PRIVACY POLICY

PREFACE

We at Mehmet Özen Mak. San. Ve Tic. A.Ş. attach great importance to the protection of your personal data and/or special categories of personal data under the Personal Data Protection Law No. 6698. We are very sensitive about the storage of all the personal data and/or special categories of personal data communicated to our company through various channels. In this context, we at Mehmet Özen Mak. San. Ve Tic. A.Ş. have taken all necessary technical and administrative measures to comply with the provisions of the Law on the Protection of Personal Data No. 6698 and similar legislation. We would like to emphasize that we will protect your rights which are guaranteed by the Laws. In this context, you can safely share your personal data with us, and communicate your suggestions, complaints and hesitations.

We share our Privacy Policy which is very important in relation to the protection of personal data and which is introduced in our Company.

                                                                                                 Mehmet Özen Mak. San. Ve Tic. A.Ş.

1. PURPOSE OF PRIVACY POLICY

Protection of personal data and compliance with the laws are our fundamental principles. Our company has always been very sensitive about the protection of personal and/or special categories of personal data. As Mehmet Özen Mak. San. Ve Tic. A.Ş (hereinafter “Mehmet Özen” or “Company”), we kept the personal and/or special categories of personal data we obtained from you in all projects we carried out, and never shared them with third parties. Under the Law on the Protection of Personal Data No. 6698, we revised our in-house regulations and took all necessary technical and administrative measures. We as Mehmet Özen accept, represent and undertake to comply with all obligations introduced by the Laws in the future.

2. SCOPE OF PRIVACY POLICY

This Privacy Policy has been prepared in accordance with the Law on the Protection of Personal Data No. 6698.

Your personal data and/or special categories of personal data is obtained with your consent or in accordance with the law. Your data are being used for the following purposes:

- To ensure Company security,

- To provide perfect service to our customers,

- To perform our commercial activities,

- To solve your problems quickly,

- To increase our quality. 

Certain personal data and/or special categories of personal data are anonymized through procedures foreseen by the Law. Data used for statistical purposes is not subject to the Law or the scope of our policy. We as Mehmet Özen reserve the right to change our data policy, regulation and directive in order to protect personal data in accordance with the Law.

This privacy policy aims to protect the data obtained from real and legal persons Mehmet Özen is business partners with, our clients, employees and all other persons in some way. It contains various arrangements aimed at realizing the stated purpose.

3. FUNDAMENTAL PRINCIPLES REGARDING THE PROCESSING OF PERSONAL AND/OR SPECIAL CATEGORIES OF PERSONAL DATA

Our fundamental principles regarding the processing of personal data and/or special categories of personal data are below. In this context, these principles will apply to the data Mehmet Özen obtains or processes based on consent or according to the Law.

- Legality: Mehmet Özen inquires the source and legality of the personal data and/or sensitive data which it receives from real and legal persons and which it obtains through various methods. In this context, the legality of the method by which data are obtained is important for Mehmet Özen.

- Conformity with the principle of integrity: Mehmet Özen inquires the source of the personal data and/or sensitive data which it receives from real and legal persons and which it obtains through various methods. Mehmet Özen questions the source of the personal data and/or sensitive personal collected by itself or received from other companies. In this context, Mehmet Özen places importance on collection of such data under the rules of lawfulness and fairness.

- Relevancy, limited with the purposes for which they are processed: Mehmet Özen uses the personal data and/or sensitive data which it obtains through various methods only for the purposes for which they are processed and to the extent required by the service.

- Accuracy of Personal Data / Special categories of personal data : Mehmet Özen places importance on accuracy and correctness of all the the personal data and/or sensitive data which it receives from real and legal persons and which it obtains through various methods.

- Being up-to-date when necessary: Mehmet Özen places importance to the notification of any change in the personal data and/or sensitive data which it obtains through various methods to the company, and to updating this data when changes are notified.

- Processing for specific and legitimate purposes: Mehmet Özen processes data as limited to the purposes for which the consent of relevant individuals is taken during the provision of the service. Mehmet Özen shall not process or use or allow to use of data other than purposes of the business in question.

-Storage for the duration prescribed by the applicable legislation or the purpose for which they are processed: Mehmet Özen internally stores personal data and/or special categories of personal data for periods foreseen under the Law. It stores the contractual personal data for prescription and dispute periods under the Law and requirements of the Commercial Code, Code of Obligations and the Tax Law. Accordingly, it anonymizes, destroys or deletes the data when such purposes cease to exist. These data are deleted or destroyed according to the “STORING, TRANSFERRING AND ANONYMIZING PERSONAL DATA POLICY”.

