Clarification Text regarding the Law on the Protection of Personal Data
MAKİM MAKİNA TEKNOLOJİLERİ SANAYİ VE TİCARET A.Ş.
CLARIFICATION TEXT PURSUANT TO LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA
Makim Makina Teknolojileri Sanayi ve Ticaret A.Ş. (“MAKİM”) respects your privacy and attaches utmost importance to the security of your personal data. Within this scope, this clarification text has been prepared in order to inform you under Law No. 6698 on the Protection of Personal Data (the “Law”) and other relevant legislation.
As of October 7, 2016, Articles 8, 9, 11, 13, 14, 15, 16, 17, and 18 of Law No. 6698 on the Protection of Personal Data have entered into force.
The Law was adopted with the aim of protecting the fundamental rights and freedoms of individuals, particularly the right to privacy, in the processing of personal data, and of regulating the obligations of real and legal persons who process personal data and the principles and procedures to be followed. Therefore, this text is provided to fulfill the obligation of disclosure arising from the Law and is presented for the information and review of all individuals related to MAKİM, including suppliers, customers, supplier employees, customer employees, MAKİM employees, and all other persons whose personal data are processed by MAKİM in any manner.
MAKİM declares, represents, and undertakes that it shall not transfer, sell, rent, or in any way make available to third parties your personal data entrusted to us or submitted via forms on MAKİM’s website, including your name, email address, work and home addresses, phone number, and other personal information, except for legal purposes.
Processing of Your Personal Data
The processing of your personal data refers to any operation performed on such data, whether wholly or partly by automated means or by non-automated means provided that they form part of a data recording system, including but not limited to collection, recording, storage, preservation, alteration, reorganization, disclosure, transfer, acquisition, making available, classification, or prevention of use.
Data Controller and Representative
Pursuant to the Law, your personal data may be processed by MAKİM as the data controller within the scope explained in this document. MAKİM is responsible for determining the purposes and means of processing personal data registered in its database, as well as for the establishment and management of the data recording system.
Purposes for Processing Your Data
Your personal data may be processed in accordance with Articles 5 and 6 of the Law for the purposes of fulfilling legal obligations; carrying out necessary operational activities within the company to ensure the delivery of products and services offered by our company; conducting necessary work with the relevant business units and partners to offer products and services that suit your consumption and purchase preferences; ensuring the protection of the rights of real persons through effective human resource management; making, implementing, and executing commercial decisions by our company; and ensuring the legal safety of real persons with whom we have business relations as well as our Company itself.
Your personal data may be processed by MAKİM, as the data controller, without your explicit consent under the following conditions:
Where it is necessary to protect the life or physical integrity of the data subject or another person, who is unable to express consent due to actual impossibility or whose consent is not legally valid;
Where processing of personal data of the parties to a contract is necessary, provided that it is directly related to the performance of the contract;
Where it is necessary to process data for the data controller to fulfill its legal obligations;
Where the data is made public by the data subject;
Where processing is necessary for the establishment, exercise, or protection of a right;
Where processing is necessary for the legitimate interests of the data controller, provided that it does not violate the fundamental rights and freedoms of the data subject.
Your personal data may be used for the following purposes:
To communicate with you and others as part of the business;
To send important information about changes to our terms of service and our services, and other administrative information;
To ensure quality, training, and security improvements (e.g., in relation to phone calls made to our contact numbers that are recorded or monitored);
To resolve complaints and handle data access or correction requests;
To comply with applicable laws and regulatory obligations, including those outside your country of residence, such as anti-money laundering and counter-terrorism laws, to comply with legal processes, and to respond to requests from public and governmental authorities (including those outside your country of residence);
To manage our infrastructure and business operations and to comply with internal policies and procedures, including those related to auditing, finance and accounting, billing and collections, IT systems, data and website hosting, business continuity, and records, documents, and print management;
To determine and defend legal rights; to protect our operations, rights, privacy, security, or property, and/or those of our business partners, you, or others; and to pursue available remedies or limit our damages;
To conduct market research and analysis, including satisfaction surveys.
Transfer of Processed Personal Data: To Whom and For What Purpose
Your collected personal data may be transferred, in accordance with the conditions and purposes for personal data processing specified in Articles 8 and 9 of the Law, to our business partners, suppliers, shareholders, legally authorized public institutions, and private persons for the purposes of ensuring legal and commercial security for our Company and the parties in business relations with our Company; carrying out necessary work by our business units to benefit you from the products and services offered by our Company; customizing the products and services offered by our Company according to your tastes, usage habits, and needs; determining and implementing our Company’s commercial and business strategies; and executing our human resources policies.
Method and Legal Grounds for Collecting Personal Data
Your personal data is collected by our Company through various channels and based on different legal grounds to conduct our commercial activities. Your personal data collected on this legal basis may be processed and transferred for the purposes specified within the scope of the personal data processing conditions and purposes outlined in Articles 5 and 6 of the Law.
Rights of the Data Subject under Article 11 of the Law
If data subjects submit their requests concerning their rights, as listed below, to our Company through the methods specified in this Clarification Text, our Company will conclude the request free of charge as soon as possible and within no later than thirty (30) days depending on the nature of the request. However, if a fee is stipulated by the Personal Data Protection Board, the fee in the tariff determined by our Company shall be charged. In this context, data subjects have the right to:
Learn whether personal data is being processed;
Request information if personal data has been processed;
Learn the purpose of the processing and whether it is used in accordance with the purpose;
Know the third parties to whom personal data is transferred domestically or abroad;
Request correction of personal data if it is incomplete or incorrectly processed and request that the correction be notified to third parties to whom the data has been transferred;
Request deletion or destruction of personal data within the framework of the conditions set forth in Article 7 of the Law and request that the deletion or destruction be notified to third parties to whom the data has been transferred;
Object to any result arising to their detriment through the exclusive analysis of processed data via automated systems;
Request compensation for damages incurred due to unlawful processing of personal data.
Pursuant to Article 13(1) of the Law, you may submit your request to exercise your above-mentioned rights to our Company in writing or by other methods determined by the Personal Data Protection Board. Since the Board has not specified any other methods at this time, your application must be submitted to our Company in writing in accordance with the Law. The methods and procedures for submitting your written request within the scope of Article 11 of the Law are explained below.
To exercise your above-mentioned rights, please fill out the relevant application form and send a signed copy, along with documents identifying your identity, to the following address by hand delivery, through a notary public, by other methods specified in the Law, or by sending a securely signed electronic version to makim@hs01.kep.tr:
MAKİM Makina Teknolojileri Sanayi ve Ticaret A.Ş.
HAB Ankara Aerospace and Aviation Specialized Organized Industrial Zone,
Saray OSB Mah., G5 Street, No:4,
06980 Kahramankazan / ANKARA, TURKEY
DATA CONTROLLER
MAKİM MAKİNA TEKNOLOJİLERİ SANAYİ VE TİCARET A.Ş.