GDPR Declaration

REGARDING THE PROTECTION OF PERSONAL DATA OF WEB SITE VISITORS AND PHYSICAL VISITORS CLARIFICATION DECLARATION

The purpose of this Clarification Declaration is to state that as 4A ELEKTRİK ELEKTRONİK TEKNOLOJİ A.Ş. (“our Company”) it is our primary principle to provide security and protection of your Personal Data and Information and to respect ethical values.

As Data Controller, we will be authorized to do the following about your (our Company and Website visitors) Personal data; according to laws and good faith they can be recorded, kept, categorized, updated within the purposes stated below, can be processed only for the cases deemed suitable by the regulations, and can be processed and shared within the scope of protecting fundamental rights and freedoms especially the right of privacy.

Accordingly, we present the following declaration for the purposes of fulfilling our Clarification Obligation as per article 10 of the Data Protection Law (“KVKK”).

Data Controller:
4A ELEKTRİK ELEKTRONİK TEKNOLOJİ A.Ş. (“our Company”) that holds the title of “Data Controller” as defined in Data Protection Law numbered 6698 processes your personal data within the purposes and the limits described in the regulation.

Scope:
The personal data of our website visitors, potential customers and physical visitors of our company is collected, recorded and processed through digital and technical channels with automatic or manual ways by our company (4A ELEKTRİK ELEKTRONİK TEKNOLOJİ A.Ş. ) in accordance with article 5 of Data Protection Law for the purposes to provide security regarding the entry-exit monitoring, to provide security for and monitor the services given to our customers and potential customers who want to get internet service, to provide security for the company, customers and other persons and to protect the customers’ benefits regarding the service they got.

Data Categories for the Personal Data that has been collected from the Visitors who visit our website or the Physical visitors who visit our company are as follows:

IDENTITY

Name Surname, T.R. ID No, Date of Birth

CONTACT

E-mail address, Cell Phone Number, Mailing Address, Intercompany Contact Information (internal phone number, corporate e-mail address)

SENSITIVE PERSONAL DATA

BIOMETRICAL DATA

Fingerprint,

VISUAL AND AUDIO DATA

Security camera records (no audio), Teleconference, video meeting, records from the information received during meetings on phone or face to face,

PROCESS SECURITY DATA

Keeping the internet usage logs of the persons and the website visitors within the objectives stated in Cookie Policy numbered PL-XXX by the website cookies.

Security Camera records (no audio), IP Information, entry time, exit time.

Personal data regarding religion or faith, appearance, political opinion, membership to any association, hobbies, or sensitive data, etc. are not requested by “4 ELEKTRİK ELEKTRONİK TEKNOLOJİ A.Ş”. In the case they included in the documents provided by the person, they will not be assessed or processed.

Purpose of Collecting and Processing Personal Data;

Your personal data may be processed with the purposes and reasons including but not limited to the purposes and legal reasons stated below:

Operating Customer Relations Management and Customer Satisfaction Processes,

Creating and Following Visitor Records,

Operating Activities Complying the Regulations, Providing Workplace Security, Operating Emergency Management Processes

Providing Security of the Physical Place,    

Control of the entry and exit records of the visitors, Providing security in entry and exit of the employees to the company headquarters, Fulfilling similar legal obligations such as providing security within the company,                                                                                                                                            Conducting Occupational Health/Safety Activities,

• Implementing Occupational Health and Safety and Data Protection Law measures for the visitors,

Informing the Authorized Persons, Institutions and Organizations,

Keeping regulations and other information stipulated by related institutions and other authorities, reporting, following notification obligations, submitting Camera Records to law enforcers when necessary.

Providing Information Security.

The above-stated purposes and;

Your personal data can be processed for the below stated Legal Reasons;
In the cases where data processing is necessary for realizing our Company’s legitimate interests and our operational and commercial activities stated above and our Tax-Plate and Trade Registry Gazette and conducted by our Company, for establishing, using or protecting a right,

In the cases where data processing is necessary for legitimate interests of the data collector provided that not to harm the fundamental rights and freedoms of the relevant person.

As per articles 5 and 6 of the Data Protection Law, within the above-stated personal data processing conditions and purposes and only limited to those purposes, personal data is collected and processed.

Sharing Your Personal Data with the Third Persons within Country

Your personal data that we collected can be shared with the purpose of our Company to perform its obligations as per law and to provide your security with relevant organizations and institutions such as public legal entities such as Personal Data Protection Authority, Ministry of Finance, Ministry of Customs and Trade, Ministry of Labor and Social Security, Turkish Employment Agency, Social Security Institution, Information and Communication Technologies Authority in a manner allowed and needed including but limited to the Data Protection Law numbered 6698, Labor Law, Occupational Safety and Health Law, Social Insurance and General Health Insurance Law, Turkish Code of Commerce, Identity Reporting Law, Regulation of Publications on the Internet and Combating Crimes Committed by means of such Publication and provisions of the miscellaneous regulations.

