Personal Data Protection Law Information Text

As Demes Kablo Sanayi ve Ticaret A.Ş., acting in our capacity as Data Controller, we hereby inform you, in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”), all relevant legislation and regulatory decisions; within the scope of our duty to provide information, we wish to inform you regarding which of your personal data will be processed; the purposes for which your personal data will be processed; to whom and for what purposes it may be transferred; the methods of collection and the legal grounds; the processing periods; the identity of the data controller; and the rights granted to you under the KVKK.

1. DEFINITIONS:

The following terms used in this privacy notice:

Personal Data: Any information relating to an identified or identifiable natural person;
Law on the Protection of Personal Data (“KVKK”): Law No. 6698 on the Protection of Personal Data, which entered into force upon its publication in the Official Gazette on 7 April 2016;
Legislation: All laws, decrees with the force of law, regulations and bylaws containing provisions relating to the protection of personal data,
Board: The Personal Data Protection Board,
Processing of Personal Data: Any operation performed on personal data, such as the collection, recording, storage, retention, alteration, reorganisation, disclosure, transfer, acquisition, making available, classification or restriction of use of such data, whether carried out wholly or partly by automated means or by non-automated means provided that it forms part of a data filing system,
Data Controller: A natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system,
Data Processor: A natural or legal person who processes personal data on behalf of the data controller based on the authority granted by the data controller,
Data Subject: The natural person whose personal data is being processed,
Demes Kablo Sanayi ve Ticaret A.Ş.: … registered with the Commercial Registry under registration number …, with MERSIS number …, having its registered office at …, and acting as the data controller who has prepared this privacy notice.

2. PERSONAL DATA PROCESSED

The Personal Data We Process

The Personal Data We Process:

Identity: First Name and Surname
Contact: Email Address, Telephone Number
Customer: Package Selection
Personal Details: Title
Transaction Security: IP Address, Device ID, Device Type, Device Log Records [….]

3. PURPOSES FOR WHICH YOUR PERSONAL DATA IS PROCESSED

Demes Kablo Sanayi ve Ticaret A.Ş. processes your personal data on the legal basis set out in Article 5 of the Personal Data Protection Law (KVKK), namely that “the processing of data is necessary for the legitimate interests of the data controller”, in a manner that is (i) lawful and in accordance with the principles of good faith, (ii) accurate and, where necessary, up to date, (iii) for specific, explicit and legitimate purposes, (iiii) in a manner that is relevant, limited and proportionate to the purpose for which they are processed, and (iv) Retained in accordance with the rules set out in the relevant legislation or for as long as necessary for the purposes for which they are processed; and in accordance with the purposes and legal grounds specified below; your personal data is processed whilst maintaining its accuracy and up-to-date status as you have provided it to us or as it has been reported to us:

• Providing support to visitors via the website
• Carrying out website management and operational activities
• Identification and fulfilment of obligations arising from internet legislation
• Management of business relationships and/or relationships with other third parties,
• Facilitating access to the company by using a “map” application,
• Keeping visitors informed via social media accounts,
• Providing information to authorised persons, institutions and organisations
• Monitoring and improving the website experience
• Conducting communication activities
• Tracking and managing the application processes of job applicants
• Monitoring recruitment processes

4. METHODS AND LEGAL BASES FOR THE COLLECTION OF YOUR PERSONAL DATA

Our company collects your personal data electronically or in writing, using automated and semi-automated methods, via our website, digital and printed forms, and cookies, in accordance with the conditions and purposes of personal data processing set out in Articles 5 and 6 of the Law. Your data,

• Your visit to the https://www.demes.com/ website and the actions you take during your visit,
• Completing the form in the ‘Contact Us’ and ‘Human Resources’ sections,
• Cookies,

are collected through these means.

