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PERSONAL DATA PROCESSING INFORMATION NOTICE

 

1. Data Controller and Representative

Pursuant to the Personal Data Protection Law No. 6698 (“KVKK”), as Kıvanç Tekstil Konfeksiyon San. ve Dış Tic. Ltd. Şti., acting in the capacity of the data controller, your personal data may be collected by our Company in connection with the services provided by our Company and depending on our Company’s commercial activities; through automatic or non-automatic methods, via our Company departments and offices, Group Companies, website, social media platforms and similar channels, verbally, in writing or electronically. Within the scope of the purposes explained below, your personal data may be processed, recorded, stored, classified, updated in accordance with the law and the principles of honesty, and may be disclosed/transferred to third parties where permitted by the legislation and/or limited to the purpose for which they are processed.

Your personal data may be processed by being created and updated for as long as you benefit from the products and services offered by our Company and our Group Companies.

For this reason, as Kıvanç Tekstil Konfeksiyon San. ve Dış Tic. Ltd. Şti. (“STROM” or the “Company”), within the scope of the Personal Data Protection Law No. 6698 (“KVKK”) and the relevant legislation, we have prepared this Information Notice in order to inform our visitors, customers, employees, employee candidates, business partners and platform users (website and mobile application users) regarding the processing, storage and transfer of their personal data within the framework of our commercial activities.

2. Purpose of Processing Your Personal Data

Primarily in accordance with the KVKK legislation and the relevant legislation, your personal data or special categories of personal data are processed in compliance with the fundamental principles stipulated under the KVKK for purposes including but not limited to:

    • Ensuring the general and commercial security of our businesses,
    • Conducting recruitment processes,
    • Ensuring security processes, carrying out security camera recording processes, identity verification and authorization procedures for facility entrances,
    • Conducting Occupational Health and Safety (OHS) activities, coordinating training, keeping occupational accident records, coordinating Occupational Health and Environmental visitor procedures and emergency operations, conducting health-related processes, maintaining guest internet usage records, receiving communication forms,
    • Conducting our Company’s operational activities, business relationships and human resources processes, responding to requests of the relevant persons, providing services in the most appropriate manner, maintaining marketing and technical processes, and ensuring the commercial security of the Company.

Such personal data are securely stored in physical and/or electronic environments for a period appropriate to the purpose of processing.

Within the scope of these activities, STROM acts in compliance with all obligations stipulated by the KVKK and all relevant legislation concerning the protection of personal data.

3. Method and Legal Basis for Collecting Personal Data

Your personal data are obtained verbally, in writing or electronically for the purposes stated above, in order to provide the services offered by our Company within the legal framework and to duly fulfill our contractual and legal obligations completely and accurately.

The personal data collected based on these legal grounds may also be processed and transferred for the purposes specified in this notice within the scope of the personal data processing conditions and purposes set forth in Articles 5 and 6 of the KVKK.

Your personal data are collected through various channels such as camera recording systems, visitor declarations, training attendance records, forms, witnesses, unit supervisors, petitions, incident location information, authorized institutions, visitor internet access and registration systems, security cameras established to ensure the general and commercial security of our facilities and businesses, website, e-mail, personal applications, hand delivery, forms and declarations of employee candidates, based on the legal grounds specified above, for the purpose of improving our services and conducting our commercial activities.

Within this framework, your personal data may be processed and transferred with your explicit consent in accordance with the principles set forth in Article 4(2) of the KVKK, or without obtaining explicit consent where the conditions set forth in Articles 5(2) and 6(3) exist.

4. Transfer of Your Personal Data

Your personal data processed for the purposes explained above may be transferred by STROM, limited to the purposes specified above, to Group Companies, business partners, suppliers, customers, shareholders, authorized public institutions and organizations, private persons, companies providing support services required for carrying out our activities, and independent audit companies (including lawyers, tax consultants, auditors and third parties from whom we receive consultancy services), within the framework of the fundamental principles stipulated under the KVKK and the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK.

Due to legal regulations in our country, identity information, contact information and many other personal data are periodically shared with authorities expressly authorized under the legislation (such as the General Directorate of Security and other law enforcement agencies, the Social Security Institution, Tax Offices, Banks, Official Institutions and Organizations, Regulatory and Supervisory Authorities) or upon the request of an authorized authority.

