Purpose
Akcanglass Cam San. And Trade. Inc. (as "Akcanglass" for short); our customers,
personal data of real persons, including our suppliers and employees, in accordance with the Constitution of the Republic of Turkey and
Personal Data No. 6698 and international agreements to which our country is a party regarding human rights
Processing in accordance with the relevant legislation, especially the Law on Protection of Personal Data ("KVKK") and the relevant data
Our priority is to ensure that people use their rights effectively.
For this reason, but not limited to the following; of our employees, suppliers, customers, internet
of our users who visit our site, in short, automatic or
All personal information obtained by non-automatic means, provided that it is part of any data recording system
Akcanglass Personal Data processing, storage and transfer of data
We do this in accordance with the Protection and Processing Policy (for short, the "Policy").
Protection of personal data and fundamental rights and freedoms of natural persons whose personal data are collected
Observation of personal data is the basic principle of our policy regarding the processing of personal data. Therefore, personal data
protection of privacy, confidentiality of communications, thoughts and beliefs.
We maintain freedom by observing the rights to use effective legal remedies. For the protection of personal data
All administrative and technical protection required by the nature of the relevant data in accordance with the legislation and current technology
We are taking precautions.
This Policy applies to personal data shared during our commercial or social responsibility and similar activities.
What we follow regarding processing, storage, transfer and deletion within the framework of the principles mentioned in KVKK
explains the methods.
Scope
Our customers, business contacts, business partners, employees, suppliers, potential customers
All personal data processed by the Company, including and other third parties, are subject to this Policy.
is within the scope of
Our policy is to process all personal data owned or managed by the Company.
It is implemented in activities related to KVKK and other relevant legislation regarding personal data and
It has been handled and prepared considering international standards.
Definition and Abbreviations
In this section, special terms and expressions, concepts, abbreviations, etc. used in the Policy. is explained briefly.
Company: Akcanglass Cam San. And Trade. Inc.
Explicit Consent: Regarding a specific issue, based on being informed and free will, leaving no room for hesitation
Approval given openly and limited to that transaction only.
Employee: Company personnel
Personal Data Owner (Relevant Person): The real person whose personal data is processed.
Personal Data: Any information regarding an identified or identifiable natural person.
Special Personal Data: Persons' race, ethnic origin, political opinion, philosophical belief, religion, sect,
or other beliefs, appearance and dress, association, foundation or union membership, health, sexual life, criminal
data regarding his conviction and security measures, as well as biometric and genetic data.
Processing of Personal Data: Processing of personal data wholly or partially automated or any data recording
Obtaining, recording and storing by non-automatic means, provided that it is part of the system
storing, changing, reorganizing, disclosing, transferring, taking over, making available
Any actions taken on data such as bringing, classifying or preventing the use of
kinds of transactions.
Data Processor: Real person who processes personal data on behalf of the data controller, based on the authority given by the data controller.
or legal entity.
Data Controller: Determines the purposes and means of processing personal data, and determines the data recording system.
Real or legal person responsible for its establishment and management.
KVK Board: Personal Data Protection Board.
KVKK: Personal Data Protection Law published in the Official Gazette No. 29677 dated April 7, 2016.
Policy: Akcanglass Cam San. And Trade. Inc. Protection, Processing and Privacy of Personal Data
Policy.
Roles and Responsibilities
Personal Data Protection Committee
Human Resources, Accounting, IT, Quality, Sales Department created within Akcanglass
The Personal Data Protection Committee, consisting of representatives and Senior Management, writes and updates this policy.
is responsible for keeping it. If any behavior contrary to the principles set out in this Policy is detected,
The Personal Data Protection Committee handles the situation in accordance with the Personal Data Breach Incident Management Procedure.
evaluates it this way.
Legal Obligations
Legal obligations as a data controller within the scope of protection and processing of personal data in accordance with KVKK
listed below:
Our obligation to inform
While collecting personal data as the data controller;
For what purpose your personal data will be processed,
Our identity, information regarding the identity of our representative, if any,
To whom and for what purpose your processed personal data may be transferred,
Our method of collecting data and its legal reason,
Rights arising from the law,
We have the obligation to inform the Relevant Person regarding the matters.
