MAKİM MAKİNA TEKNOLOJİLERİ SAN. VE TİC. A.Ş. (MAKİM)
SWITCHBOARD CALL RECORDING CLARIFICATION TEXT

Clarification Text on the Processing of Personal Data Pursuant to Law No. 6698 Regarding Telephone Call Recordings

This clarification text is shared by MAKİM Makina Teknolojileri San. ve Tic. A.Ş. (“MAKİM”) in accordance with Article 10 of Law No. 6698 on the Protection of Personal Data (“LPPD”) and relevant legislation, regarding the processing of personal data obtained from real persons who communicate with authorized personnel of the institution via telephone.

This Clarification Text has been prepared to inform you of the methods for collecting personal data, the purposes and legal grounds for processing, and your rights regarding to whom the data may be transferred.

Legal Basis, Collection Method, and Legal Grounds for the Call Recording Activity

Your personal data is collected and stored through the MAKİM switchboard system via voice recording, solely during the verbal communication you establish with the operator.

Your personal data is processed based on the legal ground specified in Article 5/2-(f) of the LPPD: “processing is necessary for the legitimate interests of the data controller, provided that this processing does not violate the fundamental rights and freedoms of the data subject.”

Your identity information, contact information, voice recording, and any personal data shared during the call may be processed for the following limited purposes:

• To properly address the caller,

• To confirm the call,

• To ensure transaction security,

• To be used as evidence in case of potential future disputes,

• To record and examine notifications such as requests, suggestions, satisfaction, complaints, and objections and respond when necessary, as well as to monitor service quality,

• To ensure legal security,

• To fulfill legal rights and obligations.

Ensuring the Security of the Collected Data

MAKİM implements all necessary technical and administrative measures to ensure the security of personal data obtained through the switchboard call recordings, in accordance with Article 12 of the LPPD.

Retention Period of Personal Data Obtained via Switchboard Call Recordings

The recorded personal data will be retained in accordance with the law and related regulations, for the maximum period required for the purpose for which they were processed, and in any case, for no longer than the legal statute of limitations.

Personal data obtained through MAKİM’s switchboard call system is retained for 1 month.

Transfer of Personal Data Obtained Through Switchboard Call Recordings and Purpose of Transfer

Only a limited number of employees have access to the data obtained from switchboard recordings. These data may be transferred to authorized public institutions within the framework of the data processing conditions and purposes set forth in Articles 8 and 9 of the LPPD (e.g., based on a written request by a prosecutor or judge during an investigation). Aside from the situations stated above, your call recordings are not shared with third parties and are not transferred abroad.

Employees with access to the recordings are required to sign a confidentiality agreement and declare that they will maintain the confidentiality of the data they access.

Deletion, Destruction, or Anonymization of Personal Data Obtained via Switchboard Call Recordings

Even if your personal data processed through the voice recordings subject to this clarification are processed lawfully in accordance with Article 138 of the Turkish Penal Code and Article 7 of the LPPD, they will be deleted, destroyed, or anonymized ex officio by MAKİM or upon request by the data subject when the reasons requiring their processing no longer exist. Additionally, the voice recordings are automatically deleted after a one-month retention period without any manual intervention.

Rights of the Data Subject

MAKİM is responsible for taking the necessary administrative and technical measures to effectively, promptly, and correctly respond to requests submitted in accordance with this Clarification Text.

You may submit your requests regarding your rights listed under Article 11 of the LPPD concerning “data subjects” to MAKİM in writing or by using the registered electronic mail (KEP) address, secure electronic signature, mobile signature, or the email address previously provided to and registered in MAKİM’s system, or via a dedicated software or application developed for the purpose of the application, in accordance with the “Communiqué on the Principles and Procedures of Application to the Data Controller.”

MAKİM provides alternative methods to facilitate the use of your right to access information and to respond to your requests in the shortest time possible.

If the data subject submits a request to MAKİM in accordance with the law and principles of good faith, the Company will conclude the request as soon as possible and within thirty (30) days at the latest from the date of receipt, depending on the nature of the request, free of charge. However, if the process requires additional cost, a fee may be charged in accordance with the tariff determined by the Personal Data Protection Board.

If MAKİM responds to your request in writing, no fee will be charged for the first ten (10) pages. However, a processing fee of 1 Turkish Lira may be charged for each page over ten pages, as stated in the applicable legislation.

Data Controller:
MAKİM MAKİNA TEKNOLOJİLERİ SAN. VE TİC. A.Ş.

Wet Signature: You may apply using the Data Subject Application Form.
Address: HAB Ankara Aerospace and Aviation Specialized Organized Industrial Zone, Saray OSB Mah., G5 Street, No:4, 06980, Kahramankazan / ANKARA, TURKEY

MAKİM reserves the right to reject your application if the submitted information or documents are incorrect or if the application is unauthorized, lacks a valid basis, or is found to be submitted for abuse.

MAKİM may respond to the data subject in writing or electronically.

MAKİM reserves the right to verify your identity before responding.

Respectfully submitted to the public.