PDPL Information Text

DATA PROTECTION LAW İNFORMATION TEXT

1. PURPOSE

As UNOVA, we respect the privacy of your personal data, attach importance to data security, and consider this matter among the priorities of our company. We adopt the principles of collecting, processing, and protecting personal data of our customers, potential customers, website users, employees, job candidates, former employees of UNOVA, interns, company shareholders, company officials, our business partners, group company employees, and visitors in accordance with the regulations stipulated in the Personal Data Protection Law No. 6698. Therefore, we recommend that you carefully read this text, which explains how we process your personal data, with whom we share it, and how you can exercise your rights. Including individuals benefiting from our services, all kinds of personal data belonging to individuals associated with UNOVA will be recorded, stored, updated, and processed within the framework of the Personal Data Protection Law No. 6698, with specific, clear, and legitimate purposes, subject to compliance with the law and the principle of honesty, and may be processed and shared with third parties as long as your relationship with our company continues. As defined in the Personal Data Protection Law, we determine the information we obtain from you within the scope of our relationship with you as the “Data Controller”.

1. DEFINITIONS

In this information text;

Personal Data: Any kind of information relating to an identified or identifiable natural person, Processing of Personal Data: Any operation performed on personal data such as obtaining, recording, storing, preserving, altering, rearranging, disclosing, transferring, taking over, making available, classifying, or preventing the use of data, whether fully or partially automated or as part of any data recording system. Personal Data Protection Law “PDPL”: Law No. 6698 on the Protection of Personal Data published in the Official Gazette on April 7, 2016,

Authority: Personal Data Protection Authority,

Data Processor: Natural or legal person who processes personal data on behalf of the data controller based on the authority given by the data controller,

Data Controller: Natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.

Data Subject: The natural person whose personal data is processed,

Contact Person: The person who facilitates communication with the Authority and relevant individuals. The contact person is not the representative of the Data Controller. The contact person is not authorized to act on behalf of the Data Controller, but is only the person to whom requests from the Data Subjects are communicated. (It is not an evaluation authority for questions and requests from Data Subjects, but only acts as a facilitator for communication.)

1. DATA CONTROLLER

Data Controller: UNOVA

Address: ANKARA OSB MAH. 1203 CAD. NO:12 YENİMAHALLE / ANKARA

Phone: 0 (312) 503 38 53

Email: info@unova.com.tr

1. APPLICATION

As UNOVA:

We attach importance to ensuring that the personal data of our customers, potential customers, website users, employees, job candidates, former employees of UNOVA, interns, company shareholders, company officials, business partners, group company employees, and visitors are protected, collected, processed, transferred, and disposed of in accordance with the Republic of Turkey Constitution, international agreements to which our country is a party, and relevant legislation, including Law No. 6698 on the Protection of Personal Data.

In this context, we may process your personal data, which you share with us, in compliance with Law No. 6698 PDPL, limited to our activities and purposes, relevant and proportionate, transfer them to third parties domestically and internationally, store them, use them for profiling, and classify them.

1. Purpose of Processing Your Personal Data 

In accordance with Articles 4, 5, and 6 of Law No. 6698 PDPL, your personal data may be processed under the following conditions:

In cases explicitly provided for by laws, for the establishment or performance of a contract, to fulfill our legal obligations, for the establishment, exercise, or protection of a right, for our legitimate interests, or provided that it has been made public by you (the data subjects), personal data may be processed with explicit consent if the processing conditions are not met. In addition, all processed personal data will be:

• In accordance with the law and the principle of honesty,
• Correct and up-to-date,
• For specific, clear, and legitimate purposes,
• Processed in connection with the purpose they were collected for, limited and proportionate,
• Will be retained for the period required by the relevant legislation or for the purpose for which they were processed.

• Your personal data may be processed by our company for the following purposes without compromising our quality:

• Conducting occupational health and safety activities,
• Planning and monitoring business with business partners, dealers, or suppliers,
• Establishment and execution of customer records,
• Conducting customer relations and monitoring corporate governance activities,
• Management and tracking of customer requests and complaints,
• Ensuring business continuity,
• Monitoring contract processes,
• Monitoring legal processes and communication processes with official institutions,
• Ensuring legal and commercial security,
• Improving and enhancing the services provided by our company,
• Determination and implementation of commercial and business strategies,
• Conducting market research,
• Planning and organizing activities to ensure or increase loyalty to products and services,
• Continuation of business and operations,
• Conducting sales and procurement processes,
• Fulfillment of warranty obligations,
• As our customers, designing contractual processes such as sales and after-sales support with you, carrying out all necessary transactions, executing and monitoring contract processes, planning and executing operational processes related to sales,
• Creating efficiency reports by receiving information about customer-based developments,
• Ensuring and/or increasing loyalty to products and services,
• Execution of company activities and procedures,
• Execution of financial and accounting transactions,
• Execution of financial, accounting, and financial transactions including billing processes related to sales, risk management,
• Execution of internal audit processes,
• Fulfillment of notification obligations to relevant/authorized public institutions,
• Execution of job and internship application and evaluation processes,
• Establishment of workplace personnel files and execution of processes related to employment,
• Execution of Human Resources processes,
• Fulfillment of contractual and legal obligations for employees,
• Conducting training activities,
• Execution of physical security processes,
• Planning of information security processes, establishment and management of information technology infrastructure,
• Conducting risk management,
• For logging activities

1. Method and Legal Basis for Collection of Your Personal Data

Your personal data may be collected in oral, written, or electronic form, fully or partially automated or as part of any data recording system, as indicated above.

