Privacy Statement on Product and or Service Procurement Processes
PEKER YÜZEY TASARIMLARI SANAYİ VE TİCARET ANONİM ŞİRKETİ PRIVACY STATEMENT ON PRODUCT AND/OR SERVICE PROCUREMENT PROCESSES
1. Data Controller
Your personal data are processed by Peker Yüzey Tasarımları Sanayi ve Ticaret Anonim Şirketi, a joint stock company registered at Manisa Trade Registry Directorate with the registration number of 14936 and having its registered office situated at Manisa OSB IV. Kısım Keçiliköy OSB Mah. Ahmet Nazif Zorlu No: 22 Yunusemre / Manisa (the “Company”), in its capacity as a data controller, in accordance with the provisions of the Law No. 6698 on the Protection of Personal Data (the “LPPD”) and pursuant to this Privacy Statement on Product and/or Service Procurement Processes (the “Privacy Statement”).
Our Company respects your rights regarding your privacy and the protection of your personal data, and aims to establish and maintain a relationship with your party that is based on trust. Within this scope, our Company processes your personal data in accordance with all legal regulations on the protection of personal data, particularly the LPPD, and adopts all security measures which are required to ensure the security of your data. This Privacy Policy is intended to provide clarifications on the scope of processing of your personal data which are collected within the scope of your potential or existing commercial relationship with our Company or the potential or existing commercial relationship of your employer firm with our Company. For further details on the processing of your personal data by our Company, please visit Peker Yüzey Tasarımları Sanayi ve Ticaret Anonim Şirketi’s Policy on the Protection and Processing of Personal Data, which is accessible from https://www.belenco.com/en/policy-on-the-protection-and-processing-of-personal-data.aspx .
2. The Methods of Collection of Your Personal Data
Your personal data are collected by our Company wholly or partly by automated means or provided that the process is a part of any data filing system, through non-automated means, from physical and/or electronic environments, via our Company’s websites, printed forms, customer services line, e-mail, phone, SMS, facsimile, cargo/mail, online meeting / communication platforms, open access internet resources, our Company’s headquarters and factory information desks, turnstile records, Company information technology systems, internal integrated systems, integrated systems with authorized public institutions and private organizations and other methods (channels) which may be included in the future.
3. The Categories of Your Processed Personal Data and the Purposes for and the Legal Basis of the Processing of Your Personal Data
A. In Terms of the Suppliers / Supplier Personnel from which Products and/or Services are Procured
Your personal data categories which are processed within the scope of the conducting and conclusion of proposals and contractual negotiations concerning the establishment and/or execution of the commercial relationship; the management of contractual process (e.g. lease contracts); the management of goods / services procurement processes; the formation of existing / potential supplier lists; the selection of service providers and/or service provider personnel; the conducting of activities for ensuring business continuity and other communication activities concerning services; the management of repairs / maintenance / restoration activities; the management of the issuance / amendment /cancellation of invoices, payments and collections and other accounting and financial affairs (e.g. current card opening, return/declaration management); the management of service provider communication and satisfaction; the management of foreign trade operations; the management of imports; the carrying out of operations management; the management of warehouse / logistics activities; the management of orders, planning and manufacturing activities; the management of investments and smart manufacturing; the management of hazardous substances and wastes; the management of incentives/subsidies; the management of R&D activities (e.g. project / patent applications, participation to contests / fairs, procurement of samples, project applications filed with TÜBİTAK (The Scientific and Technological Research Council of Turkey) and other organizations); the management of requests / complaints / suggestions; the management of security of physical spaces; the car parking vehicle tracking management; the management of audits / internal audits; the management of legal and consultancy affairs including the fulfillment of the statutory obligations and the conducting of disputes, to which the Company is a party and/or in which the Company is involved (e.g. lawsuits / execution proceedings / mediation); the management of communication, audit and reporting within the scope of compliance with the regional / global policies and procedures of our group companies and shareholders; the management of storage and archiving activities; the management of information security activities; and the management of quality standards including product / service / process improvement processes, and the purposes for and the legal basis for the processing of your personal data are thoroughly explained herein below.
