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Privacy Policy

POLICY ON THE PROCESSING AND PROTECTION OF PERSONAL DATA

1. PURPOSE AND SCOPE

As CSB MACHINE TRADING CO. LTD., located at Derbent Neighborhood, Dilek_1 Street, No. 14, Turgutlu/Manisa, in accordance with the Personal Data Protection Act No. 6698, which is enshrined as a constitutional right; whilst carrying out our activities, we attach great importance to the protection of personal data belonging to all natural persons with whom we come into contact in any way, and to the fulfilment of the requirements set out in the Personal Data Protection Act (KVKK) in this context. This Personal Data Protection Policy has been prepared to inform you about the processes relating to the collection, use, sharing and storage of personal data by CSB MACHINE TRADING CO. LTD., located at Derbent Neighborhood, Dilek_1 Street No:14, Turgutlu/Manisa. In the process of processing and protecting personal data, the provisions of the relevant legislation currently in force shall take precedence. Within this framework, the primary purpose of this Data Protection and Processing Policy (“Policy”) is to set out, using a methodological approach, the rules, measures, duties and responsibilities adopted by our Company under the data protection legislation, and to ensure transparency regarding the measures we implement to protect personal data.

2. DEFINITIONS AND ABBREVIATIONS

The terms used in the implementation of this Policy have the meanings set out below.

Staff: This refers to our company’s employees.
Data Protection Officer: The person responsible for monitoring, on an individual basis, the processing of personal data within our company and the implementation of the Data Protection Policy and Procedures.
Personal Data: It refers to any information relating to an identified or identifiable natural person. For example: first name, surname, address, telephone number, date of birth, place of birth, eye colour, Turkish identity number.
Data Subject: A natural person whose personal data is processed. For example: an employee, a visitor, a customer, a data subject
Processing of Personal Data: Any operation carried out on personal data, whether fully or partially automated, or by non-automated means provided that it forms part of a data filing system. For example: collection, recording, storage, alteration, and transfer.
Data Protection Act: Refers to the Law on the Protection of Personal Data No. 6698.

3. PRINCIPLES GOVERNING THE PROCESSING OF PERSONAL DATA

Our organisation processes personal data in accordance with the procedures and principles set out in the Personal Data Protection Act (KVKK) and other relevant legislation. The following principles are observed when processing personal data:

  • Compliance with the law and the principles of integrity: Our organisation processes personal data in accordance with the provisions of the relevant legislation, the law and the principles of good faith. We provide information to data subjects.
  • Accuracy and, where necessary, up-to-date status: Our organisation takes the necessary measures to ensure that the personal data it processes is accurate and up to date.
  • Processing for specific, explicit and legitimate purposes: Our organisation clearly and unambiguously defines the legitimate and lawful purposes for which personal data is processed. Our organisation processes personal data only to the extent that it is relevant to and necessary for the services it provides.
  • Being relevant to the purpose for which they are processed, limited and proportionate: As part of the services it provides, our organisation processes personal data to achieve the specified objectives and refrains from collecting, processing and storing personal data that is not necessary for the fulfilment of those objectives.
  • Retention for the period stipulated in the relevant legislation or for as long as is necessary for the purpose for which the data is processed: Our organisation stores personal data in accordance with the provisions of the relevant legislation. At the end of the retention period, personal data is deleted, anonymised or destroyed.

CONDITIONS FOR THE PROCESSING OF PERSONAL DATA

When processing personal data, our organisation complies with the following conditions in accordance with the provisions of the Personal Data Protection Act No. 6698:

  1. Personal data may not be processed without the explicit consent of the data subject. Personal data is processed only with the explicit consent of the data subject. Accordingly, patients are informed about this matter and their explicit consent, given of their own free will, is obtained.
  2. Where any of the following conditions apply, personal data may be processed without the explicit consent of the data subject:

    a) Explicit provision in the legislation.
    b) Where a person is unable to express their consent due to actual impossibility, or where their consent is not recognised as legally valid, it is necessary to protect their own life or physical integrity, or that of another person.
    c) Provided that it is directly related to the conclusion or performance of a contract, the processing of personal data belonging to the parties to the contract is necessary.
    d) It is essential for the data controller to be able to fulfil its legal obligations.
    e) The fact that the information has been made public by the person concerned.
    f) Data processing is necessary for the establishment, exercise or defence of a legal claim.
    g) Provided that it does not infringe upon the fundamental rights and freedoms of the data subject, the processing of data is necessary for the legitimate interests of the data controller.

