DEFINITIONS and TERMS
As used in this KVKK (Turkey’s Personal Data Protection Law No. 6698) Privacy Notice;
Personal Data : Means any information relating to an identified or identifiable natural person. In the legislative rationale, a person being identified or identifiable is defined as that person being made identifiable by associating the available data with a natural person in any way. (Name, Surname, Turkish ID Number, Passport Number, Address, Telephone, System Login/Logout Times, Areas/products visited and transactions carried out, Digital data held in databases or files relating to their locations, Documents such as job applications/CVs and order records in which information on individuals held by HR/marketing/sales or other units is stored, Place/Date of Birth, Vehicle Registration Plate, E-mail Address / IP Address, Fingerprint, Image and Audio Recordings, All similar data that make a person identifiable)
Special Categories : Special categories of personal data are data which, if disclosed, may lead to discrimination against or victimisation of the data subject. For this reason, they must be protected much more strictly than other personal data. Special categories of personal data may be processed with the explicit consent of the data subject or in the limited cases listed in the Law. (Race, Ethnic Origin, Political Opinion, Philosophical Belief, Religion, Sect or other beliefs, Appearance and Dress, Membership of an Association, Foundation or Trade Union, Health, Sexual Life, Criminal Conviction/Ownership Data, Data Relating to Security Measures, Biometric and Genetic Data)
Processing of personal data: Any operation performed on personal data, including obtaining, recording, storing, altering, sharing with third parties and transferring abroad personal data, wholly or partly by automated means or by non-automated means provided that they form part of a data filing system,
Personal Data Protection Law No. 6698 “KVKK”: Personal Data Protection Law No. 6698, which entered into force upon its publication in the Official Gazette on 7 April 2016,
Board: The Personal Data Protection Board,
Explicit Consent : Consent relating to a specific matter, based on information and given of one’s free will, clear enough to leave no room for doubt, and limited solely to that operation.
Anonymisation : Rendering personal data such that they can in no way be associated with an identified or identifiable natural person, even when matched with other data.
Personal Data Owner (Data Subject): The natural person whose personal data are processed, for example: customers, suppliers, visitors,
dealer/service employees, public institution employees, employees and job applicants.
Data Processor: The natural or legal person who processes Personal Data on behalf of the data controller, based on the authority granted by it,
Data Controller: The natural or legal person who determines the purposes and means of processing Personal Data and is responsible for establishing and managing the data filing system. It is the person who determines, in general terms, “why” and “how” the data processing activity is carried out.
Contact Person: The person who ensures communication with the Authority and liaison with Data Subjects. The contact person is not the representative of the Data Controller. The contact person does not have the authority to act on behalf of the Data Controller and is the person to whom requests from the Authority are notified. (They are not an evaluating authority for questions and requests from Data Subjects and hold only a liaison position.)
IMPLEMENTATION
As Unna Bilişim San. Tic. A.Ş., we hereby inform
our employees, interns, active and potential customers and their employees, active and potential suppliers and their employees, job applicants, visitors, business partners, the institutions and organisations we cooperate with and their employees, and all our other relevant third parties / data subjects
that their personal data in our possession are collected, processed, transferred, securely retained and destroyed within the framework of, first and foremost, Personal Data Protection Law No. 6698, the Constitution of the Republic of Türkiye, the international conventions to which our country is a party and the relevant legislation, and that, in our capacity as Data Controller, we approach this with sensitivity and care.
Cases in Which Unna Bilişim San. Tic. A.Ş. May Process Your Personal Data Without Your Explicit Consent under KVKK
Pursuant to Article 5 of KVKK, in the following cases Unna Bilişim San. Tic. A.Ş. may, without seeking your explicit consent, process your personal data mentioned above
that it has obtained in accordance with the law:
Where it is expressly provided for by law,
Where the processing of your personal data is necessary to protect your own or another person’s life or physical integrity, in cases where you are unable to express your consent as a data subject due to actual impossibility or where your consent is not recognised as legally valid,
Where the processing of personal data of the parties to a contract is necessary, provided that it is directly related to the establishment or performance of a contract you have concluded with Unna Bilişim San. Tic. A.Ş. and its affiliated companies or the other natural and/or legal persons specified in Article III,
Where it is necessary for Unna Bilişim San. Tic. A.Ş. to fulfil a legal obligation,
Where your personal data have been made public by you,
Where data processing is necessary for the establishment, exercise or protection of a right,
Where data processing is necessary for the legitimate interests of Unna Bilişim San. Tic. A.Ş., provided that it does not harm your fundamental rights and freedoms.
In the processes within the scope of this Privacy Notice on the Collection, Processing, Transfer, Retention and Destruction of Personal Data, the relevant legal regulations in force shall apply with priority. In the event of any inconsistency between the legislation in force and the Privacy Notice, the Data Controller accepts that the legislation in force shall apply.
The KVKK Privacy Notice entered into force on 01.01.2023 and has been made available to our employees and all our relevant parties on our website https://www.unna.com.tr, in the shared area on the server under Management Systems Documentation, and by distribution in person. If all or certain articles of the Privacy Notice are renewed in order to comply with changing conditions and legislation, the publication date will be updated and the notice will be announced again.