NB: No special categories of personal data (e.g., religion or blood type information) pertaining to the supplier and/or its personnel should be included in the signature circular (list of authorized signatories), power of attorney or other documentation which may be sought during the contract negotiation, execution and performance processes or such documents should be communicated by having such data redacted.
| Personal Data Category |
The Purposes for and Legal Basis of Processing of Personal Data |
| Identity Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) being expressly permitted by law, as stipulated in article 5(2)(a) of the LPPD; (ii) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (iii) personal data being revealed to the public by the data subject himself/herself, as stipulated in article 5(2)(d) of the LPPD; (iv) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (v) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Emergency Management Processes;
· Carrying out of Audit / Ethics Activities;
· Carrying out of Training Activities;
· Conducting of Activities in Accordance with the Legislation;
· Conducting of Finance and Accounting Affairs;
· Ensuring the Security of Physical Locations;
· Carrying out of Assignment Processes;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Conducting of Goods / Services Procurement Processes;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Follow-up of Requests / Complaints;
· Ensuring the Security of Movable Properties and Resources;
· Conducting of the Procurement Chain Management Processes;
· Ensuring the Security of the Data Controller’s Operations;
· Conducting of Investment Processes;
Providing Information to Authorized Individuals, Institutions and Organizations.
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| Communication Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) being expressly permitted by law, as stipulated in article 5(2)(a) of the LPPD; (ii) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (iii) personal data being revealed to the public by the data subject himself/herself, as stipulated in article 5(2)(d) of the LPPD; (iv) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (v) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Emergency Management Processes;
· Carrying out of Audit / Ethics Activities;
· Carrying out of Training Activities;
· Conducting of Activities in Accordance with the Legislation;
· Conducting of Finance and Accounting Affairs;
· Carrying out of Assignment Processes;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Conducting of Goods / Services Procurement Processes;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Follow-up of Requests / Complaints;
· Ensuring the Security of Movable Properties and Resources;
· Conducting of the Procurement Chain Management Processes;
· Ensuring the Security of the Data Controller’s Operations;
· Conducting of Investment Processes;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Professional Work Experience Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) being expressly permitted by law, as stipulated in article 5(2)(a) of the LPPD; (ii) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (iii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iv) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (v) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Emergency Management Processes;
· Carrying out of Audit / Ethics Activities;
· Carrying out of Training Activities;
· Conducting of Activities in Accordance with the Legislation;
· Conducting of Finance and Accounting Affairs;
· Carrying out of Assignment Processes;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Conducting of Goods / Services Procurement Processes;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Follow-up of Requests / Complaints;
· Ensuring the Security of Movable Properties and Resources;
· Conducting of the Procurement Chain Management Processes;
· Ensuring the Security of the Data Controller’s Operations;
· Conducting of Investment Processes;
· Furnishing of Information to Authorized Individuals, Institutions and Organizations.
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| Finance Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) being expressly permitted by law, as stipulated in article 5(2)(a) of the LPPD; (ii) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (v) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Conducting of Finance and Accounting Affairs;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Goods / Services Procurement Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Conducting of the Procurement Chain Management Processes;
· Conducting of Investment Processes;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Audio-Visual Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Goods / Services Procurement Processes;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Legal Transaction Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Request / Complaint / Suggestion Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Goods / Services Procurement Processes;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Follow-up of Requests / Complaints;
· Conducting of the Procurement Chain Management Processes;
· Providing Information to Authorized Individuals, Institutions and Organizations
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| Vehicle Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Emergency Management Processes;
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Ensuring the Security of Physical Locations;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Logistics Activities;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Follow-up of Requests / Complaints;
· Ensuring the Security of Movable Properties and Resources;
· Conducting of the Procurement Chain Management Processes;
· Ensuring the Security of the Data Controller’s Operations;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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Special Categories of Personal Data
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Your personal data, as limited with the criminal convictions and security measures, are processed within the scope of foreign trade process, on the basis of the personal data processing condition (legal ground) of being expressly permitted by law, as stipulated in article 6(3) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Logistics Activities;
· Conducting of Storage and Archiving Activities.
