Clarification Text on the Use of Personal Data

Law No. 6698 on the Protection of Personal Data entered into force after being published in the Official Gazette dated 07.04.2016 and numbered 29677. The Law, which was prepared by taking into account international documents, comparative law practices and the needs of our country, aims to process and protect personal data at modern standards. In this context, the purpose of the Law is to regulate the conditions for processing personal data, the protection of fundamental rights and freedoms of individuals in the processing of personal data, and the obligations of real and legal persons who process personal data and the procedures and principles to be followed. In this context, this information text is submitted for your information and review in order to fulfill our obligation to inform in accordance with Article 10 of the relevant law in terms of the conditions and purposes to be explained below and the data to be processed in accordance with the law.

Definition of Data Controller:

As defined in Article 3 of Law No. 6698, the data controller is defined as "the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system".

General Principles for Processing Personal Data

Our Company acts in accordance with the general principles set forth by Law No. 6698 in the processing of personal data. Our general principles in the processing of personal data are as follows;

1) Compliance with the law and good faith,

2) Being accurate and up to date when necessary,

3) Processing for specific, explicit and legitimate purposes,

4) Being relevant, limited and proportionate to the purpose for which they are processed,

5) Retention for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

Although your personal data may vary depending on the service, product or commercial activity provided by our Company, it may be collected verbally, in writing or electronically by automatic or non-automatic methods, offices, branches, dealers, call center, website, social media channels, mobile applications and similar means of our Company and our member workplaces.

Legal Purposes and Reasons for Collecting Personal Data

Objective

In order to be provided when information is requested from authorized public institutions and organizations, especially when requested by the Court and authorized public officials, In order to fulfill legal obligations and to exercise rights arising from the legislation in force, to be deemed necessary in order to fulfill the obligations arising from the establishment, execution and conclusion of the contract, The processing of personal data by our Region to establish the rights of our party or you or third parties, It is mandatory for the use or protection of the data, Provided that the fundamental rights and freedoms of the person are protected, it is mandatory to process the data for the legitimate interests of our Region, (carrying out the satisfaction evaluation activities of existing customers, organization and event management, carrying out finance-accounting transactions, carrying out audit processes, carrying out occupational health and safety activities, fulfilling the obligation to notify authorized public institutions such as courts, etc.). It is mandatory for the protection of the life or physical integrity of the person who is unable to disclose his/her consent due to actual impossibility or whose consent is not legally valid, or of another person, Personal Data has already been made public by the person concerned, It is mandatory to process data for the establishment, exercise or protection of a right.

Reason

Your personal data is obtained in all kinds of verbal, written or electronic media in order to provide the products and services offered by the Company within the legal framework determined in line with the above-mentioned purposes and to fulfill our Company's contractual and legal obligations in a complete and accurate manner. Your personal data collected for this legal reason can also be processed and transferred for the purposes specified in this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVK Law.

Personal data, by our company;

-Improving the services offered, developing new services and providing information about them,

-Commercial electronic message approval in terms of existing customers and prospective customers; promotion and marketing of campaigns and services,

-Resolution of customer problems and complaints,

-Statistical evaluations and market research,

-Determining and implementing the company's commercial and business strategies,

-Managing relationships with member businesses and business partners,

Follow-up of accounting and payment transactions,

-Legal processes and compliance with legislation,

-Responding to information requests from administrative and judicial authorities,

-Planning internal reporting and business development activities

-Financial control and reporting and realization of legal notifications,

-Managing internal control and audit activities,

-Ensuring information and transaction security and preventing malicious use,

-It is used to make the necessary arrangements to ensure that the processed data is up-to-date and accurate and to carry out activities related to all these processes.

Transfer of Processed Personal Data

Our Company may share your personal data with our domestic and foreign business partners, member merchants, banks, financial institutions, independent audit institutions, etc. persons and institutions permitted by the provisions of the Law on Payment and Securities Settlement Systems, Payment Services and Electronic Money Institutions and other legislation. Stored data may be transferred within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law. Records and documents regarding the transactions carried out by our company with its customers are kept for a certain period of time within the scope of legal regulations, and if you request the deletion of your personal data, this request can be fulfilled until the end of the period determined by legal regulations, and your personal data will not be processed and shared with third parties during this process, except for the obligations arising from legal regulations.

Rights of the Personal Data Owner Listed in Article 11 of the KVK Law

As personal data owners, if you submit your requests regarding your rights to our Company by the methods set out below in this Clarification Text, our Company will finalize the request within thirty days at the latest without any fee depending on the nature of the request. However, if a fee is stipulated by the Personal Data Protection Board, the fee in the tariff determined by our Company will be charged. In this context, personal data owners;

-Learn whether personal data is being processed,

-Request information if personal data has been processed,

-Learning the purpose of processing personal data and whether they are used in accordance with their purpose,

-To know the third parties to whom personal data are transferred domestically or abroad,

To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,

-To request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear, although it has been processed in accordance with the provisions of the KVK Law and other relevant laws, and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,

-Objection to the occurrence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,

-If personal data is damaged due to unlawful processing of personal data, it has the right to demand the compensation of the damage.

Evaluation of Data Subject's Requests

Pursuant to Article 13, Paragraph 1 of the KVK Law No. 6698, you can submit the requests regarding the exercise of the above-mentioned rights to our Company in writing or by other methods determined by the Personal Data Protection Board. Since the Personal Data Protection Board has not determined any method at this stage, you must submit your application to our Company in writing in accordance with the KVK Law. In this context, the channels and procedures you will submit your written application to our Company within the scope of Article 11 of the KVK Law are explained below.

In order to exercise your rights mentioned above, you can send your request, which includes the necessary information identifying your identity and other information requested and your explanations regarding your right you request to exercise among the rights specified in Article 11 of the KVK Law, to Karaağaç Mah. 750 Sk. No:13/B Merkez/ERZİNCAN address in person with documents identifying your identity, you can send it by registered mail with return receipt requested, send it via notary public or other methods specified in the KVK Law or send it to info@gulhan.com with secure electronic signature.

Links to third party websites

Our Region's website may contain links to third party websites. Our Region does not accept any responsibility for the privacy policies of these sites and in no way guarantees that the applicable data protection practices of these Web sites comply with all relevant legislation and regulations.