As a company, we take care to ensure that this Policy, which is open to the public, is clear, understandable and easily accessible.
We show.
Our obligation to ensure data security
In order to ensure the security of the personal data we are responsible for as the data controller, administrative and
We are taking technical measures. Obligations regarding data security and measures taken are subject to Article 9 and 1 of this Policy.
It is detailed in chapter 10.
Classification of Personal Data
Personal data
Personal data; It is all kinds of information regarding an identified or identifiable natural person.
Protection of personal data is only related to real persons and belongs to legal entities, including natural persons.
Information that does not contain relevant information is excluded from personal data protection. For this reason, this Policy is a legal entity
It does not apply to personal data.
Special personal data
People's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs and their appearance and
clothing, association, foundation or union memberships, health, sexual life, criminal convictions, and security
Data regarding measures and biometric and genetic data are special personal data.
Processing of Personal Data
Our personal data processing principles
We process personal data in accordance with the principles below.
Processing in accordance with the law and the rules of honesty
We process personal data in accordance with the rules of honesty, transparency and within the framework of our obligation to inform.
Ensuring that personal data is accurate and up to date when necessary
We take the necessary precautions in our data processing procedures to ensure that the data processed is accurate and up-to-date.
we take it. The Personal Data Owner is also required to update his/her data and correct any errors in the processed data, if any.
We offer you the opportunity to apply to us.
Purpose of use of personal data
Processing for specific, clear and legitimate purposes
As a company, the scope and content of personal data are clearly defined, legislation and the ordinary flow of commercial life
We process it within the framework of our legitimate purposes determined to continue our activities.
Personal data must be relevant, limited and proportionate to the purpose for which they are processed
Personal data in a limited and proportionate manner, in connection with the purpose we clearly and precisely determine.
We are processing.
We avoid the processing of personal data that is not relevant or does not need to be processed. Because,
Unless there is a legal requirement, we do not process personal data of a special nature or when we need to process them.
We obtain explicit consent regarding this.
Personal data provided by legal regulations and for the duration of our commercial legitimate interests
storage
Many regulations in the legislation require personal data to be stored for a certain period of time. Because,
The personal data we process is required by the relevant legislation or for the purposes of processing personal data.
We keep it for as long as possible.
If the storage period stipulated in the legislation expires or the purpose of processing is eliminated, personal
We delete or destroy the data. Our policies and procedures regarding retention periods are subject to this Policy.
9.1. It is detailed in the article.
Explicit consent to be obtained within the scope of processing the data of the Relevant Person
Explicit consent of the relevant person, except for cases listed in the Law that do not require explicit consent.
We are taking.
Our purposes for processing personal data
As a company, we use personal data for purposes similar to those listed below, including but not limited to those listed below.
We are processing:
Carrying out our activities,
Providing support services to customers within the scope of the contract and service standards,
Determining the preferences and needs of our customers and determining the services to be provided to our customers within this scope
shaping, updating,
To fulfill our legal obligations as required or required by legal regulations.
to ensure,
Evaluating job applications,
To contact people who have business relations with the company,
Marketing,
Vendor / supplier management,
Billing.
Processing of special personal data
Special categories of personal data are subject to administrative and technical measures stipulated by law and prescribed by the KVK Board.
It is processed by us if there is explicit consent or when required by the legislation.
Special personal data regarding health and sexual life, protection of public health, protective
execution of medicine, medical diagnosis, treatment and care services, health services and their financing
For the purpose of planning and management, persons who are under the obligation of confidentiality or authorized institutions and
Since it can be processed by organizations, it is not processed by us other than the data of our employees.
Such data belonging to our employees may be processed by persons prescribed by law.
Processing of personal data for human resources and employment purposes
Your CV, diploma, etc. that you shared with us during your application process as an Employee Candidate. in other documents
We process, store and transfer your personal data for the purpose of evaluating job applications.
The processing, transfer and storage of the personal data you share as an Employee Candidate is subject to this Policy and the Candidate.
It is within the scope of the Personal Data Protection Policy for Employees.