Your personal data, as limited with health information, are processed within the scope of goods / services procurement management process, on the basis of the personal data processing condition (legal ground) of the existence of explicit consent, as stipulated in article 6(2) of the LPPD (if they fall within the scope of the aforesaid process), and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Goods / Services Procurement Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Conducting of the Procurement Chain Management Processes.
***NB: The (i) processing and transfer of your personal data, concerning your criminal convictions and security measures, on the legal condition of “personal data, except for data concerning health and sexual life may be processed without seeking explicit consent of the data subject” as stipulated in article 6(3) of the LPPD, for the purpose of the attainment of the approved person status certificate; (ii) processing of your personal data concerning your health by the Company’s occupational physician and other healthcare professional, on the legal condition of “personal data concerning health and sexual life may only be processed, without seeking explicit consent of the data subject, by the persons subject to secrecy obligation or competent public institutions and organizations, for the purposes of protection of public health, operation of preventive medicine, medical diagnosis, treatment and nursing services, planning and management of healthcare services as well as their financing” as stipulated in article 6(3) of the LPPD, for the purpose of the protection of public health and the transfer thereof, again, to healthcare professionals; and (iii) processing of your special categories of personal data pursuant to the exemptions to the LPPD, as listed in article 28 thereof, and the transfer thereof within this scope are not subject to the legal condition of the existence of explicit consent.
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B. In Terms of the Dedicated Suppliers / Supplier Personnel Working at our Company’s Premises
Your personal data categories which are processed within the scope of the conducting and conclusion of proposals and contractual negotiations concerning the establishment and/or execution of the commercial relationship; the management of contractual process (e.g. lease contracts); the management of goods / services procurement processes (e.g. cleaning services); the selection of dedicated suppliers and/or supplier personnel; the conducting of activities for ensuring business continuity and other communication activities concerning services; the management of repairs / maintenance / restoration activities; the management of the issuance / amendment /cancellation of invoices, payments and collections and other accounting and financial affairs (e.g. current card opening, return/declaration management); the management of supplier personnel requests / complaints / support (e.g. Bir Söyle Bin Kazan application); the management of foreign trade operations; the management of imports; the carrying out of operations management; the management of warehouse / logistics activities; the management of orders, planning and manufacturing activities; the management of investments and smart manufacturing; the management of hazardous substances and wastes; the management of incentives/subsidies; the management of R&D activities (e.g. project / patent applications, participation to contests / fairs, procurement of samples, project applications filed with TÜBİTAK (The Scientific and Technological Research Council of Turkey) and other organizations); the management of security of physical spaces; the car parking vehicle tracking management; the formation of dedicated supplier / supplier personnel files; the management of internal / external training, certification and orientation activities; the management of administrative affairs and communications/correspondences (e.g. information / documentation request follow-up and management); the management of dedicated supplier / supplier personnel attendance checks; the management of disciplinary / investigation / ethics activities; the management of entrustment/allocation, inspection and tracking of devices / vehicles / systems; the management of occupational health and safety activities; the carrying out of performance assessments of dedicated supplier / supplier personnel and the reporting thereof to the principal employer; the management of transportation of dedicated supplier / supplier personnel (e.g. provision of service/shuttle vehicles); the management of audits / internal audits; the management of legal and consultancy affairs including the discharge of the statutory obligations and the conducting of disputes, to which the Company is a party and/or in which the Company is involved (e.g. lawsuits / execution proceedings / mediation); the management of communication, audit and reporting within the scope of compliance with the regional/global policies and procedures of our group companies and shareholders; the management of storage and archiving activities; the management of information security activities (e.g. the establishment of access/authorization matrix, the keeping of log records, the granting of authorization for access to the system room); and the management of quality standards including product / service / process improvement processes, and the purposes for and the legal basis for the processing of your personal data are thoroughly explained herein below.
