in the Official Gazette dated 07.04.2016 and numbered 29677, in order to comply with the Law on the Protection of Personal Data No. 6698 (“KVKK”) and related legal regulations. ve Tic. Inc. It has been prepared within the scope of the disclosure obligation of the data controller in order to specify the procedures and principles adopted and to be applied by us.

      Name, surname, date of birth, T.C. your personal data such as identity number, e-mail address, billing and/or delivery addresses, mobile phone number, order/product information, call center voice recordings; KVKK article 5(2)(a) limitedly and in moderation for the purposes of fulfilling our legal obligations, maintaining and improving our customer support processes after sales processes, providing customer relations management, tracking requests and complaints, confirming the call and using it as evidence in possible future disputes. ), “explicitly stipulated in the laws”, “obligatory for the data controller to fulfill his legal obligation” specified in article 5(2)(ç) of KVKK and “data controller” specified in article 5(2)(f) of KVKK. It is collected and processed on the basis of legal reasons” that data processing is mandatory for the legitimate interests of our company.

      Your personal data, only in connection with the purposes listed and in a measured manner, by taking all necessary administrative and technical measures within the scope of KVKK; In order to fulfill our legal obligations, especially to our suppliers/business partners who provide the e-commerce and technological infrastructure of our Company, for the use of programs and systems, legally authorized public institutions and organizations, public security issues and legal disputes, upon request and in accordance with the legislation, to prosecutors’ offices and courts. and to provide information to relevant public officials.

      Your personal data; If there is a period stipulated in the relevant legislation for the storage of these data in our databases and systems with care and confidentiality by our company, by taking all technical and administrative measures, they will be processed for the period required for the purpose for which they are processed. However, the relevant provisions of the KVKK, “Regulation on the Deletion, Destruction or Anonymization of Personal Data” and our Company Policies will be destroyed immediately.

      In case you send your requests regarding your rights as a relevant person to the head office address on our website or to the kvkk@natureza.com.tr It will be evaluated and finalized within 30 days.

      In accordance with Article 11 of the KVKK, your rights as a personal data owner are as follows:

      Learning whether your personal data is processed or not,
      If your personal data has been processed, requesting information about it,
      Learning the purpose of processing your personal data and whether they are used in accordance with the purpose,
      Learning the third parties to whom your personal data is transferred, in the country or abroad,
      To request correction of your personal data in case of incomplete and/or incorrect processing and to notify the third parties to whom the personal data has been transferred,
      Requesting the deletion or destruction of your personal data in the event that the reasons requiring processing are eliminated, although it has been processed in accordance with the provisions of the KVKK 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 by analyzing your processed data exclusively through automated systems,
      Requesting the compensation of your damages in case you suffer damage due to the processing of your personal data in violation of the KVKK.

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