Exceptional cases where explicit consent is not required for the processing of personal data
We may process personal data without explicit consent in the following exceptional cases arising from the law:
It is clearly foreseen in the laws,
It belongs to the parties to a contract, provided that it is directly related to the establishment or execution of a contract.
It is necessary to process personal data,
Data processing is mandatory for the establishment, exercise or protection of a right,
As the data controller, we may process your data for our legitimate interests, provided that fundamental rights and freedoms are not harmed.
It is necessary for us to process
It is mandatory to fulfill any of our legal obligations as the data controller,
Those who are unable to express their consent due to actual impossibility or whose consent is not given legal validity
It is necessary to protect the life or physical integrity of the person or someone else,
It has been made public by the person concerned.
Exceptional cases where special categories of personal data may be processed without the express consent of the Relevant Person are herein.
7.4 of the Policy. stated in the article.
Transfer of Personal Data
Transfer of personal data domestically
As a company, we take the decision stipulated in the KVKK and taken by the KVK Board regarding the transfer of personal data.
We act in accordance with the regulations.
Personal data and special categories of data, provided that exceptional cases in the legislation are reserved.
If the Person or Relevant Person is under 18 years of age, the person's guardian or legal guardian
It will not be transferred by us to other natural persons or legal entities without the express consent of the representative.
In exceptional cases stipulated by KVKK and other legislation, the Relevant Person or the Relevant Person is under 18 years of age.
In case of a person, the data may be processed without the explicit consent of the relevant person's parent or legal representative.
It can be transferred to the authorized administrative or judicial institution or organization in the prescribed manner and within the limits.
In addition, with the exceptional cases stipulated by the legislation;
7.7 of the Policy. In the cases described in the article,
Regarding sensitive personal data, Article 7.4 of the Policy. In the cases listed in the article,
By taking the measures prescribed by the KVK Board and the relevant legislation, the health and safety of the Relevant Person
Special personal data regarding sexual life can only be used for the protection of public health, protective
execution of medicine, medical diagnosis, treatment and care services, health services and their financing
For the purpose of planning and management, persons who are under the obligation of confidentiality or authorized institutions and
It can be transferred to organizations without seeking explicit consent.
Transfer of personal data abroad
As a rule, the Personal Data Subject or Relevant Person must be a person under 18 years of age.
In this case, it will not be transferred abroad without the express consent of the Relevant Person's parent or legal representative. However
7.4 of this Policy. and 7.7. In cases where one of the exceptional circumstances stated in the articles exists,
Third parties other than:
Being located in countries with adequate protection declared by the KVK Board,
If it is located in countries where there is not sufficient protection, data in Turkey and the foreign country in question
Those responsible must undertake in writing to provide adequate protection and the KVK Board has permission,
In such cases, personal data may be transferred abroad without explicit consent.
Institutions and organizations to which personal data are transferred
Personal data, including but not limited to;
To our suppliers,
To our business partners and business contacts,
To our company's subsidiaries and group companies,
To legally authorized public institutions and organizations,
To legally authorized private legal persons,
To the service recipient or third parties or collaborating consultants, organizations or authorities,
To our shareholders,
According to the principles and rules explained above, within the conditions and purposes listed in Articles 8 and 9 of the Law
can be transferred.
Measures we take regarding the legal transfer of personal data
Technical measures
To protect personal data, including but not limited to;
It carries out in-company technical organization for the processing and storage of personal data in accordance with the legislation,
Creates the technical infrastructure to ensure the security of the databases where your personal data will be stored,
It monitors and inspects the processes of the created technical infrastructure,
It determines the procedures for reporting the technical measures and audit processes we take,
Periodically updates and renews technical measures,
Risky situations are re-examined and necessary technological solutions are produced,
Uses virus protection systems, firewalls and similar software or hardware security products and
We establish security systems in line with technological developments.
We employ employees who are experts in technical matters.
Administrative measures
To protect your personal data
including but not limited to;
Access to personal data, including company and affiliate employees within our company
and establishes procedures,
We inform our employees about the legal protection and processing of personal data.
and educates,
In the contracts we make with our employees and/or in the policies we create, the company
to record the measures to be taken in cases of unlawful processing of personal data by
is taking.
Processing of personal data by data processors we work with or partners of data processors
We supervise their activities.
