Eylül Translation Consultancy and Publishing Services Co. Ltd.
(hereinafter referred to as the "Company")
Acting as the "Data Controller," we hereby inform you, in accordance with Article 10 of the Personal Data Protection Law No. 6698 ("KVKK"), about the purposes of processing your personal data ("Personal Data"), the methods of collection, legal grounds, and your rights. Your personal data will be processed based on legal grounds such as "the explicit consent of the data subject," "the necessity of data processing for the establishment or performance of a contract," and "the necessity of data processing for the establishment, exercise, or protection of a right," primarily for the purposes of evaluating offers, requests, and complaints, and responding to messages received, while adhering to the principle of protecting fundamental rights and freedoms, particularly the right to privacy
a) Data Controller and Its Representative
In accordance with the Personal Data Protection Law No. 6698 ("Law No. 6698"), your personal data may be processed by the Company, acting as a data controller/data processor, within the scope described below.
b) Scope of Disclosure
This disclosure text covers all real person data subjects whose personal data are processed automatically or manually as part of any data recording system, including Company Stakeholders, Company Officials, Business Partners/Suppliers, Affiliates, Employees, Employee Candidates, Visitors, Company and Group Company Customers, Potential Customers, and Third Parties.
c) Purpose of Processing Personal Data
Personal Data will be processed in compliance with the law and the purpose of the Company to:
• Best plan and implement human resources procedures and policies,
• Properly plan, execute, and manage commercial partnerships and strategies,
• Ensure the legal, commercial, and physical security of itself and its business partners,
• Process personal data necessary for the establishment or performance of written and/or verbal translation service agreements,
• Manage Information Technology Processes,
• Contact Personal Data Owners who submit requests and complaints, ensuring the coordination, communication, and effective management of offers, requests, and complaints,
• Notify customers of third parties about campaigns, discounts, benefits, terms, pricing, etc., in accordance with the Data Controller’s instructions, and confirm identity information when necessary,
• Prevent data loss by copying and backing up data, take all necessary technical and administrative security measures, improve service quality, provide call center services, and prepare reports,
• Manage relationships with business partners or suppliers,
• Support affiliates in staff recruitment processes and compliance with relevant legislation,
• Conduct internal and certification audit activities,
• Create and track visitor records, control entry and exit to workplace premises, and ensure workplace security,
• Fulfill obligations within the scope of Occupational Health and Safety,
• Maintain business operations and business continuity,
• Provide information to institutions based on legal requirements,
are processed within this scope.
Your personal data will be processed in accordance with the conditions and purposes set out in Articles 5 and 6 of Law No. 6698, for the purpose of defining and implementing our company’s commercial and business strategies.
Persons Necessary for the Performance of Services
Your personal data may be shared with banks, notaries, technical, logistical, and similar complementary or auxiliary service providers, business partners, suppliers, solution partners, support service organizations, external service providers, contracted organizations, independent audit institutions, and other legally authorized third parties, to the extent necessary to ensure the full and flawless provision of services. These third parties are limited to those who must access the relevant information to properly deliver the respective services.
Persons Whose Sharing is Mandated by Law
Your personal data may also be transferred — limited only to the relevant person or institution — if it is necessary to fulfill the Company's legal obligations, explicitly stipulated by law, or ordered by a judicial/administrative authority in accordance with the law.
Consultancy and Support Service Providers
Your personal data may be transferred, solely to the extent necessary for the execution of these purposes, to third-party service providers supporting storage, archiving, IT support, security, and call center services; business partners and financial institutions; law firms, consultancy companies, and other related parties as well as authorized public institutions for the protection of Company or user rights and for the fulfillment of legal obligations.
Agencies and Advertisers
Some of your personal data may be shared with advertisers in an anonymized and aggregated form — along with information belonging to other users — to enable the tailoring of advertisements to target audiences. Anonymized data cannot be matched with you and does not contain identifiable personal information. Your confidentiality is guaranteed in anonymized data.
e) Sharing Your Personal Data with Third Parties in Turkey and Abroad
Your personal data may be shared, domestically or abroad, with companies to which our Company provides services, human resources consultancy firms, financial institutions, information technology companies, notaries, healthcare organizations, professional consultants, lawyers, accountants, occupational health and safety organizations, and other institutions with which the Company has commercial, administrative, or contractual relationships.
f) Method and Legal Basis for Collecting Personal Data
Depending on the services provided by our Company, your personal data may be collected verbally, in writing, or electronically, through automatic or non-automatic methods, via offices, locations, branches, call centers, websites, social media platforms, technical and other means, mobile applications, and similar channels. Your personal data may continue to be processed and updated as long as you benefit from the Company’s services. Additionally, your personal data may be processed when you contact our call center, use our website, visit our premises, or participate in our trainings, seminars, or events.