NB: All medical reports and other health data underlying the eligibility to work documents pertaining to the personnel to be assigned at our Company within the scope of supplier, temporary worker or sub-employer relationship, and their personal files should be retained by the supplier companies, and kept in their own data filing systems as available for submission to the public institutions and organizations and other authorities if so required.
| Personal Data Category |
The Purposes for and Legal Basis of Processing of Personal Data |
| Identity Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Emergency Management Processes;
· Conducting of Information Security Processes;
· Carrying out of Audit / Ethics Activities;
· Carrying out of Training Activities;
· Conducting of Authorizations for Access;
· Conducting of Activities in Accordance with the Legislation;
· Conducting of Finance and Accounting Affairs;
· Carrying out of Company / Products / Services Loyalty Processes;
· Ensuring the Security of Physical Locations;
· Carrying out of Assignment Processes;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Conducting of Goods / Services Procurement Processes;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Performance Rating Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Follow-up of Requests / Complaints;
· Ensuring the Security of Movable Properties and Resources;
· Conducting of the Procurement Chain Management Processes;
· Ensuring the Security of the Data Controller’s Operations;
· Conducting of Talent / Career Development Activities;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Communication Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Emergency Management Processes;
· Conducting of Information Security Processes;
· Carrying out of Audit / Ethics Activities;
· Carrying out of Training Activities;
· Conducting of Authorizations for Access;
· Conducting of Activities in Accordance with the Legislation;
· Conducting of Finance and Accounting Affairs;
· Ensuring the Security of Physical Locations;
· Carrying out of Assignment Processes;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Conducting of Goods / Services Procurement Processes;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Follow-up of Requests / Complaints;
· Ensuring the Security of Movable Properties and Resources;
· Conducting of the Procurement Chain Management Processes;
· Ensuring the Security of the Data Controller’s Operations;
· Conducting of Talent / Career Development Activities;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Professional Work Experience Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Emergency Management Processes;
· Conducting of Information Security Processes;
· Carrying out of Audit / Ethics Activities;
· Carrying out of Training Activities;
· Conducting of Authorizations for Access;
· Conducting of Activities in Accordance with the Legislation;
· Conducting of Finance and Accounting Affairs;
· Ensuring the Security of Physical Locations;
· Carrying out of Assignment Processes;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Logistics Activities;
· Conducting of Goods / Services Procurement Processes;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Performance Rating Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Follow-up of Requests / Complaints;
· Ensuring the Security of Movable Properties and Resources;
· Conducting of the Procurement Chain Management Processes;
· Ensuring the Security of the Data Controller’s Operations;
· Conducting of Talent / Career Development Activities;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Audio-VisualData |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Emergency Management Processes;
· Carrying out of Audit / Ethics Activities;
· Carrying out of Training Activities;
· Conducting of Activities in Accordance with the Legislation;
· Ensuring the Security of Physical Locations;
· Carrying out of Assignment Processes;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Ensuring the Security of Movable Properties and Resources;
· Conducting of the Procurement Chain Management Processes;
· Ensuring the Security of the Data Controller’s Operations;
· Conducting of Talent / Career Development Activities;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Legal Transaction Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes,
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Request / Complaint / Suggestion Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Attainment and Evaluation of Recommendations for the Improvement of Business Processes;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Vehicle Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Emergency Management Processes;
· Carrying out of Audit / Ethics Activities;
· Carrying out of Training Activities;
· Conducting of Activities in Accordance with the Legislation;
· Ensuring the Security of Physical Locations;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Logistics Activities;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Ensuring the Security of Movable Properties and Resources;
· Conducting of the Procurement Chain Management Processes;
· Ensuring the Security of the Data Controller’s Operations;
· Furnishing of Information to Authorized Individuals, Institutions and Organizations.