Storage of Personal Data
Personal data is processed for a period of time stipulated in the relevant legislation or required for the purpose for which they are processed.
storage
Personal data retention periods stipulated in the legislation are reserved.
We keep personal data for as long as required by the purpose of processing.
In cases where we process personal data for more than one purpose, the purposes of processing the data are eliminated
or If the Relevant Person or Relevant Person is a person under 18 years of age, the Relevant Person
If there is no obstacle in the legislation to the deletion of data upon the request of the parent or legal representative,
data is deleted or destroyed. Legislative provisions and KVK Board decisions regarding destruction or deletion
It is complied with.
Measures we take regarding the storage of personal data
Technical measures
Deletion and destruction of personal data
It creates technical infrastructures and related control mechanisms for
Takes the necessary precautions to keep personal data securely,
Employs employees with technical expertise,
Creating and implementing business continuity and emergency plans against possible risks
developing systems,
We establish security systems in accordance with technological developments regarding the storage areas of personal data.
Administrative measures
Technical data regarding storage of personal data
We raise awareness by informing our employees about and administrative risks,
In case of cooperation with third parties to store personal data, personal data
contracts made with the companies to which it is transferred; the persons to whom personal data is transferred, the transferred personal data
regarding taking the necessary security measures to protect and securely store data
We include the provisions.
Security of Personal Data
Our obligations regarding the security of personal data
Personal data;
To prevent unlawful processing,
In order to ensure that it is stored in accordance with the law, administrative and
We are taking technical measures.
10.2 Measures we take to prevent unlawful processing of personal data
We carry out the necessary inspections within our company and have them carried out,
We train and inform our employees about the legal processing of personal data,
The activities carried out by our company are evaluated in detail for all business units, and the relevant
As a result of the evaluation, personal data specific to the commercial activities carried out by the relevant units
is working,
Processing personal data in cases where cooperation is made with third parties for the purpose of processing personal data
In contracts made with companies; Persons processing personal data must take the necessary security measures
It contains the relevant provisions.
In case of unlawful disclosure of personal data or data leakage, the situation should be reported to the KVK Board.
By notifying us, we carry out the investigations and take the measures stipulated by the legislation in this regard.
Technical and administrative measures taken to prevent unlawful access to personal data
To prevent unlawful access to personal data;
Employs employees with technical expertise,
Periodically updates and renews technical measures,
We create access authorization procedures within our company,
It determines the procedures for reporting the technical measures and audit processes we take,
We create the data recording systems used within our company in accordance with the legislation and
carries out periodic inspections,
Systems for creating and implementing emergency aid plans against possible risks
developing,
We train and inform our employees about access to personal data and authorization,
In cases where cooperation is made with third parties for activities such as processing and storing personal data
In contracts made with companies that provide access to personal data; persons who have access to personal data
It contains provisions regarding taking the necessary security measures.
Security within technological developments to prevent unlawful access to personal data
We install systems.
Measures we take in case of unlawful disclosure of personal data
Takes administrative and technical measures to prevent unlawful disclosure of personal data.
and we update them in accordance with our relevant procedures. Unauthorized disclosure of personal data
If we detect that the situation has been made, we will notify the Relevant Person or the person who is under 18 years of age.
In case of a situation, the system and subsidiaries are required to notify the relevant person's parent or legal representative and the KVK Board.
We create structures.
In case of an unlawful disclosure despite all administrative and technical measures taken, the KVK Board
If deemed necessary by the KVK Board, this situation will be announced on the KVK Board's website or by another method.
can be done.
Rights of Personal Data Owner
Within the scope of our obligation to inform, we inform the Personal Data Owner and
We establish systems and infrastructures. Personal Data Owner's exercise of his rights regarding your personal data
We make the necessary technical and administrative arrangements.
Personal Data Owner on his personal data;
Learning whether personal data is processed or not,
Requesting information if personal data has been processed,
Learning the purpose of processing personal data and whether they are used for their intended purpose,
Knowing the third parties to whom personal data is transferred at home or abroad,
Requesting correction of personal data if they are incomplete or incorrectly processed,
If the reasons requiring the processing of personal data disappear, the personal data will be deleted or
do not want to be destroyed,
The correction, deletion or destruction mentioned above may not be carried out to third parties to whom personal data is transferred.
requesting notification,
An adverse result may arise by analyzing the processed data exclusively through automatic systems.
do not object to coming out,
In case of damage due to illegal processing of personal data, request compensation for the damage.
has the right to do so.
