General Data Protection Regulation GDPR

INTRODUCTION

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The Law on Protection of Personal Data No. 6698 (“Law”) entered into force on 7 April 2016. With the law, the definition of personal data is made, the principles regarding their protection and the conditions to be followed by the data controllers in the processing of this data are included. According to the Law, personal data is any information relating to “identified or identifiable natural persons”. Processing of personal data means “all kinds of operations performed on personal data, including obtaining, recording, storing, changing, sharing with third parties and transferring personal data to abroad, automatically or non-automatically, provided that it is a part of any data recording system”. . In order to ensure compliance with the Law, Necdetergun.org adopts the principles regarding the protection and processing of personal data in the relevant legislation and takes the necessary administrative and technical measures. For the scope of this Personal Data Protection and Processing Policy (“Policy”), see. 6. DATA OWNER AND PERSONAL DATA CATEGORIZATION. The relevant legal regulations in force regarding the processing and protection of personal data shall be applied in priority. In case of incompatibility between the current legislation and the Policy, necdetergun.org accepts that the current legislation will find an area of application.

PROCESSING PERSONAL DATA

2.1. PRINCIPLES ON THE PROCESSING OF PERSONAL DATA

The Constitution. 20/III, the protection of personal data is guaranteed by stating that personal data can only be processed in cases stipulated by the law or with the explicit consent of the person. In line with this right granted to personal data owners, Necdetergun.org processes personal data in line with the principles set forth in the relevant legislation or in accordance with the following principles in cases where the person has express consent: – Processing in Compliance with the Law and the Rule of Integrity – Ensuring Personal Data Are Accurate and Up-to-Date When Necessary – Specific, Explicit and Legitimate Processing For The Purposes – Being Related To The Purpose For Which They Are Processed, Limited And Provisional – Retention For The Time Required For The Purpose For Which They Are Processed Or As For The Purpose For Which They Are Processed

2.2. TERMS AND PURPOSE OF PROCESSING PERSONAL DATA

In principle, personal data can only be processed in cases with the explicit consent of the personal data owner. In Article 5 of the Law, the conditions regarding the processing of personal data and in Article 6 are included. The law defines personal data that carries the risk of causing victimization or discrimination when processed unlawfully, as “personal data of special nature”. Special categories of personal data are listed in Article 6 of the Law in a limited way and these include race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and dress, association, foundation or union membership, health, sexual orientation. It includes data on life, criminal convictions and security measures, as well as biometric and genetic data. As stated in the policy above, the customer / user, etc. We do not process sensitive personal data. The explicit consent of the data owner should be disclosed on a specific subject, based on information and free will. In the presence of one or more of the conditions mentioned below, personal data may be processed without the explicit consent of the owner. Necdetergun.org processes personal data in any case, in accordance with the general principles set forth in Article 4 of the Law, in line with the purposes and conditions set forth below. Regarding general personal data; – Necdetergun.org’s activities regarding the processing of your personal data are clearly stipulated in the Laws. Being unable to express its consent due to legal invalidity – The processing of your personal data by Necdetergun.org is directly related to and necessary for the establishment or performance of a contract – The processing of your personal data is mandatory for Necdetergun.org to fulfill its legal obligations – Provided that your personal data has been made public by you ; Limited processing of your personal data by Necdetergun.org for the purpose of making it public – Necdetergun.org’s processing of your personal data is mandatory for the establishment, exercise or protection of Necdetergun.org or you or third parties’ rights – Necdetergun.org provided that it does not harm your fundamental rights and freedoms. It is mandatory to process personal data for the legitimate interests of . In this context, personal data is processed by Necdetergun.org for the following purposes.

TRANSFERRING PERSONAL DATA

3.1. GENERAL PRINCIPLES ON TRANSFERRING PERSONAL DATA

Articles 8 and 9 of the Law include matters regarding the transfer of personal data within the country and abroad. Necdetergun.org may transfer the personal data/private personal data of the data owner to third parties by taking the necessary security measures in line with the data processing purposes of the personal data it has obtained in accordance with the law. In this respect, Necdetergun.org will be able to transfer personal data to third parties in the presence of one of the processing conditions specified in Part II and the following conditions: – If there is explicit consent of the personal data owner, – If there is a clear regulation in the law regarding the transfer of personal data, – The personal data owner or if it is necessary for the protection of someone else’s life or physical integrity and the personal data owner is unable to express his consent due to actual impossibility or if his consent is not legally valid; – If it is necessary to transfer the personal data of the parties to the contract, provided that it is directly related to the conclusion or performance of a contract, – If personal data transfer is mandatory for Necdetergun.org to fulfill its legal obligation, – If the personal data has been made public by the personal data owner, – Personal data If data transfer is mandatory for the establishment, exercise or protection of a right, – If personal data transfer is necessary for the legitimate interests of Necdetergun.org, provided that it does not harm the fundamental rights and freedoms of the personal data owner.

3.2. TRANSFERRING PERSONAL DATA ABROAD

Necdetergun.org will be able to transfer the personal data of the personal data owner abroad for legitimate and lawful personal data processing purposes in the following cases: – In case the explicit consent of the data owner is available, or – In case the data owner does not have the explicit consent of the data owner, but one or more of the other conditions mentioned above are present; Provided that (i) there is sufficient protection in the country where the data is transferred, and (ii) there is insufficient protection in the country where the data is transferred, Necdetergun.org undertakes in writing together with the data controller in the relevant foreign country and the permission of the KVK Board is obtained.