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| Transaction Security Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) being expressly permitted by law, as stipulated in article 5(2)(a) of the LPPD; (ii) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (iii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iv) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (v) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Conducting of Information Security Processes;
· Carrying out of Audit / Ethics Activities;
· Carrying out of Training Activities;
· Conducting of Authorizations for Access;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Communication Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Goods / Services Manufacturing and Operations Processes;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Physical Space Security Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (ii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iii) data processing being required for the legitimate interests of the data controller, provided not to impair the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Ensuring the Security of Physical Locations;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Storage and Archiving Activities;
· Follow-up of Requests / Complaints;
· Ensuring the Security of Movable Properties and Resources;
· Conducting of the Procurement Chain Management Processes;
· Ensuring the Security of the Data Controller’s Operations;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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| Location Data |
Your personal data within this category are processed on the basis of the personal data processing conditions (legal grounds) of (i) the processing of the personal data pertaining to the contracting parties being required, provided that the processing is directly related to the conclusion or performance of the contract, as stipulated in article 5(2)(c) of the LPPD; (ii) data processing being required for the data controller’s compliance with a legal obligation, as stipulated in article 5(2)(ç) of the LPPD; (iii) data processing being required for the establishment, exercise or protection of a right, as stipulated in article 5(2)(e) of the LPPD; and (iv) data processing being required for the legitimate interests of the data controller, except where such interest are overridden by the fundamental rights and freedoms of the data subject, as stipulated in article 5(2)(f) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Activities for Ensuring Business Continuity;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Ensuring the Security of the Data Controller’s Operations;
· Providing Information to Authorized Individuals, Institutions and Organizations.
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Special Categories of Personal Data
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Your personal data, as limited with the criminal convictions and security measures, are processed within the scope of foreign trade process, on the basis of the personal data processing condition (legal ground) of being expressly permitted by law, as stipulated in article 6(3) of the LPPD, and for the following purposes:
· Carrying out of Audit / Ethics Activities;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting / Inspection of Business Activities;
· Conducting of Logistics Activities;
· Conducting of Storage and Archiving Activities.
Your personal data, as limited with health information, are processed on the basis of the personal data processing condition (legal ground) of being processed by persons subject to secrecy obligation or competent public institutions and organizations, for the purposes of protection of public health, operation of preventive medicine, medical diagnosis, treatment and nursing services, planning and management of healthcare services as well as their financing, as stipulated in article 6(3) of the LPPD, and for the following purposes:
· Conducting of Emergency Management Processes;
· Carrying out of Audit / Ethics Activities;
· Carrying out of Training Activities;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting of Occupational Health / Safety Activities;
· Conducting of Storage and Archiving Activities;
· Providing Information to Authorized Individuals, Institutions and Organizations.
Your personal data, as limited with criminal convictions and security measures which are processed other than as expressly permitted by law, and data concerning health life which are processed by other than by the occupational physician, are processed within the scope of (i) the formation of the dedicated supplier / supplier personnel files; (ii) goods / services procurement management; and (iii) dedicated supplier / supplier personnel transportation management (e.g. provision of service/shuttle vehicles) processes, on the basis of the personal data processing condition (legal ground) of the existence of explicit consent, as stipulated in article 6(2) of the LPPD (if they fall within the scope of each of the aforesaid processes), and for the following purposes:
· Conducting of Emergency Management Processes;
· Conducting of Activities in Accordance with the Legislation;
· Follow-up and Conducting of Legal Affairs;
· Conducting / Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Conducting of Goods / Services Procurement Processes;
· Conducting of Storage and Archiving Activities;
· Conducting of Contractual Processes;
· Conducting of the Procurement Chain Management Processes;
· Ensuring the Security of the Data Controller’s Operations.