In addition, your personal data may be shared with the person or institution authorized under a court order or upon the request of an administrative authority expressly authorized by law.

Apart from these, your personal data are shared to a limited extent with group companies and business partners (contractors, suppliers, external service providers, insurance companies, etc.) for the continuation of activities and improvement of service quality.

The purposes of sharing your personal data include, but are not limited to:

    • Ensuring the legal and commercial security of STROM, Group Companies and business partners (administrative communication operations carried out by our Company, ensuring the physical security and supervision of Company locations, evaluation processes regarding business partners/customers/suppliers and their authorized representatives or employees, reputation research processes, legal compliance, audits, financial affairs, etc.),
    • Maintaining STROM’s commercial activities,
    • Determining and implementing STROM’s commercial and business strategies,
    • Managing and conducting STROM’s human resources processes and employment policies.

Your personal data may also be transferred abroad by STROM:

    • With your explicit consent pursuant to Article 4(2) of the KVKK,
    • Without explicit consent where the conditions specified in Articles 5(2) and 6(3) exist and in accordance with Article 9 of the Law, to persons and organizations located only in foreign countries that have been declared by the Personal Data Protection Board (“Board”) as providing adequate protection,
    • Or, for countries where adequate protection has not been declared, provided that the data controllers in Türkiye and in the relevant foreign country undertake adequate protection in writing and the approval of the Board has been obtained for the relevant transfer.

Necessary security measures are taken when your personal data are shared.

5. Your Rights as the Relevant Person Pursuant to Article 11 of the KVKK

Pursuant to Article 11 of the KVKK, you have the following rights:

    • To learn whether your personal data are processed,
    • To request information if your personal data have been processed,
    • To learn the purpose of processing your personal data and whether they are used in accordance with that purpose,
    • To know the third parties to whom your personal data are transferred domestically or abroad,
    • To request correction of incomplete or inaccurate personal data and to request notification of such correction to third parties to whom the personal data have been transferred,
    • To request deletion or destruction of personal data where the reasons requiring processing no longer exist despite being processed in accordance with the KVKK and other relevant legislation, and to request notification of such action to third parties to whom the personal data have been transferred,
    • To object to a result arising against you through the exclusive analysis of processed data by automated systems,
    • To request compensation for damages arising from the unlawful processing of personal data.

6. Method of Exercising Your Rights and Responding to Your Requests

Pursuant to Article 13(1) of the KVKK, you may submit your request regarding the exercise of your rights specified above to our Company in writing or through other methods determined by the Personal Data Protection Board.

Accordingly, as personal data owners, by attaching the necessary documents identifying your identity (copy of identity card, etc.) and your explanations regarding the right you wish to exercise under Article 11 of the KVKK, you may print and complete the KVKK Application Information and Application Form available at www.strom.com.tr, and submit:

    • A signed copy of the form personally or via registered mail with return receipt to Kıvanç Tekstil Konfeksiyon San. ve Dış Tic. Ltd. Şti., Karadeniz Mah. Cebeci Cad. No:179/A Gaziosmanpaşa, İstanbul, together with documents identifying your identity (the envelope should bear the phrase “Information Request Within the Scope of the Personal Data Protection Law”),
    • Or through a Notary Public to the same address (the notification envelope should bear the phrase “Information Request Within the Scope of the Personal Data Protection Law”).

We reserve the right to reject your application if the information and documents submitted are incorrect or if the application is unauthorized.

Depending on the nature of your request, STROM will conclude your application free of charge as soon as possible and no later than thirty (30) days from the date it reaches us. However, if the process requires an additional cost, the fee determined by the Board shall be charged.

If your application is evaluated negatively, the justified reasons for rejection will be sent to the address specified in your application via e-mail or postal service.

For information other than KVKK applications, you may contact us via info@strom.com.tr

If new application methods are determined by the Personal Data Protection Board, these methods will be announced by STROM.

Kıvanç Tekstil Konfeksiyon San. ve Dış Tic. Ltd. Şti.