4. RIGHTS OF DATA SUBJECT REQUESTING INFORMATION UNDER ARTICLE 11 OF PERSONAL DATA PROTECTION LAW

Article 11 of the Law on Protection of Personal Data No. 6698 regulates the rights of the data subject. The law refers to the data subject, and entitles him/her to make certain requests regarding the processing of data. According to this article, the data subject has the following rights:

a)Learn whether or not her/his personal data have been processed;

b)Request information as to processing if her/his data have been processed;

c)Learn the purpose of processing of the personal data and whether data are used in accordance with their purpose,

ç)Know the third parties in the country or abroad to whom personal data have been transferred,

d)Request rectification in case personal data are processed incompletely or inaccurately;

e)Request deletion or destruction of personal data within the framework of the conditions set forth under article 7 entitled “Deletion, Destruction, and Anonymization of Personal Data”;

f)Request notification of the operations made as per indents (d) and (e) to third parties to whom personal data have been transferred

g)Object to occurrence of any result that is to her/his detriment by means of analysis of personal data exclusively through automated systems;

h)Request compensation for the damages in case the person incurs damages due to unlawful processing of personal data.

“Information Request Form Under Law No. 6698” regarding the application process enabling you to exercise your rights above has been prepared and published in the website by Mehmet Özen. You can exercise your above-mentioned rights by following the application procedures and principles stated in the website.

5. DELETION, DESTRUCTION AND ANONYMIZATION OF PERSONAL DATA

Personal data and/or special categories of personal data are deleted, destroyed or anonymized by our company when legal prescription or storage durations are expired, when legal proceedings are finalized or other requirements cease to exist. These data are deleted and destroyed according to the “PERSONAL DATA STORAGE, TRANSFER, DELETION AND ANONYMIZATION POLICY” Deletion, destruction and anonymization procedures are carried out upon the request by the data subject or ex officio by Mehmet Özen.

6. SCRIMPING POLICY

Scrimping Policy is also called maximum savings policy. The personal data and/or special categories of personal data received by our company through various channels are transferred to our Company’s system. According to the said principle, the data are processed into the system as required. Data which will be collected by Mehmet Özen are determined according to the purpose and may vary. Accordingly, data are collected for a specific purpose and unnecessary data are not collected. Redundant information is not stored in the system, they are deleted or anonymized. However, these data may be used for statistical purposes.

7. DATA CONFIDENTIALITY AND SECURITY

Mehmet Özen places importance to the confidentiality of your personal data and/or special categories of personal data. Accordingly, your personal data and/or special categories of personal data which reaches to our Company are confidential. Mehmet Özen keeps the said data confidential at every stage of its commercial operations. In this context, it fully complies with the Company privacy policy. All necessary technical and administrative measures are taken to protect the personal data and/or sensitive personal data collected by our Company through various methods, to prevent any harm to the rights of data subjects, and to protect the data. Moreover, we require the companies with whom we share the personal data and/or sensitive personal date within the framework of legality to protect them. Our softwares are continuously updated and renewed. We conform to all technological requirements and comply with relevant standards to ensure maximum protection.

8. DATA CURRENCY

Currency is of utmost importance in Mehmet Özen. Personal data and/or special categories of personal data obtained through various methods are processed upon request and updated. Mehmet Özen takes necessary measures regarding this matter.

9. DATA ACCURACY

Mehmet Özen places importance to the accuracy of Personal data and/or special categories of personal data declared. Mehmet Özen is not required to and also is prohibited under laws and our business principles to investigate the accuracy of the data submitted by our customers or persons who contacted with us. In this context, data submitted as such are deemed to be accurate.

10. PURPOSES OF PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA PROCESSING

The processing of personal data and/or special categories of personal data processing by our company shall be executed in line with the purposes stipulated in letter of clarification issued by Mehmet Özen. You can read the Disclosure Text at Mehmet Özen’s website.

11. PROCESSING PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA

In order to carry out its commercial activities, perform its services and realize its legitimate purposes, Mehmet Özen may process your personal data and/or special categories of personal data. Such data will not be used for any services contrary to laws or for illegitimate purposes. We are particularly careful about processing special categories of personal data. Our Company complies with its “Special categories of personal data Protection and Processing Policy” when processing special categories of personal data. Moreover, all necessary and adequate measures determined by the Board are taken when processing special categories of personal data.

12. PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA PROCESSING FOR ADVERTISING PURPOSES

The consent of the receiver must be obtained in relation to electronic messages sent for advertisement purposes. Accordingly, electronic messages can be sent to persons only with prior consent. This matter has been clearly regulated in the “Law on the Regulation of E-Commerce” and the “Regulation on Commercial Communication and Commercial Electronic Messages.” Mehmet Özen observes the provisions of the above-mentioned Law when sending commercial electronic messages. We also obey the principle of obtaining the consent of the customer according to the Law, and the details of “the consent”. The said consent can be obtained via any electronic communication channel or at physical medium in written. The existence of the receiver’s full name and electronic communication address denotes to the affirmative declaration of intention implying that the receiver accepts to receive commercial electronic messages. The consent to be obtained should cover all commercial electronic messages that are sent to the electronic communication addresses of the recipients to promote and market the goods and services of the company, to promote the business or to increase the recognition level of the company with contents including greetings and wishes.

13. DATA PROCESSING DUE TO LEGAL OBLIGATIONS OF THE COMPANY AND BEING STIPULATED EXPLICITLY IN THE LAW

Personal data may be processed without prior consent when it’s stipulated explicitly in the relevant legislation and/or to fulfill a legal obligation specified in the legislation. Type and scope of the data processes are required for data processing activity that is permitted by the Laws and they should comply with the relevant legal provisions.

14. COLLECTION AND PROCESSING OF DATA FOR CONTRACTUAL RELATIONSHIP

If a contractual relationship was formed with existing and potential customers, the collected personal data may be used by Mehmet Özen without their approval. However, this use shall be for the purposes of performing the service, the contract, execution of the commercial activity, and as required by the services. These data may be updated by contacting the customers.

15. PERSONAL DATA SHARED WITH BUSINESS AND SOLUTION PARTNERS

Mehmet Özen adopts as a principle to act in compliance with the laws when exchanging the data. Accordingly, we act according to the relevant provisions of the Law when sharing data with business and solution partners. Mehmet Özen shares personal data with the business and solution partners only as much as necessary for the performance of the service and the execution of the commercial activity while complying with the principle of data confidentiality. We also request our business and solution partners with whom we share data to take necessary administrative and technical measures to ensure data security.

16. PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA PROCESSED WITH AUTOMATIC SYSTEMS

The data from the information obtained via automatic systems without the explicit consent of the persons shall not be used against the person. However, Mehmet Özen may take decisions regarding the persons it will process by using the data within its own system. Mehmet Özen complies with all relevant provisions of law with respect to personal data and/or special categories of personal data which are processed via automatic systems.

17. PROCESSING PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA OF THE EMPLOYEES OF MEHMET ÖZEN MAK. SAN. VE TİC. A.Ş. WITHIN THE FRAMEWORK OF LEGAL OBLIGATIONS

Mehmet Özen may process personal data of its employees without an explicit consent if such processing is explicitly required by the legislation or in order to fulfill a legal obligation as prescribed by the applicable legislation. Such processing shall be restricted with the performance of the obligations arising under the Law.

PROCESSING PERSONAL DATA BASED ON A CONTRACT AND BUSINESS RELATIONSHIP:PROCESSING PERSONAL DATA BASED ON A CONTRACT AND BUSINESS RELATIONSHIP: The personal data of the employees may be reasonably processed without the consent of the employees to the extent of the requirements of establishing a business relationship between the company and the employees. However, Mehmet Özen hereby undertakes the protection and the confidentiality of the data of the employees, and any measures necessary regarding this matter.

PROCESSING SPECIAL CATEGORIES OF PERSONAL DATA OF EMPLOYEES: According to Law on Protection of Personal Data No. 6698, it is necessary to obtain the consent of the person whose data will be processed, and to take adequate measures determined by the Board for the processing special categories of personal data In accordance with the Law and the principles set forth by the Board, Mehmet Özen obtains the consent of the person show data will be processed and takes the necessary measures determined by the Board when processing the special categories of personal data of the employee. However, special categories of personal data may be processed without the consent of the relevant person limited to and related to the cases permitted by the Law.

PERSONAL DATA PROCESS VIA AUTOMATIC SYSTEMS:PERSONAL DATA PROCESS VIA AUTOMATIC SYSTEMS Certain personal data of employees may be processed via automatic systems. Such data may be used in performance assessments, keeping statistical data, internal promotions and ratings. The employees are entitled to object the results that are against them. Objection must be filed in accordance with internal rules and procedures. Objections of the employees are also evaluated within the Company.

