KVKK Agreement (Personal Data Protection)

Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. 

PERSONAL DATA PROTECTION POLICY

1. INLET

As a data controller Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. it is very important to protect the personal data of the people whose data are processed. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. he is aware of his responsibility to ensure that personal data is guaranteed in the form and conditions described by the legal regulations; Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. thus, it makes this responsibility a policy.

1. This policy Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. it determines the principles that must be followed while fulfilling the obligations to protect personal data and processing personal data in accordance with the Protection of Personal Data (KVK) regulations. In this context, for the processing and protection of personal data in accordance with the KVK regulations, Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. necessary arrangements are made by the company and the system that is needed to raise awareness is established.
2. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. it declares that it will act in accordance with the procedures to be applied depending on the policy and policy, as the data controller in terms of personal data in its own body.
3. PURPOSE AND SCOPE OF POLICY
   1. The purpose of this policy, Proje Endüstriyel Packaging Tekstil Tekstil Otom. Yellow and Tic. LTD.STI. to make statements about the personal data processing activity carried out in accordance with the KVK regulations and the systems adopted for the protection of personal data and to determine the principles regarding the processes. For the processes of processing and protection of personal data, this policy and Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. the process and the targeted aim of the process and targeted personal data is the legality and protection of other written policies within its body.
   2. This policy Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. it is applied in all activities carried out for the processing and protection of personal data, managed by
   3. This policy does not apply to data that does not have the characteristics of personal data.
   4. This policy is to be made in the context of changes in the purposes of processing and transferring personal data and in the collection methods, if required by KVK regulations. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. When deemed necessary, it can be changed from time to time.
4. IMPLEMENTATION OF POLICY AND KVK REGULATIONS
   1. In the process of processing and protection of personal data, KVK regulations will be applied first and KVK regulations will apply in case of incompatibility between these regulations and policy provisions.
   2. The update table is in Annex 1.
5. TANIMLAR

Personal Data: Any information about an identified or identifiable real person (including “personal data” as appropriate, as appropriate, “personal data” includes “personal data”).

Specially Qualified Personal Data: Biometric and genetic data, as well as data on race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, attire, association foundation or union membership, health, sexual life, criminal convictions and security measures.

Processing of Personal Data: Any data carried out on data such as obtaining, recording, storage, preservation, modification, reorganization, disclosure, transfer, transfer, acquisition, acquisition, classification or use of personal data, which are completely or partially automatic or non-automatically, provided that they are part of any data recording system, are available. kind of process.

KVKK: Law No. 6698 on the Protection of Personal Data.

KVK Regulations: Law No. 6698 on the Protection of Personal Data and the Regulation on the Protection of Personal Data, Communiqué and Related Legislation, Board of Personal Data Protection Board Decisions, Court Decisions and applicable international agreements for data protection and all kinds of other legislation.

Data Controller: The person who determines the purposes and means of processing personal data and manages the place where the data is kept systematically (data recording system).

Data Processor: A natural and legal person who processes personal data on his behalf based on the authority given by the data controller.

Personal Data Owner: Personal data Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. by or Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. the real person who is processed in his name.

Data Recording System: Registration system in which personal data is configured by being configured according to certain criteria.

Clear Consent: Consent on a particular subject, based on information and explained by free will.

Anonymization: Making personal data unavailable in any way, even by matching it with other data, to a certain or identifiable real person.

Application Form: Application Form for the applications to be made by the relevant person (personal data owner) to the data controller, prepared in accordance with the Law No. 6698 on the Protection of Personal Data and the Communiqué on the Application Procedures and Principles issued by the Personal Data Protection Authority, which includes the application made by the personal data owners to exercise their rights.

Board: Personal Data Protection Board.

POLICY: Personal Data Processing and Protection Policy.

