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Explanatory Text for the Law on Protection of Personal Data

Explanatory Text for the Law on Protection of Personal Data

1. Identity of the Data Officer

As SAHMER OTELCILIK TURIZM GIDA SANAYI VE TICARET A.S. (“SAHINN”), we attach great importance to the security and privacy of your personal data and, in this respect, we make the following available to your information in order to fulfil the obligation of clarifying the following issues regarding all personal data of all persons associated with SAHINN including our guests who benefit from our services, within the scope of the Law no. 6698 of Republic of Turkey on the Protection of Personal Data (the “Law”).

The protection of personal data is among the basic policies of SAHINN. SAHINN has given priority to the confidentiality of personal data during its existence in this field, adopted it as a working principle and instructed its employees to work in compliance with this principle. SAHINN accepts and undertakes to comply with all the requirements stipulated by the Law on the Protection of Personal Data. With full awareness of this responsibility and acting in the capacity as Data Officer, we process, record, transfer, share and store your personal data in the manner described by us and within the limits prescribed by official legislation.

2. Collection and Processing of Personal Data and Processing Purposes

Although your personal data may vary with respect to the products and services or commercial activity offered by SAHINN, they can be processed by our Company under the best protection.

In our institution, personal data such as identity data, communication data, religion / belief data, health, financial, biometric, educational data as well as other private personal data belonging to persons such as candidate employees, employees, former employees, customers, guests, suppliers, visitors are stored.

Your personal data which are obtained in accordance with data owners’ express consent and the requirements for compliance with laws stipulated in the legislation of Republic of Turkey are processed for the following purposes by SAHINN:

• Being able to keep customers’ records and ensure the performance of works within this scope;
• Carrying out product supply and after-sales service processes in our company, handling repair & maintenance works, ensuring the customer satisfaction and meeting the demands;
• Being able to carry out the necessary activities by our business units to benefit you from the products and services offered by our Company;
• Ensuring the legal and commercial security of the persons in business relationship with our business (administrative operations for the communication carried out by our business, ensuring the physical safety and surveillance of the locations under the possession of our business, evaluation processes for business partners / customers / suppliers (principals or their employees), legal compliance process, financial works etc.);
• Managing security operations, accidents or other similar medical-insurance incidents;
• Ensuring the security of the people in our facilities by making use of video camera (CCTV) images and assisting in the prevention, detection and prosecution of criminal offenses, as well as establishing, enforcing or defending our legal rights by taking into consideration the photographs;
• Providing you with information about activities and services that you will request from our business,
• Determining and implementing commercial and business strategies of our business
• Ensuring the execution of human resources policies of our business
• Fulfilling a legal obligation prescribed by the legislation as may be explicitly stated in the legislation or if necessary
• Conducting analysis and loyalty studies about the products and services purchased, planning and implementing of activities such as promotions, surveys, advertisements, market researches, marketing and campaigns as well as presenting general and special offers;

Furthermore, your personal data mentioned above can be stored in the physical archives and information systems under the possession of SAHINN and kept in both digital and physical environments.

3. Transferring Personal Data

In order to provide you with this service, your personal data may be transferred to service providers such as information technology companies, archives, printing, card printing, distribution companies and other third parties with whom we cooperate domestically and internationally, as well as to our board of directors, our business/solution partners and legally authorized public and private institutions and organizations, provided that it is limited to the reason that requires your personal data to be transferred within the scope of the Law and related regulations for the purposes described above.

4. Method and Legal Reason for the Collection of Personal Data

For the purposes stated above, your personal data may be collected from all kinds of verbal, written or electronic media by automatic or non-automatic methods based on the legitimate interest of our company and legal reasons, in accordance with the basic principles of the Law and provided that it is foreseen in the laws specified in paragraph 2 of Article 5 of the Law, without prejudice to the establishment and / or execution of the contract, the fulfilment of the legal obligation, and fundamental rights and freedoms of the person concerned.

5. Your Rights for the Protection of Personal Data

Under the Law, you have the right to get information about whether your personal data have been processed, to request information, if your personal data have already been processed, to get information for what purpose your personal data is processed and whether they are used for their intended purpose, to get information about third parties to whom your personal data have been transferred domestically and internationally, if your personal data are incomplete or incorrectly processed, to request us to make appropriate correction on them, to make a request for the deletion, destruction or anonymisation of your personal data in the event that the reasons that require processing are eliminated and request us to notify about any correction as described above and any deletion, destruction and anonymisation the third parties to whom the personal data have been transferred, and to request an objection if you believe that a result against you has arisen as a consequence of analysis of the processed data exclusively through automated systems.

Under the Law, you can make your applications for issues on your personal data with the SAHINN Personal Data Owner Application Form through one of the following channels.

In accordance with Article 13 of the Law, our Company will finalize the application requests depending on the nature of the request within 30 (thirty) days at the latest. If your request requires cost, the tariff set by the Personal Data Protection Board shall be applied. If the request is rejected, the reason(s) of rejection shall be justified in writing or electronically.

Rights relating to personal data may only be exercised for personal data owned by the relevant person. Requests for data of persons other than the person who completed the form and attached his/her own photocopy of the identity card to the form shall not be taken into consideration.

SAHINN reserves the right to update this “Explanatory Text on the Protection of Personal Data” at any time within the framework of amendments to the applicable official legislation.

Click here for the application form.