PROCESSING OF SPECIAL CATEGORIES OF PERSONAL DATA

TERMS AND CONDITIONS Our company complies with the regulations set out in the Personal Data Protection Act No. 6698 regarding the processing of special categories of personal data.

KVKK “ARTICLE 6— (1) Data relating to a person’s race, ethnic origin, political opinions, philosophical beliefs, religion, denomination or other beliefs, dress and appearance, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data, are defined as ‘special category personal data’.”

The processing of special categories of personal data is prohibited. However, the processing of such data;

  • The explicit consent of the data subject,
  • Where expressly provided for by law,
  • Where a person is unable to express their consent due to practical impossibility, or where their consent is not recognised as legally valid, it is necessary to protect their own life or physical integrity, or that of another person,
  • In relation to the personal data made public by the data subject, and provided that it is consistent with their intention to make it public,
  • It is necessary for the establishment, exercise or protection of a right,
  • Where it is necessary for the protection of public health, the provision of preventive medicine, medical diagnosis, treatment and care services, and the planning, management and financing of health services, by persons or authorised bodies and organisations subject to a duty of confidentiality,
  • The fact that it is mandatory in order to fulfil legal obligations in the areas of employment, health and safety at work, social security, social services and social assistance,
  • Foundations, associations and other non-profit organisations or bodies established for political, philosophical, religious or trade union purposes may, provided that they comply with the legislation to which they are subject and their objectives, that their activities are limited to their fields of operation, and that no information is disclosed to third parties, direct their activities towards their current or former members and affiliates, or towards persons who are in regular contact with such organisations and bodies,

this is possible.

METHODS OF COLLECTING AND PROCESSING PERSONAL DATA

It processes personal data relating to natural persons in accordance with Articles 4, 5 and 6 of the Personal Data Protection Act, and on the basis of the Personal Data Processing Inventory, which must be drawn up in accordance with Articles 5, 7, 9 and 10 of the Regulation and must contain the information set out below.

  1. Data category
  2. Purposes and legal basis for the processing of personal data
  3. Recipients/recipient groups transferred
  4. Groups of data subjects
  5. The maximum retention period necessary for the purposes for which personal data are processed
  6. Transfers to foreign countries
  7. Administrative and technical measures taken regarding data security

THIRD PARTIES TO WHOM OUR COMPANY TRANSFERS PERSONAL DATA AND THE TRANSFER ITSELF

OBJECTIVES With regard to the sharing of personal data by our company with third parties, subject to the provisions set out in other laws, we strictly comply with the conditions laid down in the Personal Data Protection Act (KVKK). Within this framework, personal data is not transferred to third parties by CSB MACHINE TRANDING CO.LTD., located at Derbent Neighborhood, Dilek_1 Street No:14, Turgutlu/Manisa, without the data subject’s explicit consent. However, personal data may be transferred by our company without obtaining the data subject’s explicit consent where any of the following conditions set out in the KVKK apply:

  • Where expressly provided for by law,
  • Where a person is unable to express their consent due to actual impossibility, or where their consent is not recognised as legally valid, and where it is necessary to protect their own life or physical integrity, or that of another person,
  • Provided that it is directly related to the conclusion or performance of a contract, where the processing of personal data belonging to the parties to the contract is necessary,
  • It is necessary for the data controller to be able to fulfil their legal obligations, • The data has been made public by the data subject themselves,
  • Where data processing is necessary for the establishment, exercise or defence of a legal claim,
  • Provided that it does not infringe upon the data subject’s fundamental rights and freedoms, the processing of data must be necessary for the legitimate interests of the data controller. Provided that adequate safeguards are in place; in the case of special categories of personal data other than those relating to health and sexual life, such processing must be provided for by law, whilst in the case of special categories of personal data relating to health and sexual life,
  • The protection of public health,
  • Preventive medicine,
  • Medical diagnosis, • The provision of treatment and care services,
  • Your personal data may be transferred for purposes such as the planning and management of healthcare services and their funding, without your explicit consent. In the transfer of special categories of personal data, the conditions set out in the terms and conditions governing the processing of such data are also complied with.