Processed Personal Data and the Legal Basis of Processing
Your identification information, such as your full name, date of birth, place of birth, and Turkish ID number as found in your driver’s license, ID card, or passport, is processed when services are rendered
based on legal obligations under the Tax Procedure Law No. 213 (Article 230 and following) and the Turkish Commercial Code No. 6102 (Article 82). (Law No. 6698, Article 5/2-a)
Even if you have not purchased any goods/services, if you become a member of our websites, your personal data is processed based on the necessity of processing for the performance of the membership agreement and in accordance with Article 48 of the Consumer Protection Law No. 6502. (Law No. 6698, Article 5/2-c)
Email, address, phone number, and other contact information
In the event that you receive services, your contact information is processed for the purposes of providing necessary information regarding the services received, establishing communication between the parties, and fulfilling contractual obligations. (Law No. 6698, Article 5/2-c)
Your history of products and services received from us is recorded to offer you a better shopping experience, to identify suitable products for you, to improve service quality, to conduct product planning, and to notify you about relevant products and services upon your request. These records are processed based on the necessity of data processing for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed. (Law No. 6698, Article 5/2-f)
Telephone conversations you have with us are recorded for the purposes of ensuring customer satisfaction, resolving possible disputes, and ensuring security. These records are processed based on the necessity of data processing for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed. (Law No. 6698, Article 5/2-f)
Camera recordings are made at all our domestic and international branches to ensure security. These recordings are processed based on the necessity of data processing for the legitimate interests of the data controller, provided that the fundamental rights and freedoms of the data subject are not harmed. (Law No. 6698, Article 5/2-f)
How Long Your Personal Data is Retained?
Unless otherwise required by legislation, your personal data is retained for a maximum of 10 (ten) years, pursuant to Article 182 of the Turkish Commercial Code and Article 146 of the Turkish Code of Obligations. Camera recordings are retained for a maximum of 1 year.
g) Rights of the Personal Data Owner under Article 11 of Law No. 6698
The Company, in accordance with Article 10 of the Law, informs you of your rights, provides guidance on how to exercise those rights, and carries out the necessary internal processes, administrative and technical arrangements for this purpose. Under Article 11 of the Law, the Company grants Personal Data owners the following rights:
a. To learn whether their personal data is being processed,
b. To request information if their personal data has been processed,
c. To learn the purpose of personal data processing and whether it is used in accordance with its purpose,
d. To know the third parties to whom personal data is transferred domestically or abroad,
e. To request the correction of personal data if it is incomplete or incorrectly processed,
f. To request the deletion or destruction of personal data when the reasons requiring their processing no longer exist,
g. To request that the processes carried out under subparagraphs (d) and (e) be notified to third parties to whom personal data has been transferred,
h. To object to the emergence of a result against the person through the exclusive analysis of processed data by automated systems,
i. To request compensation for damages arising from the unlawful processing of personal data,
explains that you have these rights.
In accordance with the Law on the Protection of Personal Data No. 6698, Personal Data Owners may submit their requests regarding the rights listed above, along with documents verifying their identity, by filling out and signing the Application Form available at https://cevirisepeti.net/ and delivering it to the Company free of charge, via the following methods or other methods determined by the Personal Data Protection Board:
(i) By delivering a wet-signed copy of the completed application form in person to Koşuyolu Mah. Lambacı Sok. Ateşoğlu Apt. A Blok No 1/5 Koşuyolu, Kadıköy/ISTANBUL,
(ii) By signing the completed form with a "secure electronic signature" under the Law No. 5070 on Electronic Signatures and sending it via registered electronic mail (KEP) to .............@hs01.kep.tr,
(iii) By using the email address previously notified to the Company and registered in the Company’s system to send the application form.
In order for third parties to submit an application on behalf of personal data owners, a notarized special power of attorney issued by the data owner must be provided.
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