Exercising rights regarding personal data
Personal Data
Owner may request his/her personal data if a separate method is determined by the KVK Board.
method or by sending the "KVKK Application Form" on our website to info@akcanglass.com.tr.
can be sent in writing and with wet signature.
The Personal Data Owner has the right to exercise and request to exercise the above-mentioned rights.
In the application containing relevant explanations; The requested matter must be clear and understandable, the requested subject must be
If it relates to the applicant personally or if acting on behalf of someone else, he/she is specifically authorized in this regard.
and this authority must be documented, and the application must contain identity and address information and
Documents proving identity must be attached. The Relevant Person must be under the age of 18
In this case, the parent or legal representative can submit the application regarding personal data with proof of the identity of the Relevant Person.
It must be sent by attaching the documents mentioned above along with the documents.
These requests will be made on an individual basis and will not be processed by unauthorized third parties regarding personal data.
Requests will not be evaluated.
Evaluation of the application
Time to respond to your application
Regarding personal data
Requests can be processed free of charge as soon as possible and in any case within 30 (thirty) days at the latest, depending on their nature, or
If the conditions in the tariff to be published by the KVK Board regarding the fee are met, the fee in the tariff
correspondingly is concluded.
Additional information and documents may be requested during the application or while the application is being evaluated.
It may happen.
Our right to reject the application
Regarding personal data
applications;
Personal data is anonymized through official statistics, such as research, planning and statistics.
processing for purposes,
Personal data does not violate the privacy of private life or personal rights or does not constitute a crime
provided that it is processed for artistic, historical, literary or scientific purposes or within the scope of freedom of expression,
Processing of personal data made public by the Personal Data Owner,
The application is not based on a justified reason,
The application contains a request contrary to the relevant legislation,
Failure to comply with the application procedure,
In such cases, it is rejected with justification.
Application evaluation procedure
11.2.1 of this Policy
In order for the response period specified in the article to begin, the requests must be made in writing and with wet signature.
the applicant's identity with certifying information and documents through other methods determined by the KVK Board.
You need to send it. If the Relevant Person is under the age of 18, the parent or legal guardian
The representative submits the application regarding personal data together with documents proving the identity of the Relevant Person.
It must be sent by attaching the documents mentioned above.
If the request is accepted, the relevant action is taken and notification is made in writing or electronically. Rejection of request
If so, the reason is explained and notified to the applicant in writing or electronically.
Right to complain to the Personal Data Protection Board
Apply
In case of rejection, if our answer is found insufficient or if we do not respond in time; application
30 (thirty) days from the date the owner learns the answer and in any case 60 days from the date of application.
He/she has the right to file a complaint with the KVK Board within (sixty) days.
Privacy Policy
This Privacy Policy is on our Company's website.
It contains our policy regarding your personal data while providing services related to the site. Personal
Acquisition and Processing of Your Data In accordance with the Personal Data Protection Law No. 6698 ("KVKK"),
As the Data Controller, we request limited and measured requests in connection with the purpose and duration of processing.
The purpose that requires processing of your personal data that you have shared with us
These personal data will be recorded, stored, preserved and rearranged within the scope of legal
domestic data, which can be shared with institutions authorized to request it, in cases and conditions stipulated by KVKK.
or to be transferred to third parties abroad, transferable, classified and other listed in KVKK.
We inform you that it can be processed in different ways. User or Users; Job application on the website
to make requests and suggestions, to introduce themselves and to follow user preferences more closely.
In order to be able to use the website directly or to communicate, name, surname, e-mail, business name,
The personal data they will share in their applications on our website will be shared with the Site and Personal Data No. 6698.In accordance with the Law on Protection of Personal Data, they share this data entirely with their own will and express consent.
to provide better service to them, their applications or complaints and site activities
and that they were requested to be informed about their innovations during their visits.