1. PRINCIPLES TO BE APPLIED IN THE PROCESSING OF PERSONAL DATA
   1. Processing personal data in accordance with the law and honesty rules
      1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. it acts in accordance with the law and honesty rules during the processing of personal data; It takes into account the principles of proportionality and necessity, and processes personal data at a level that is suitable for data processing purposes.
   2. Keeping personal data accurate and up-to-date when needed
      1. It is necessary to keep personal data accurate and up-to-date in order to protect the fundamental rights and freedoms of the person concerned. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. it ensures that the personal data it processes is accurate and up-to-date and takes the necessary measures in this direction; If the personal data owner requests a change to his personal data, he/she updates the relevant personal data.
   3. Processing personal data for specific, clear and legitimate purposes
      1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. it clearly and precisely determines the purpose of processing personal data, which is legitimate and lawful; It is related to and as much as necessary for the personal data, the activity it carries out and the services it provides. For what purpose personal data will be processed Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. put forward by; In this direction, personal data owner is enlightened within the scope of KVK regulations and open consent is obtained from the personal data owner when necessary.
   4. Limited and measured processing of personal data for the purpose of processing
      1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI.processes personal data in a way that is suitable for the achievement of determined purposes; It avoids the processing of personal data that is not related to the realization of the purpose or that is not needed. In this context, personal data processing activities are not carried out to meet the needs that may arise later.. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. it processes personal data only in cases that are considered limited within the scope of KVK regulations (KVKK Articles 5.2 and 6.3) or for the purpose within the scope of express consent obtained from the personal data owner (KVKK Articles 5.1 and 6.2) and in accordance with the principle of proportionality.
   5. Keeping personal data for as long as stipulated in KVK regulations or for the purpose for which they are processed
      1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. , only keeps personal data for the period required for the purpose specified in the KVK regulations or for the purpose for which they are processed; In this context, first of all, it determines whether a period is foreseen for the storage of personal data in the KVK regulations, if a period has been determined, it acts in accordance with this period, if a period is not determined, it keeps personal data for the period required for the purpose of processing; In the event that the reasons that require the expiration or processing of the period are eliminated, personal data deletes, destroys or anonymizes personal data within the framework of obligations within the scope of KVK regulations, according to the nature of the data and the intended use.
2. PROCESSING OF PERSONAL DATA AND SPECIALLY QUALIFIED PERSONAL DATA BASED ON AND LIMITED TO THE PROCESSING CONDITIONS IN THE KVK REGULATIONS
   1. Processing of Personal Data
      1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. In accordance with the KVK regulations, it processes personal data based on one or more of the conditions in Article 5 of the KVKK regarding the processing of personal data; In accordance with Article 10 of the KVKK, it enlightens the personal data owners and provides the necessary information if the personal data owners request information.
3. 1. Proje Endüstriyel Packaging Tekstil Otom. yellow and Tic. LTD.STI. Personal data collected through web pages and mobile applications, Proje Endüstriyel Packaging Teknik Tekstil Otom. yellow and Tic. LTD.STI. processing by
      1. https://endustriyelkesim.com/ including sites and mobile applications such as the transaction, service and content broadcasting, announcement, information, event, etc. Requesting the sending of e-mails, performing membership transactions persons whose data are processed some personal information they providename, surname, phone address, e-mail, etc.) data owners in accordance with their consent and the provisions of the legislation, to be able to serve you better, made / celebration and event in the segregation activities aimed at constructing the activities and not sending unwanted e-mails, only Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. used in and Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. processed by.
      2. Proje Endüstriyel Packaging Tekstil Otom. yellow and Tic. LTD.ŞTİ. it does not share the information it collects from the contact forms with third parties, except for the persons with whom the data sharing agreement has been made, without the knowledge of the filler or otherwise, and does not use it for any reason other than activity.
4. 1. Explicit Consent
      1. One of the conditions for the processing of personal data is the express consent of the owner, and it is processed after the information to be made within the scope of the fulfillment of the obligation to the personal data owners and if the personal data owners give explicit consent. Personal data owners are notified of their rights before the explicit consent is obtained within the framework of the obligation to disclose.
5. 1. Processing of Personal Data Without Explicit Consent
      1. In cases where the processing of personal data is foreseen without express consent within the scope of KVK regulations (KVK Articles 5.2 and 6.3); Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. personal data will be able to process personal data without obtaining the express consent of the personal data owner and personal data within the limits drawn by the KVK regulations Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. processed by. The basis of the personal data processing activity may be only one of the following conditions, and more than one of these conditions may be the basis of the same personal data processing activity.