Your personal data may be processed by our Company in accordance with Articles 5 and 6 of the Personal Data Protection Law (KVKK) for the purposes listed above, either with your explicit consent or, in the exceptional cases specified by law, without your explicit consent. These exceptional cases are as follows:

• Where expressly provided for by law,
• The processing of data being necessary for the establishment, exercise or defence of a legal claim,
• The processing of data being necessary for the data controller to fulfil its legal obligations,
• The processing of data being necessary for the legitimate interests of the data controller, provided that such processing does not infringe upon the fundamental rights and freedoms of the data subject,

is carried out on these legal grounds.

5. THE RETENTION PERIOD FOR YOUR PERSONAL DATA

Your personal data will be processed in accordance with legislation on the protection of personal data—in particular the “KVKK”—as well as regulatory decisions, national and international agreements, and the retention periods stipulated in other legislation; and in any event, for as long as the purposes set out above remain valid. For example, your data is retained for a period of three years from the date of its recording.

6. TRANSFER OF YOUR PERSONAL DATA TO THIRD PARTIES AND/OR ABROAD

Your personal data will be processed in accordance with Articles 8 and 9 of the “KVKK” (Law on the Protection of Personal Data) regarding the transfer of personal data; based on the purposes set out in Article 3 of this document; and, where required by relevant legislation, primarily to authorised public institutions and organisations, as well as to third parties from whom we receive support in areas such as storage, archiving, security, call centres, service, healthcare and similar sectors; Group Companies with which we collaborate and/or from which we receive or provide services; business partners; supplier companies; banks; financial institutions; consultancy firms providing support in legal, tax and similar fields; and the dealers, suppliers, banks and insurance companies with which these firms work. Your data is not transferred abroad.

7. ACCESS TO YOUR PERSONAL DATA AND YOUR RIGHTS UNDER THE DATA PROTECTION ACT

In accordance with Article 11 of the “KVKK”, you may submit a request to our company, Demes Kablo Sanayi ve Ticaret A.Ş., to:

· Find out whether your personal data has been processed,
· Request information regarding the processing of your personal data if it has been processed,
· To find out the purpose of the processing of your personal data and whether they are being used in accordance with that purpose,
· To know the third parties to whom your personal data have been transferred within or outside the country,
· To request the rectification of your personal data if they have been processed incompletely or incorrectly,
· To request the erasure or destruction of your Personal Data where the grounds for its processing no longer apply, subject to an assessment in accordance with the principles of purpose, duration and lawfulness,
· To request that third parties to whom your Personal Data has been transferred be notified of any rectification, erasure or destruction of your Personal Data,
· To object to a decision made solely through the automated processing of your Personal Data where such a decision results in a negative outcome for you,
· To claim compensation for any loss or damage suffered as a result of the unlawful processing of your Personal Data

You have these rights.

In this context, you may submit your request regarding the above-mentioned rights to the email address provided below (which may change from time to time) or to the postal address provided below (which may change from time to time), either by hand-delivering a signed letter accompanied by documents verifying your identity, or by sending it via a notary.

Demes Kablo Sanayi ve Ticaret A.Ş. will process your request free of charge as soon as possible and within a maximum of 30 (thirty) days, depending on the nature of the request. Should any costs arise as a result of fulfilling your requests, we may only charge you the fees set out in the tariff determined by the Personal Data Protection Board and in the Communiqué on the Procedures and Principles for Applications to the Data Controller.

In this context, you may submit your request regarding the above rights by:
· completing the “Data Subject Request Form” and sending it to the email address provided below (which may change from time to time), or
· by submitting the “Data Subject Application Form” along with identity-verifying documents to the postal address provided below (which may change from time to time), either by hand-delivering a signed letter or via a notary public.

Demes Kablo Sanayi ve Ticaret A.Ş. will process your request free of charge as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request. Should any costs arise as a result of fulfilling your requests, we may only charge you the fees set out in the tariff determined by the Personal Data Protection Board.

Postal address: …………….
Email address: …………………….

This policy comes into effect on the date it is approved by you. Demes Kablo Sanayi ve Ticaret A.Ş. reserves the right to update this “KVKK Policy” at any time in line with changes to the applicable legislation.

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