Within the framework of the activities for the execution of commercial processes; communication forms, fair organizations, business cards, supplier information request forms, other commercial documents, payment information and documents, valuable documents, employee and intern candidate application forms, resumes, electronic mail, website, various contracts, mobile applications, consumer complaint forms, our customers, our suppliers, and other third parties including individuals from outside our company can be collected in various ways in oral, written, or electronic media.

We process your collected personal data in accordance with Articles 5/2-c – Establishing and fulfilling a contract, Article 5/2-ç – Fulfilling our legal obligations, and Article 5/2-f – Within the legitimate interests of our company or with your explicit consent, as mentioned above.

1. Transfer of Your Personal Data

Your personal data; To be responsible together with UNOVA for purposes such as the preservation of data, prevention of unauthorized access, and prevention of illegal processing, by taking data security measures in line with the purposes mentioned above, in accordance with the Personal Data Protection Law (KVKK) and the current legislation;

Due to legal obligations and needs arising from the legislation, it may be transferred to authorized public institutions and organizations, intermediary financial institutions to assess financial risks, independent audit firms for the conduct of audit processes, institutions providing intermediary/agency services in business trips and organization, fair processes, our business partners, suppliers, shareholders, local/international organizations from which we receive support in our business processes, affiliated companies and/or directly/indirectly domestic/foreign organizations in cooperation within the scope of relevant contracts for the conduct of activities as UNOVA, and other third parties.

1. Storage and Deletion of Data 

In accordance with the legislation, relevant personal data must be stored for certain periods. Therefore, it is the responsibility of our company to store personal data in accordance with the legislation and for the necessary period. These storage periods are defined in detail on a data basis in the prepared personal data inventory. Personal data is kept for the period prescribed by the legislation or required by its purpose. Data is stored in physical or electronic media. Security measures necessary for the storage and preservation of data have been taken, and a secure environment has been provided by our company. Personal data whose storage period has expired is destroyed at 6-month intervals. (deletion/destruction/anonymization)

Your Rights as a Data Subject

In accordance with Article 11 of the PDPL,

• Learning whether your personal data is being processed,
• If your personal data has been processed, requesting information regarding this,
• Learning the purpose of processing personal data and whether they are used for their intended purpose,
• Knowing the third parties to whom your personal data is transferred domestically or abroad,
• If your personal data is incomplete or incorrectly processed, requesting their correction,
• Requesting the deletion or destruction of your personal data in accordance with the conditions specified in the KVKK legislation,
• When you request the correction of incomplete or incorrect data or the deletion or destruction of your personal data, requesting that this situation be notified to third parties to whom your personal data has been transferred,
• Objecting to the occurrence of a result against you by analyzing processed data exclusively through automated systems,
• If you suffer damage due to the unlawful processing of personal data, demanding the compensation of this damage, you have the rights.

To exercise these rights,

By filling out the Information Request Form on our website at www.unova.com.tr or by submitting a petition containing your request;

Including the identity and address information of the applicant (Documents proving your identity must be attached.),

The subject of the request will be related to you personally,

If you are acting on behalf of someone else, you must have special authorization in this regard, and your authorization must be documented,

Your request must be clear and understandable;

You can send it in writing to our company’s address “OSB MAH. 1203 CAD. NO:12 YENİMAHALLE / ANKARA” or via e-mail from your registered e-mail address in our system. Depending on the nature of your request under the above article, your request will be processed free of charge or in accordance with the fee schedule determined by the Personal Data Protection Board within the shortest time possible (within 30 days at the latest).

As the data subject, in accordance with Article 14 of the Personal Data Protection Law No. 6698, if the application is rejected, the response is found insufficient, or no response is received within the specified period; within thirty days from the date you learn the response or in any case within sixty days from the date of application with your consent, you may file a complaint with the Board.

In accordance with Article 28/2 of the KVKK; personal data subjects cannot assert their other rights mentioned above except for the right to request the remedy of damages in the following cases:

• If the processing of personal data is necessary for the prevention of crime or the conduct of a criminal investigation.
• If personal data processed by the data subject himself/herself has been made public.
• If the processing of personal data is necessary for the protection of the economic and financial interests of the State in relation to budget, taxation, and financial matters by the competent and authorized public institutions and organizations, and professional organizations with the characteristics of public institutions, for the conduct of supervision or regulation tasks, or for the conduct of disciplinary investigation or prosecution.

OTHER MATTERS

In the context of this Personal Data Protection and Processing Information Document, relevant legal regulations in force regarding the processing and protection of personal data will be primarily applied.

The Information Document is published on the website “www.unova.com.tr” and made accessible to relevant individuals. Changes and updates may be made to the Information Document to comply with changing conditions and legislation and will be made available to relevant individuals via the aforementioned website.

UNOVA