Also, your personal data can be shared

for the purposes of carrying out the necessary purpose for the implementation of the labor contract;

with the Occupational Physician -your health data- for treatment and controlling health;

with the Company Auditors -your payroll information- for realizing audit activities;

for the purposes of providing security within security; with the Law Enforcers for the purposes of controlling entry-exit or investigation for the security of the workplace,

for fulfilling our Legal obligations stated below;

within our legal liabilities such as court decision or perpetuate testimony provided that it will be suited to the laws and process with our company lawyers and relevant institutions;

for the purposes of managing the company, operating businesses, and implementing company policies, especially;

with the companies that we are affiliated or partnered to provide internal operations.

Your personal data can be shared especially with the above-stated institution/institutions and similar trustworthy third persons and/or institutions and organizations and/or our business partners and/or institutions providing services from abroad and/or in-country in a manner and extent necessary for achieving above-stated purposes and by providing data security and only limited to those purposes by taking all necessary measures and (when necessary) taking an Explicit Consent of the person within the frame of data processing conditions and purposes stated in articles 8 and 9 of Data Protection Law.  Also, the personal data may be shared with the public institutions and organizations that are authorized to demand and take these data by legal necessity.

Sharing Your Personal Data with the Third Persons in Abroad

Personal Data that you provided as a Physical Visitor is not shared with 3rd persons except the cases where sharing is obliged by Law.Your IP information, entry and exit time to the website, duration, etc. information (COUNTRY NAME) that processed automatically during your visit to our website can be shared with 3rd parties from abroad.

Method of Collecting Personal Data
Personal data are collected with verbal, written and/or electronic means, used, recorded, stored and processed by our company.

Retention Period, Deletion, Destruction or Anonymization of the Personal Data
Your personal data are stored for the retention period that is stated in the relevant legal regulations (if a period is not determined in the relevant legal regulations, for the duration that is necessary for the processing purposes stated above as per our company’s activities and practices of the commercial life) and then deleted, destructed or anonymized afterward as per Data Protection Law.

If the processing purpose of your personal data has ended and the retention period determined by the relevant regulation and our Company is, the personal data can only be kept for the purposes to submit as evidence for possible legal disputes or protecting the rights of the person in question depending on the personal data or constituting a defense. These periods are determined by considering the timeouts for asserting the right in question and the instances where requests are submitted to our company before about the same manner after the timeouts.

In such cases, the personal data can only be reached when it is necessary to use in a legal dispute and they cannot be reached for any other purpose. When the period stated here ends, the personal data is deleted, destructed or anonymized. These matters are examined in detail in 4A ELEKTRİK ELEKTRONİK TEKNOLOJİ A.Ş. Policy on Storing and Destructing Personal Data.

Security of Your Personal Data
For the purposes of protecting your data in the environments that are processed and stored to prevent unauthorized access, loss and harm, within the Data Protection Law, the necessities of the technical and administrative measures published by Personal Data Protection Authority regarding the Security of Personal Data shall be reviewed periodically and complied by our company.

Your Rights as a Data Owner                                                                                                                        

As per article 11 of Data Protection Law, everyone can request the following about themselves;
a) Learn whether your personal data concerning has been processed,
b) Request information as to processing if your personal data is processed,
c) Learn the purpose of processing and whether personal data is processed as per their purpose,
d) Learn the third parties in-country or abroad if the data transferred,
e) Demand the rectification of the data content if there is incompleteness or inaccuracy in their processing,
f) Demand deletion or destruction of data within the framework of the conditions stated in 7th article,
g) Demand notification of the operations made according to sub-paragraphs (e) and (f) to third parties to whom personal data transferred,
h) Object to occurrence of any result that is to your detriment by analysis of personal data exclusively through automated systems,
i) Demand compensation for the damages caused due to the unlawful processing of personal data.

Methods for Application by the Data Owner Regarding His Rights
As per sub-article 1 of article 13 of the Data Protection Law, you can submit your request about using your rights stated above based upon “Notification Regarding the Rules and Procedures of Application to the Data Controller” numbered 30356 published in the Official Gazette with the methods and information stated below:

Written applications shall be made by printing the Privacy Clarification Application Form of 4A ELEKTRİK ELEKTRONİK TEKNOLOJİ A.Ş. that you can find in our website and by doing the following;

• With the personal submission of the Applicant,
• Through a notary,
• The application form can be sent to us by signing with a “secure electronic signature” defined in the Electronic Signature Act numbered 5070 by the Applicant to send the e-mail address stated below.
• This can be done by the person/customer in question from the e-mail address of this person/customer that is notified to the data controller or registered in the data controller’s system.
• THE APPLICATION METHOD IS EXPLAINED IN THE TABLE BELOW:

• Name-Surname-TR ID :
• Signature             :