PROCESSING PERSONAL DATA IN FAVOR OF EMPLOYEES:Mehmet Özen may process the personal data of the employees without obtaining their consent for the procedures in favor of them. Mehmet Özen may process personal data of his employees for the disputes arising out of business relationships.

TELECOMMUNICATION, INTERNET AND COMMUNICATION:Mehmet Özen may internally allocate computers, phones, cars, software and e-mail to employees for facilitating the performance of the business. Company can inspect and audit all data stored on such means. Employee may not use any of such means allocated by the company for private purposes. He/She must use them only for business purposes. From the start of business relationship with Mehmet Özen, employee accepts, represents and undertake not to store any data and information other than those required for business purposes on the computers, phones or other means allocated to him/her.

18. LOCAL AND OVERSEAS TRANSFER OF PERSONAL DATA

Mehmet Özen may transfer personal data to business and solution partners, trade partners and controlling shareholders in order to perform its services and business activities. Mehmet Özen may also transfer personal data to its suppliers provided that the same is limited to enable Mehmet Özen to receive external services from suppliers that are required for it to carry out its business activities. Accordingly, Mehmet Özen is authorized to transfer the personal data locally or internationally under the requirements of the Law and within the framework of the principles set by the Board.

19. RIGHTS OF THE DATA SUBJECT

Article 11 of the Law on Protection of Personal Data regulates the rights of the data subject. Mehmet Özen hereby agrees that the relevant person must provide his/her consent before processing the data within the scope of the Law and he/she reserves the right to determine the destiny of the data after the data are processed. Relevant persons can access the “Information Request Form Under Law No. 6698” at Mehmet Özen’s website. Data Subject, with respect to personal data, has right to

a) Learn whether or not her/his personal data have been processed;

b) Request information as to processing if her/his data have been processed;

c) Learn the purpose of processing of the personal data and whether data are used in accordance with their purpose,

ç) Know the third parties in the country or abroad to whom personal data have been transferred,

d) Request rectification in case personal data are processed incompletely or inaccurately,

e) Request deletion or destruction of personal data within the framework of the conditions set forth under article 7,

f) Request notification of the operations made as per indents (d) and (e) to third parties to whom personal data have been transferred,

g) Object to occurrence of any result that is to her/his detriment by means of analysis of personal data exclusively through automated systems,

h) Request compensation for the damages in case the person incurs damages due to unlawful processing of personal data by applying to the data controller.

Applications regarding the requests listed above can be made via the Company website or by completely filling out an application form obtained from the Company. The application form bearing the wet signature of the applicant can be sent to our KEP address (our company’s registered address) via Notary Public, registered letter with return receipt, or to \[info@company name]. Applications must be made by the relevant person. Applications made for requesting information about another person’s personal data are not accepted In additions, applications made on behalf of another person will not be replied by the Company. If Mehmet Özen determines that information request is made on behalf of another person, Mehmet Özen shall be entitled to sue and claims. The requests by the relevant persons shall be replied by Mehmet Özen within thirty days from its receipt. Mehmet Özen may request additional information and documents from the applicant when necessary. The relevant person has no rights with regards to personal data anonymized within the Company.

20. PRINCIPLE CONFIDENTIALITY

The data of the employees and other persons within Mehmet Özen are confidential. Nobody can use, reproduce, transfer or copy personal data and/or special categories of personal data for other purposes outside the scope of the contract, apart from the business purposes, and for purposes other than complying with the Law.

21. AUDIT AND PROCESS SECURITY

All technical and administrative precautions are taken necessary to protect personal data collected via various methods and prevent unauthorized people to access them and not to cause our customers and prospective customers to suffer from such breaches. Additionally, we request the companies with whom we share personal data and/or special categories of personal data within the framework of Legality to protect such data. In this respect, we continuously update, renew and develop our software. All technological requirements are met and standards are conformed to in order to provide maximum protection. In addition, Mehmet Özen conducts or has conducted all necessary internal and external audits necessary for the protection of personal data and/or special categories of personal data.

22. NOTIFICATION OF PERSONAL DATA VIOLATIONS

Mehmet Özen shall immediately act to remedy any violations of personal data notified to it. It shall take all necessary actions to minimize the damage or indemnify to the relevant person. In case the personal data and/or special categories of personal data are obtained by the unauthorized third persons, this situation shall immediately be notified to the Personal Data Protection Board. You can file and application as per the procedures provided at the Company website regarding the notification of the violations. To request information about data, click here for the “Information Request form Under Law No. 6698”.

23. UPDATE

Changes to this Privacy Policy are listed in the table below.