3.3. THIRD PARTIES TO THE TRANSFER OF PERSONAL DATA

Necdetergun.org may transfer the personal data of data owners managed by the Policy in accordance with the above-mentioned conditions and in accordance with Articles 8 and 9 of the Law: – To business partners anonymously in order to ensure the fulfillment of the purposes of establishment of the business partnership, (other data transfer If necessary, express consent is also obtained.) – To the sellers on a limited basis in order to fulfill the purposes within the scope of the contract with the sellers, – Necdetergun.org for the services Necdetergun.org outsourced from the supplier and necessary to fulfill the commercial activities of Necdetergun.org. to suppliers, limited to ensuring the execution of commercial activities that require the participation of Necdetergun.org affiliates, – To relevant public institutions and organizations and private legal persons, limited to the purpose they request within their legal powers.

4. PROTECTION OF PERSONAL DATA

Necdetergun.org ensures the legal processing and protection of personal data by taking other administrative and technical measures to ensure the security of the personal data it processes. In this context, Necdetergun.org provides technological opportunities and implementation costs to process personal data in accordance with the law, to store them in safe environments, to prevent unauthorized access risks and all kinds of other unlawful access, to prevent accidental data loss, to prevent deliberate damage to data and deletion. takes reasonable technical and administrative measures.

5. DISCLOSURE, RIGHTS AND INFORMATION OF THE PERSONAL DATA OWNER

5.1. DISCLOSURE OF THE PERSONAL DATA OWNER

Article 10 of the Law states that personal data owners should be informed during the acquisition of personal data. Necdetergun.org, in accordance with the general principles of other personal data processing activities specified in the relevant legislation, during the acquisition of personal data of personal data owners; (i) the identity of its representative, if any, (ii) for what purpose the personal data will be processed, (iii) to whom and for what purpose it can be transferred, (iv) the method and legal reason for collecting personal data, (v) the rights of the personal data owner.

5.2. INFORMING PERSONAL DATA OWNERS

Information requests made by personal data owners in line with the right to have information about their personal data in accordance with Article 20 of the Constitution and to “request information”, which is among the rights mentioned above, are met by Necdetergun.org in accordance with the Law. Necdetergun.org carries out the necessary channels, internal functioning, administrative and technical regulations in accordance with Article 13 of the Law in order to provide the necessary information to the personal data owners. In this regard, if personal data owners submit their requests regarding their above-mentioned rights to Necdetergun.org, they report their justified positive/negative response to the request, free of charge, within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, Necdetergun.org may charge the fee in the tariff determined by the KVK Board. Personal data owners may submit their requests regarding the above-mentioned rights to Necdetergun.org via the “Necdetergun.org Electronic Commerce and Information Services Limited Application Form” in Annex-1. Applications to be made by personal data owners will be made by one of the following methods, together with documents that will identify the personal data owner:

– Following a method prescribed by the Personal Data Protection Board.

In order for third parties to apply on behalf of personal data owners, a special power of attorney issued by the data owner through a notary public on behalf of the person to apply must be present. Necdetergun.org may request information from the relevant person in order to determine whether the applicant is the owner of personal data, and may ask questions about the application of the personal data owner in order to clarify the issues specified in the application. In cases where the application is rejected in accordance with Article 14 of the Personal Data Law, the response given is insufficient or the application is not answered in due time; He can apply to the KVK Board within thirty days from the date he learns the answer of Necdetergun.org, and probably within sixty days from the date of application.

5.3. PERSONAL DATA CATEGORY

Within the scope of this Policy, personal data processed by Necdetergun.org are categorized. The personal data of the personal data owners in the above-mentioned categories of data subjects are associated with the following categories of personal data.

Personal Data Categorization

Identity Information: Clearly belonging to an identified or identifiable natural person; processed partially or fully automatically or non-automatically as part of the data recording system; data containing information about the identity of the person.

Contact Information: Clearly belonging to an identified or identifiable natural person; processed partially or fully automatically or non-automatically as part of the data recording system; information such as telephone number, address, e-mail address, fax number, IP address

Location Data: Clearly belonging to an identified or identifiable natural person; processed partially or fully automatically or non-automatically as part of the data recording system; Within the framework of the operations carried out by the Necdetergun.org business units of the personal data owner, information that determines the location of the employees of the institutions with which we cooperate with Necdetergun.org when using Necdetergun.org tools

PRINCIPLES REGARDING THE STORAGE PERIOD OF PERSONAL DATA

Personal data is stored by Necdetergun.org for the periods stipulated in the relevant legislation and in line with its legal obligations. If a period of time is not regulated in the legislation regarding how long personal data should be stored, personal data is processed for a period of time that requires it to be processed in line with Necdetergun.org’s practices and commercial practices in connection with the activity carried out by Necdetergun.org while processing that data, then deleted or destroyed. or anonymized. If the personal data whose purpose of processing has ended and the personal data requested to be deleted/anonymized by the personal data owners have expired, the relevant legislation and the retention periods determined by Necdetergun.org; It can only be kept to constitute evidence in possible legal disputes or to assert the relevant right related to personal data or to establish a defense. Necdetergun.org is based on the statute of limitations stipulated in the relevant legislation while determining the retention periods for personal data. The personal data stored for this purpose is only accessed by limited persons when it is required to be used in the relevant legal dispute and is not accessed for any other purpose other than this purpose. At the end of this period, personal data is deleted, destroyed or anonymized.

TERMS OF DELETING, DESTROYING AND ANONYMIZING PERSONAL DATA

Although it has been processed in accordance with the provisions of the relevant law as regulated in Article 138 of the Turkish Penal Code and Article 7 of the Law, in the event that the reasons requiring its processing are eliminated, personal data is deleted or destroyed upon the decision of Necdetergun.org or upon the request of the personal data owner. is made anonymous.

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