         1. The personal data of the data owner may be processed in accordance with the law, if clearly stipulated in the law.
         2. Personal data for the protection of the life or bodily integrity of the personal data owner or a person other than the personal data owner who is unable to disclose his consent due to actual impossibility or whose consent is not legally valid. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. may be processed without express consent.
         3. Personal data belonging to the parties of the contract, provided that they are directly related to the establishment, implementation, performance or termination of a contract, without the express consent of the personal data owners. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. can be processed by
         4. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. if it is necessary to process it to fulfill its legal obligations as a data controller, it may process its personal data without the explicit consent of the data owner.
         5. Personal data that has been made public by the personal data owner without explicit consent Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. can be processed by
         6. Processing of Personal Data Without Explicit Consent If the only possible way to establish, exercise or protect a right, personal data is without obtaining explicit consent. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. can be processed by
         7. Provided that it does not harm the fundamental rights and freedoms of the personal data owner, Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI.Personal data if data processing is mandatory for legitimate interests of Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI may be processed without express consent.
6. 1. Processing of Specialized Personal Data
      1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI., It acts in accordance with the regulations stipulated in terms of processing of specially qualified personal data in accordance with Article 6 of the KVKK. In accordance with Article 6 of the KVKK, personal data of special quality is processed in the following cases, provided that the sufficient measures to be determined by the Board are taken, without the express consent of the personal data owner:
         1. Specially qualified personal data other than the health and sexual life of the personal data owner, in cases stipulated in the law,
         2. Personal data of personal data regarding the health and sexual life of the personal data owner can only be processed by persons or authorized institutions and organizations who are under the obligation to keep secrets, for the purpose of protecting public health, the execution of preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing.
7. 1. 1. Within this scope Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. it evaluates whether personal data processing activities are within the scope of one of these conditions and stops personal data processing activities that are not based on one of these conditions, ex officio or upon application. When processing special personal data, the measures determined by the Board are taken.
8. DELETION, DESTRUCTION AND ANONYMIZATION OF PERSONAL DATA
   1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI.  Although it has been processed in accordance with the provisions of the relevant law, as regulated in Article 7 of the KVKK, if the reasons that require it to be processed are eliminated, it deletes, destroys or anonymizes personal data based on its own decision or upon the request of the personal data owner. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. in this regard, it has created a policy in accordance with the provisions of the Regulation on the Deletion, Destruction or Anonymization of KVKK and personal data, and in accordance with this policy, it destroys according to the nature of the data. Within this scope Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. periodic destruction dates have been determined by the
9. 1. Deletion, Destruction and Anonymization of Personal Data
      1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. the most commonly used erasure or destruction techniques are listed below
         1. Physical destruction: Personal data can also be processed in non-automatic ways, provided that it is a part of any data recording system. While such data is being deleted/destroyed, the system of physically destroying personal data in a way that cannot be used later is applied.
         2. Secure deletion from software: While deleting/destroying data that is processed in completely or partially automated ways and stored in digital media, methods are used to delete data from the relevant software in a way that cannot be recovered.
         3. Safely Deleted by Expert: Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI in some cases, he may agree with an expert to delete personal data on his behalf. In this case, personal data is safely deleted/destroyed by the expert in this field.
      2. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. the most widely used anonymization techniques are listed below:
         1. With data masking, personal data is anonymized by extracting the basic determinant information of personal data from the data set.
         2. With the consolidation method, many data are consolidated and personal data cannot be associated with any person.
         3. With the data derivation method, a more general content is created from the content of personal data and it is ensured that personal data cannot be associated with any person.
         4. With the data hash method, the values in the personal data set are mixed and the bond between the values and the people is broken.
      3. In accordance with Article 8 of the KVKK, anonymized personal data may be processed for purposes such as research, planning and statistics. Such processing is outside the scope of KVKK and the express consent of the personal data owner will not be sought.