THE PROTECTION OF PERSONAL DATA UNDER THE RELEVANT LEGISLATION

Our company stores personal data securely, either physically or electronically, for an appropriate period of time, in accordance with the provisions of the Personal Data Protection Law (KVKK) and other relevant legislation, for the purpose of enabling CSB MACHINE TRADING CO. LTD., located at Derbent Neighborhood, Dilek_1 Street, No: 14, Turgutlu/Manisa, to carry out its commercial activities. Firstly, we assess whether there is a statutory retention period for the personal data and act in accordance with that period. Where no statutory retention period exists, a necessary retention period is determined and the personal data is retained in accordance with that period. Once the retention period has expired, the personal data is deleted, destroyed or anonymised.

However, in cases where the data controller has a legitimate interest, personal data may be retained until the expiry of the general limitation period (ten years) set out in the Turkish Code of Obligations, provided that this does not infringe upon the fundamental rights and freedoms of data subjects, even after the purpose of processing and the time limits specified in the relevant legislation have ceased to apply.

As part of this, we provide the necessary training to the relevant departments within our organisation and raise awareness.

MEASURES TAKEN TO ENSURE DATA SECURITY

CSB MACHINE TRADING CO. LTD., located at Dilek_1 Street, No. 14, Derbent Neighbourhood, Turgutlu/Manisa, takes all necessary technical and administrative measures to ensure the appropriate level of security required for the protection of personal data.

The measures provided for in Article 12(1) of the KVKK are as follows:

  • To prevent the unlawful processing of personal data,
  • To prevent unauthorised access to personal data,
  • To ensure the protection of personal data.

The measures taken by our company in this regard are listed below:

Administrative Measures

  • Our company carries out the necessary audits to ensure compliance with the provisions of the Act.
  • In the event that personal data being processed is obtained by others through unlawful means, our Company shall notify the relevant party and the Board of this situation as soon as possible.
  • With regard to the sharing of personal data, it ensures data security by entering into framework agreements with the parties with whom personal data is shared, or by including provisions to that effect in contracts.
  • It employs staff who are knowledgeable and experienced in the processing of personal data and provides its staff with the necessary data protection training.

Technical Measures

  • Our company employs knowledgeable and experienced staff to ensure data security and provides its staff with the necessary data protection training.
  • It carries out the necessary internal controls within the framework of the systems put in place.
  • It ensures that the technical infrastructure required to prevent and/or monitor the leakage of personal data outside the organisation is put in place and that the relevant matrices are drawn up.

RIGHTS OF DATA SUBJECTS UNDER ARTICLE 11 OF THE KVKK

Under Article 11 of the Law on the Protection of Personal Data No. 6698 (KVKK), data subjects may submit a request to our Company’s address;

  • The right to find out whether personal data is being processed,
  • If personal data has been processed, the right to request information regarding this,
  • The right to be informed of the purpose for which personal data is processed and whether it is being used in accordance with that purpose,
  • The right to know the third parties to whom personal data is transferred, whether within the country or abroad,
  • The right to request the rectification of personal data where it has been processed inaccurately or incompletely,
  • The right to request the erasure or destruction of personal data in accordance with the provisions of the Personal Data Protection Act (KVKK) and other relevant legislation,
  • In the event that your personal data is rectified, erased or destroyed, the right to request that these actions be notified to any third parties to whom the personal data has been disclosed,
  • To object to any decision made to your detriment as a result of the analysis of your personal data carried out exclusively by automated systems,
  • You have the right to claim compensation for any loss or damage suffered as a result of the unlawful processing of your personal data.

We would like to inform you that we continue to operate with the understanding that the security of personal data is a top priority in all the products and services we offer.