***NB: The (I) processing and transfer of your personal data, concerning your criminal convictions and security measures, on the legal condition of “personal data, except for data concerning health and sexual life may be processed without seeking explicit consent of the data subject” as stipulated in article 6(3) of the LPPD, for the purpose of the attainment of the approved person status certificate; (ii) processing of your personal data concerning your health life by the Company’s occupational physician and other healthcare professional, on the legal condition of “personal data concerning health and sexual life may only be processed, without seeking explicit consent of the data subject, by the persons subject to secrecy obligation or competent public institutions and organizations, for the purposes of protection of public health, operation of preventive medicine, medical diagnosis, treatment and nursing services, planning and management of healthcare services as well as their financing” as stipulated in article 6(3) of the LPPD, for the purpose of the protection of public health and the transfer thereof, again, to healthcare professionals; and (iii) processing of your special categories of personal data pursuant to the exemptions to the LPPD, as listed in article 28 thereof, and the transfer thereof within this scope are not subject to the legal condition of the existence of explicit consent.
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4. The Domestic and Cross-Border Transfer of Your Personal Data to Third Parties
Your personal data which are retained by our Company may be accessed solely by our personnel who have been granted with restricted access authorization for the aforementioned purposes, to the extent as is necessary to fulfill their duties, and will not be transferred to third parties located in Turkey and/or abroad in cases where the conditions for transfer which are regulated in articles 8 and/or 9 of the LPPD are not satisfied. Nevertheless, your personal data which are processed within the scope of each personal data category listed hereinabove may be transferred to the following recipient groups if the aforesaid personal data processing conditions (legal grounds) for the data category concerned are further satisfied in terms of the purposes for transfer, and in accordance with articles 8 and/or 9 of the LPPD:
· to our service providers located in Turkey and/or abroad including our group companies acting as a service provider (e.g., sworn-in certified public accountants, tax and legal consultants, auditing/accounting companies, real estate owners, translation offices, physical storage service companies, logistics companies, information technology and data hosting service providers) , as limited with the ty, communication, professional work experience, finance, audio-visual, legal transaction, request / complaint / suggestion, vehicle, transaction security, physical space security and location personal data categories and criminal conviction and security measures and health information, for the purposes as specified hereinabove for each data category, and particularly, in order to ensure the procurement of products and/services for the execution of our Company’s operations;
· to banks, insurance companies / agencies, located in Turkey and/or abroad as limited with the ty, communication, vehicle and finance personal data categories, for the purposes as specified hereinabove for each category, and particularly, in order to enable the planning and/or materialization of payment processing/transactions concerning products / services;
· to your principal employer in Turkey, as limited with the ty, communicaiton, professional work experience, audio-visual, legal transaction, request / complaint / suggestion, vehicle, transaction security and physical space security personal data categories and criminal conviction and security measures and health information, for the purposes as specified hereinabove for each data category and particularly, in order to manage the activities of the dedicated service providerrs / service provider personnel and the communication of the necessary notifications to the principal employers;
· to our business partners (e.g., project partners) located in Turkey and/or abroad, as limited with the ty, communication and professional work experience personal data categories, for the purposes as specified hereinabove for each data category, and particularly, in order to ensure business continuity and establish business collaborations within the scope of our Company’s operations;
· to our distributors and the customers of our distributors located in Turkey and/or abroad, as limited with the ty, communication, professional work experience and vehicle personal data categories, for the purposes as specified hereinabove for each data category, and particularly, in order to provide sale or after-sale support services for our Company’s goods and/or services;
· to our shareholders located overseas, as limited with the ty, communication, professional work experience, finance, audio-visual, legal transaction, request /complaint / suggestion, vehicle, transaction security, and physical space security personal data categories and special categories of personal data regarding criminal convictions and security measures and health information, for the purposes as specified hereinabove for each data category, and particularly, in order to enable the planning and/or materialization of the communication, audit and reporting activities for compliance with regional/global policies and procedures;
· to potential buyers, sellers or other transacting parties located in Turkey and/or abroad and their employees, consultants and database service providers involved in the process, who are under a confidentiality obligation, as limited with the ty, communication, professional work experience, audio-visual, legal transaction, finance, transaction security and request /complaint / suggestion personal data categories and special categories of personal data regarding health information, for the purposes as specified hereinabove for each data category, and particularly, in order to facilitate the carrying out of the legal and financial due diligence of our Company in case of any potential corporate merger, acquisition, joint venture, de-merger and other structural changes; and
· to the authorized public institutions and organizations (e.g. courts, notaries, tax offices, foreign authorities) in Turkey and/or abroad, as limited with the ty, communicaiton, professional work experience, finance, audio-visual, legal transaction, request /complaint / suggestion, vehicle, transaction security, physical space security and location personal data categories and special categories of personal data regarding criminal convictions and security measures and health information, for the purposes as specified hereinabove for each data category, and particularly, in order to fulfill our Company’s statutory obligations and the follow-up the legal affairs thereof.