10. TRANSFERRING AND PROCESSING PERSONAL DATA BY TRANSFEREES
    1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI., if there is an existing contract signed with the Personal Data Owner, in accordance with the conditions stipulated in the KVK regulations and by taking all the specified security measures, It can also be transferred abroad, unless otherwise regulated in the said contract and KVK regulations. Information about the transfer is included in the relevant lighting and/or open consent texts.
    2.  Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI., in the case of transferring personal data to a real or legal person, it also ensures that the persons to whom it transfers personal data comply with this policy. In this context, necessary protective arrangements are added to the contracts concluded with the transferred person. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI., it takes necessary technical and administrative measures to prevent violations of rights during data transfer.
    3. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. , , In accordance with Article 10 of the KVKK, it notifies the personal data owners the groups of people to whom personal data are transferred.
    4. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. In accordance with Articles 8 and 9 of the KVKK, it acts in accordance with the regulations stipulated in the Law on the transfer of personal data and put forward by the Board. The personal data collected and processed for the purposes specified in this Policy are specified in the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK, and in the lighting texts that the data owner can transfer in line with the express consent of the data owners.
11. 1. Transferring Personal Data to People in Turkey
       1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI., in line with the purposes of the personal data processing, which is in accordance with the law, it can transfer the personal data and special personal data of the personal data owner by taking the necessary security measures.
       2. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. it is the responsibility to act in accordance with the decision and relevant regulations stipulated in the KVKK and taken by the Board for the transfer of personal data. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. personal data and special data belonging to the relevant persons cannot be transferred to other real persons or legal entities without the express consent of the person concerned. Personal data is to persons in Turkey without express consent in exceptional cases specified in Article 5.2 and 6.3 of KVKK, or in other cases, provided that the express consent of the personal data owner is obtained (KVKK Articles 5.1 and 6.2) Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. can be transferred by. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI., If there is an existing contract signed with the Personal Data Owner by taking all the security measures specified in the legislation in accordance with the conditions stipulated in the KVKK and other relevant legislation and by taking all the security measures specified in the legislation, and Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. can be transferred to other business partners under its roof.
12. 1. Transfer of Personal Data to People Abroad
       1. Personal data shall be applied to persons who are abroad without express consent in exceptional cases specified in Articles 5 and 6 of KVKK or in other cases, provided that the express consent of the personal data owner is obtained. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. can be transferred by. In case of transfer of personal data in accordance with the KVK regulations without express consent, one of the following conditions is required for the foreign country to which it will be transferred:
          1. The foreign country to which the personal data is transferred is in the status of safe countries where there is sufficient protection by the board (you can check the current list on the website of the board).
          2. If the foreign country to which the transfer will take place is not included in the list of the board of the board, Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. and the data controllers in the relevant country are required to obtain permission from the Board by making a written commitment that adequate protection will be provided.
13. THE RIGHTS OF THE PERSONAL DATA OWNER AND THE USE OF THESE RIGHTS
    1. The rights of the personal data owner are given below.
       1. Find out if personal data is processed,
       2. Request information about personal data,
       3. To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
       4. Knowing the persons to whom personal data is transferred at home or abroad,
       5. Request correction of personal data in case of incomplete or incorrect processing and request that the transaction made within this scope be notified to the persons to whom the personal data is transferred,
       6. Request that personal data be deleted or destroyed in the event that the reasons that require it to be processed, although it has been processed in accordance with the KVK regulations,
       7. Objecting to this result in case of a result of the person being analyzed exclusively through automated systems,
       8. Request to be remedied in case of damage due to the processing of personal data in violation of KVK regulations.
    2. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI., In accordance with Article 10 of the KVKK, it informs the personal data owner’s rights and guides the personal data owner on how to use these rights regulated in Article 11 of the KVKK.
    3. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. it carries out the necessary channels, internal functioning, administrative and technical regulations in accordance with Article 13 of the KVKK in order to evaluate the rights of personal data owners and to provide the necessary information to personal data owners.
    4. Situations where personal data owner cannot claim their rights

