Privacy Statement on the Physical Security Processes
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These premises and extensions are under CCTV surveillance by Lotte Chemical Turkey Yüzey Tasarımları San. ve Tic. A.Ş. in order to ensure your security. For further information, please refer to the privacy statement which is accessible from https://www.belenco.com/en/privacy-statement-on-the-physical-security-processes.aspx or in case of technical difficulties, please request a hard copy of the referred text from the information desk.
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LOTTE CHEMICAL TURKEU YÜZEY TASARIMLARI SAN. VE TİC. A.Ş. PRIVACY STATEMENT ON THE PHYSICAL SECURITY PROCESSES
1. Data Controller
Your personal data are processed by Lotte Chemical Turkey Yüzey Tasarımları San. ve Tic. A.Ş., 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 the Physical Security 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 you 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 Statement is intended to provide clarifications on the scope of processing of your personal data which are collected within the scope of your visit(s) to our Company’s premises. For further details on the processing of your personal data by our Company, please visit Lotte Chemical Turkey Yüzey Tasarımları San. ve Tic. A.Ş.'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 headquarters and factory information desks, printed forms (e.g., visitor books) and closed-circuit television (CCTV) systems 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
Your personal data categories which are processed within the scope of the maintenance and safeguarding of the security of the Company’s buildings and premises, employees and fixtures as well as the Company’s visitors; the management of the warehouse; the management of physical security activities; the car parking vehicle tracking management; the management of audits and internal audits; the management of legal and consultancy affairs including the fulfilment 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; and the management of storage and archiving activities, and the purposes for and the legal basis for the processing of your personal data are thoroughly explained herein below.
| Personal Data Category |
The Purposes for and Legal Basis of Processing of Personal Data
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| Identity 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 interests 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 Spaces;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting and Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Conducting of Storage and Archiving Activities;
· Ensuring the Security of Movable Properties and Resources;
· Ensuring the Security of the Data Controller’s Operations;
· Providing Information to Authorized Individuals, Institutions and Organizations;
· Creation and Monitoring of Visitor Records.
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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) 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 interests 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 Spaces;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting and Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Conducting of Storage and Archiving Activities;
· Ensuring the Security of Movable Properties and Resources;
· Ensuring the Security of the Data Controller’s Operations;
· Providing Information to Authorized Individuals, Institutions and Organizations;
· Creation and Monitoring of Visitor Records.
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Physical Space Security Data
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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 interests 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 Spaces;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting and Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Conducting of Storage and Archiving Activities;
· Ensuring the Security of Movable Properties and Resources;
· Ensuring the Security of the Data Controller’s Operations;
· Providing Information to Authorized Individuals, Institutions and Organizations;
· Creation and Monitoring of Visitor Records.
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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) 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 interests 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;
· Ensuring the Security of Physical Spaces;
· Follow-up and Conducting of Legal Affairs;
· Carrying out of Internal Audit / Investigation / Intelligence Activities;
· Conducting and Inspection of Business Activities;
· Conducting of Occupational Health / Safety Activities;
· Conducting of Storage and Archiving Activities;
· Ensuring the Security of Movable Properties and Resources;
· Ensuring the Security of the Data Controller’s Operations;
· Providing Information to Authorized Individuals, Institutions and Organizations;
· Creation and Monitoring of Visitor Records.
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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., legal consultants, information technology and data hosting service providers) , as limited with the identity, communication, vehicle and physical space security personal data categories, 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 our group companies and shareholders located in Turkey and/or abroad, as limited with the identity, communication details, vehicle and physical space personal data categories, 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 of our group companies and shareholders; and
· to the authorized public institutions and organizations (e.g., courts, police stations) in Turkey, as limited with the identity, communication, vehicle and physical space personal data categories, 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 of 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 disposed pursuant to the general principles and regulations laid down in our Company’s policies and procedures on retention and disposal, which are drafted in accordance with primarily, the Constitution, and the LPPD, 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. Please see section 6 of this Privacy Statement for your requests concerning the disposal 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 by our Company 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.