As a provider, they accept that traffic information can be processed. Your personal data, Türk Ticaret
Law (TTK), Turkish Code of Obligations, Consumer Protection Law, other relevant laws and
ID to identify the information of the person performing the transaction within the scope of regulations and other relevant legislation,
All necessary receipts, showing the transaction or in paper form, which can record the address and other necessary information,
will be able to organize records and documents and prepare records and documents within the scope of relevant laws and relevant legislation.
can keep and store it for the periods stipulated by law and process it in accordance with the relevant regulations.
to ensure security, information storage, reporting,
Shared information during job applications that will enable fulfillment of information obligations
to evaluate personal data, to store and collect verbally, in writing or electronically, to comply with the laws and
limited to the organizations specified for the above-mentioned purposes to the extent permitted by the relevant legislation.
It can be transferred to public and private legal entities that are expressly authorized by law.All personal data you have shared with our company, Personal Data Protection Law No. 6698
In accordance with Article 12, it will be stored in accordance with the confidentiality principles. Your personal data in question
Except for the exceptions/exclusions listed in the law, only; with the explicit consent of users
based on this data, with the employees of the company authorized to keep this data or in accordance with a legal obligation.
may share it with public institutions or organizations authorized to request it.
Company Entry-Exit and Processing of Personal Data Within the Company
In order to ensure security and maintain the operation of our company,
Monitoring guest entrances and exits with security cameras in our company's buildings (interior and exterior)
Personal data is monitored and processed in accordance with the Constitution, KVK Law and other relevant legislation.
Our company's building, building entrances and inside the building through camera monitoring system
image recordings of our visitors, to ensure their security, to increase service quality, to ensure our Company's,
It is collected for purposes such as ensuring the security of visitors and other persons, and data is processed for this purpose.
is in operation. Only a limited number of records recorded and preserved digitally can be accessed.
The company employee has access and ensures the confidentiality of the data accessed with a confidentiality agreement.
He declares that he will protect it. Live camera footage is used by outsourced security tasks.
can monitor. In accordance with Article 12 of the KVK Law, data obtained as a result of camera monitoring activities
Necessary technical and administrative measures are taken to ensure the security of personal data.
Log records regarding your internet access provided to our guests are recorded in accordance with Law No. 5651 and this Law.
are recorded in accordance with the mandatory provisions of the regulated legislation; These records are only available to authorized public
upon request by institutions and organizations or audits to be carried out within our Company.
processes are processed in order to fulfill our relevant legal obligations. Obtained log Only a limited number of Company employees who are committed to confidentiality have access to these records.
Records are to be used only in requests or audit processes from authorized public institutions and organizations.
access and share with legally authorized persons. On the websites owned by our company;
people who visit these sites, in a way that is appropriate for their visit purposes.
For purposes such as ensuring their realization; Internet movements within the site are subject to the Law and related regulations.
It is recorded in accordance with the provisions of the legislation.
Deletion and Anonymization of Personal Data
KVKK article 7 and
Although it was committed in accordance with other relevant legal provisions (Article 138 of the Turkish Penal Code),
If the reasons requiring processing are eliminated, personal data will be processed ex officio, that is, at the discretion of the Company.
It is deleted or destroyed by the data controller upon the request of the personal data owner. Personal
The provisions of other laws regarding the deletion or destruction of data are reserved. Our company,
as deletion or destruction techniques; through the company's expert technical staff or an agreed expert.
deletion of personal data so that it cannot be recovered, physical destruction of personal data,It can be safely deleted from existing software. The techniques used in anonymization are;
aggregation, derivation, masking, hashing techniques and ensure that they are processed and processed in accordance with the law.
If the reasons requiring it disappear, personal data will be processed by our company or its affiliates.
can be anonymized. Since anonymized personal data will not be included in the scope of KVK law,
It may be processed for purposes such as research and statistics.
Publishing and Storing the Document
This Policy is on printed paper.
It is stored in two different environments: and electronically.
Update Period
This Policy will be determined by the Company
It is reviewed periodically and, if necessary, the principles determined within the Company by laws and regulations are
It is updated within.
Effectiveness
This Policy is available on our company's website.
It is deemed to have entered into force following its publication.