Pursuant to Article 28 of the KVKK, since the following situations are excluded from the scope of the KVKK, the personal data owner cannot claim the rights listed in 9.1 on these issues:

1. 1. 1. Processing personal data for purposes such as research, planning and statistics by anonymizing it with official statistics,
      2. Processing of personal data for art, history, literature or scientific purposes or within the scope of freedom of expression, provided that it does not violate national defense, national security, public security, public order, economic security, privacy or personal rights, or not constitute a crime,
      3. Processing of personal data within the scope of preventive, protective and intelligence activities carried out by public institutions and organizations authorized by law to ensure national defense, national security, public security, public order or economic security,
      4. Processing of personal data by judicial authorities or execution authorities regarding investigation, prosecution, trial or execution proceedings.
2. 1. Pursuant to Article 28/2 of the KVKK; In the following cases, the personal data owner cannot claim the other rights listed in 9.1, except for the right to demand the remedy of the damage:
      1. The processing of personal data is necessary for the prevention of crime or crime investigation,
      2. Processing personal data that has been made public by the personal data owner,
      3. The processing of personal data is required for the execution of supervisory or regulatory duties and for disciplinary investigation or prosecution by the authorized and authorized public institutions and organizations and professional organizations in the nature of public institutions, based on the authority given by the law,
      4. The processing of personal data is necessary for the protection of the economic and financial interests of the state in relation to budget, tax and financial matters.
   2. The use of the rights of the personal data owner
      1. The personal data owner can fill the application form from the website or physically with the information and documents that will determine their claims regarding their rights specified in this Policy, and with the methods specified below or with other methods determined by the Board, and with a time stamped or wet signature. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI. ‘what can be forwarded for free. In addition, as a personal data owner, you must add the information and documents related to your request to your application.
      2. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI.We request your requests about obtaining more information about compliance and policies of KVK regulations and exercising your above-mentioned rights on our website in person or in writing. Aydınlı, Dersaadet Cd. No:65, 34953 Tuzla/Istanbul, as registered e-mail (our registered e-mail address projeendustriyel@hs01.kep.tr ( In the subject section, “Request for information within the scope of personal data protection legislation” will be written.) or as e-mail (Our Electronic Postal Addressinfo@endustriyelkesim.com (In the subject section, “Request for Information within the Scope of Personal Data Protection Legislation” will be written.)) Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI‘What can you forward?
      3. In order for the application listed above to be accepted as a valid application, in accordance with the notification on the application procedures and principles to the data controller, the person concerned;
         1. Signature, name, surname and if the application is written,
         2. For the citizens of the Republic of Turkey, T.C. ID number, nationality for foreigners, passport number or ID number, if any,
         3. The main settlement or workplace address of the notification,
         4. E-mail address, telephone and fax number based on notification, if any,
         5. The subject of the request is required to indicate the information. Otherwise, the application will not be considered as a valid application. In the applications to be made without filling out the application form, the matters listed here must be completed. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI‘What needs to be conveyed.
         6. In order for other persons to request an application on behalf of personal data owners, a special power of attorney issued by the data owner through a notary public must be present on behalf of the person to apply.
      4. Personal data owner’s request Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI in case of transmission Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI according to the nature of the request, it will finalize the relevant request within thirty days at the latest. If the transaction requested by the personal data owner requires an additional cost, the fee in the tariff determined by the Board can be charged. your application Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STIIf it is caused by the error of , the fee received is returned to the relevant person. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STImay request information from the relevant person in order to determine whether the applicant is the owner of personal data. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STIIn order to clarify the issues in the application of the personal data owner, , may ask a question about the application of the personal data owner. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI it accepts the request or rejects it by explaining its justification and notifies the relevant person in writing or electronically. If the request in the application is accepted, Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI is fulfilled by
3. 1. 1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI In the cases listed in 9.4. and/or in the following cases, the applicant may reject the application by explaining the reason.
         1. The request of the personal data owner is likely to hinder the rights and rights of other persons,
         2. Demands that require disproportionate effort,
         3. The requested information is public information.
      2. The right of personal data owner to complain to the Board
         1. In case the application is rejected in accordance with Article 14 of the Personal Data Owner KVKK, the answer given is insufficient or the application is not answered on time; Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI it can make a complaint to the Board within thirty days from the date of learning the answer of the .
4. PROTECTION OF PERSONAL DATA
   1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI, in accordance with Article 12 of the KVKK, takes all necessary technical and administrative measures to prevent the unlawful processing of the personal data it is processing, to prevent unlawful access to the data and to ensure the protection of the data, and to ensure the appropriate security level. making or making.
5. 1. Ensuring the security of personal data
      1. Technical and administrative measures to prevent unlawful processing of personal data

Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STIIt takes technical and administrative measures according to technological possibilities and implementation costs to ensure that personal data is processed in accordance with the law. The main measures taken are as follows:

1. 1. 1. 1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI personal data processing activities carried out within the body are audited through established technical systems and legal methods.
         2. When necessary, expert personnel are employed for technical issues or external support is obtained in this regard.
         3. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI employees, supplier employees and when the service is taken from outside, these persons and their employees are informed about the law of protection of personal data and the processing of personal data in accordance with the law.
         4. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI all the activities carried out by the business are analyzed in detail in terms of all business units, and as a result of this analysis, personal data processing activities are revealed in the specific activities of the relevant business units.
         5. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI personal data processing activities carried out by the relevant units; Obligations to be fulfilled in order to ensure compliance of these activities with the personal data processing conditions sought by KVKK, Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI it has been linked to written policies and procedures by the company, and each business unit has been informed about this issue and the issues to be considered in particular should be determined.
         6. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI contracts and documents that govern the legal relationship between employees and employees, Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STIExcept for the instructions of the .
         7. The data controller is informed by the expert appointed in this regard about the law of protection of personal data and taking necessary measures in accordance with this law.
      2. Technical and administrative measures to prevent illegal access to personal data

Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI the nature of the data to be protected takes technical and administrative measures according to the nature of the data to be protected in order to prevent the disclosure, access, transfer or all unlawful access of personal data from the disclosure of or unauthorized. The main technical and administrative measures taken are as follows:

1. 1. 1. 1. Technical measures are taken in line with the developments in technology.
         2. Access and authorization technical solutions are put into effect in accordance with the legal compliance requirements determined on the basis of the business unit.
         3. Access powers are restricted and powers are regularly reviewed. Former employees are restricted to access, accounts are closed.
         4. The necessary technological solutions are produced by re-evaluating the risk issues in terms of the technical measures taken.
         5. Software and hardware containing virus protection systems and firewalls are installed.
         6. Personnel knowledgeable in technical matters are employed or external support is obtained.
         7. Employees, supplier employees and in cases where the service is taken from outside, these individuals or their employees are informed about the technical measures to be taken to prevent unlawful access to personal data.
         8. Personal Data Processing on a Business Unit Based In accordance with the legal compliance requirements, access and authorization processes are designed and implemented.
         9. Employees are informed that they cannot disclose the personal data they have learned to someone else in violation of the KVK regulations and cannot use them for the purpose of processing, and that their obligations regarding the security and confidentiality of personal data will continue after the end of the business relationship, and the necessary commitments are received from them.
         10. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI special documents containing personal data are protected / tried to be protected by encrypted (encrypted) systems. In this context, personal data is not stored in common areas, on the desktop or anywhere that is accessible to unauthorized persons. Files and folders containing personal data, etc. Documents are not moved to desktop or public folder, Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STIWithout prior written consent of , the information on computers is USB, etc. It cannot be transferred to another device, it cannot be taken out of the organizational structure.
         11. In case of security measures requested or additionally requested for the security of personal data within the scope of KVK regulations, all employees are obliged to comply with additional security measures and to ensure the continuity of these security measures.
         12. In order to be cautious against any personal data security violations, the crisis and reputation management were discussed, and in this context, the Board and the relevant person were designed to inform them.
      2. Storage of personal data:

Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI, it takes the necessary technical and administrative measures according to the technological possibilities and the cost of implementation in order to prevent the storage, loss or change of personal data in safe environments and for unlawful purposes. The main technical and administrative measures taken are as follows:

1. 1. 1. 1. Systems suitable for technological developments are used for the secure storage of personal data. The necessary technological solutions are produced by re-evaluating the risk issues.
         2. Expert personnel are employed in technical matters or foreign service is purchased.
         3. Backup programs are used in accordance with the law to ensure that personal data is stored securely.
         4. Access to data storage areas containing personal data are restricted, inappropriate accesses or access attempts are logged and instantly communicated to the relevant parties.
         5. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI in the event that an outside service is received due to technical requirements for the storage of personal data by the relevant companies to which the personal data is transferred in accordance with the law; There are provisions regarding the persons to whom personal data are transferred, taking the necessary security measures to protect personal data and ensuring that these measures are followed in their own institutions.
      2. Inspection of measures taken to protect personal data
         1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI, In accordance with Article 12 of the KVKK, it carries out or has the necessary audits carried out in order to ensure the implementation of the provisions of the KVKK within its own body. These inspection results Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI’within the scope of the internal functioning of the subject, the relevant unit is reported to the relevant unit and necessary activities are carried out to improve the measures taken.
      3. Measures to be taken in case of unauthorized disclosure of personal data
         1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI, If the personal data processed in accordance with Article 12 of the KVKK is obtained by others through illegal means, this situation will be reported to the relevant personal data owner and the board as soon as possible. If deemed necessary by the Board, this situation may be announced on the Board’s website or by any other method.
2. Proje Endüstriyel Packaging Tekstil Otom. yellow and Tic. CLASSIFICATION OF PERSONAL DATA PROCESSED BY LTD.ŞTİ
   1. Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.STI in front of Proje Endüstriyel Packaging Tekstil Otom. Yellow and Tic. LTD.ŞTİ’in line with the legitimate and lawful personal data processing purposes of In accordance with all obligations regulated in KVKK, personal data in the following classes are processed by informing the relevant persons in accordance with Article 10 of the KVKK. 11.2. specified in the article.

1. 1. In the table below, the personal data owner classes and which types of personal data of the people in these classes are processed are detailed.

APPENDIX.1 Update Table

Changes made to this policy are listed in the table below.