5. The Period for Processing of Your Personal Data
Your personal data which are acquired during our Company’s operations are retained and destroyed pursuant to the general principles and regulations laid down in our Company’s policies and procedures on retention and destruction, which are drafted in accordance with primarily, the Constitution, and the LPDD, the Regulation on the Deletion, Destruction and Anonymization of Personal Data and other applicable legislation.
Within this scope, if all of the aforementioned personal data processing conditions cease to exist, your personal data will be disposed accordingly. Your personal data will then be continued to be processed during the statutory limitation periods pertaining to the specific process. Your personal data which are processed on the basis of the requirement of the attainment of explicit consent for personal data processing will be destroyed at the first destruction period following the revocation of your explicit consent. Please see section 6 of this Privacy Statement for your requests concerning the destruction of your personal data.
6. Your Rights under the LPPD
Pursuant to article 11 of the LPPD, you possess the following rights, as a data subject:
- being informed of whether your personal data are processed or not;
- requesting information thereon if your personal data have been processed;
- being informed of the purpose for the processing of your personal data and whether such data were used in conformity with such purpose or not;
- knowing the third parties in Turkey or abroad to whom/which personal data are transferred;
- requesting the rectification of incomplete or inaccurate personal data which were processed and the notification, of the operation carried out within this scope, to third parties to whom/which personal data were transferred;
- requesting the deletion or destruction of personal data despite the processing in accordance with the law and other applicable legal provisions, once the reasons necessitating the processing cease to exist, and within this scope, if the personal data were processed incompletely and inaccurately, the notification, of the operation carried out within this scope, to third parties to whom/which personal data were transferred;
- objecting to any outcomes to your detriment by means of the analysis of the processed data exclusively through automated means;
- claiming the compensation of your damages, in case you incur any damages due to the unlawful processing of personal data.
You may submit your application regarding your aforementioned rights, in accordance with the provisions of the Communiqué on the Procedures and Principles of Application to the Data Controller (in writing or electronically, via registered electronic mail (KEP) address, signed with secure electronic signature or mobile signature, or via your e-mail address which had previously been notified to our Company and which is recorded in our system - along with the information / documentation* verifying your identity in order to enable our Company to confirm your status as an actual right-holder/beneficiary (e.g. Turkish ID number or passport number for citizens of other countries, residential address / workplace address for notification/service, mobile phone / landline /facsimile number, e-mail address) by filling in the Data Subject Application Form which is accessible from https://www.belenco.com/en/data-subject-application-form.aspx or through the channels which are indicated in the Data Subject Application Form as pertaining to the data controller, in accordance with the procedures and principles which are mentioned hereinabove and which are laid down in the applicable legislation. Your application will be concluded free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of your request; however, in case the transaction requires an additional cost, you may be charged according to the tariff determined by the Personal Data Protection Board.
* Please note that no special categories of personal data (e.g. religion or blood type information) should be included in the said documentation.