Clarification Text

TURCONN METAL SANAYİ ve TİCARET A.Ş.

INFORMATION TEXT ON PROTECTION AND PROCESSING OF PERSONAL DATA

Revision Date: December 2020

Purpose: Turconn Metal Industry and Trade Inc. (“Company”) aims to process the personal data of personal data owners (Annex-1 Table Explaining Personal Data Owners) in accordance with the Personal Data Protection Law No. 6698 (“KVK Law”) and other legislative provisions.

     Your personal data that you have reported/will report to our Company and/or obtained by our Company externally by any means, will be processed by our Company in the capacity of “Data Controller”,

     In a limited and measured manner within the framework of the purpose that requires processing of your personal data and in connection with this purpose,

     By maintaining the accuracy and most up-to-date version of personal data as you provide or have been notified to our company,

     It will be recorded, stored, maintained, rearranged, shared with institutions that are legally authorized to request this personal data, and transferred to domestic or international third parties, transferred, classified and processed in other ways listed in the KVK Law, under the conditions stipulated by the KVK Law. We inform you that you may be subject to other procedures listed in the Law.

     With this “Information Text”, it has been adopted that the activities carried out by the Company will be continued and developed in accordance with the principles in the KVK Law.

Conditions for Processing Personal Data:

     Explicit consent of the personal data owner is only one of the legal bases that enable the lawful processing of personal data, and in case one of the following conditions is met, personal data is processed by our Company without seeking the explicit consent of the data owner.

     Other than explicit consent, the basis for personal data processing may be only one of the conditions specified below, or more than one condition may be the basis for the same personal data processing activity.

Clearly Provided in Laws

     If it is clearly provided for in the law, in other words, if there is a clear provision in the relevant law regarding the processing of personal data, the personal data of the data owner may be processed by our Company within the framework stipulated in the legislation.

Failure to Obtain Explicit Consent of the Person Relevant Due to Actual Impossibility

     If it is necessary to process the personal data of a person who is unable to express his/her consent due to actual impossibility or whose consent cannot be recognized as valid, in order to protect the life or physical integrity of himself or another person, the personal data of the data owner may be processed.

Directly Related to the Establishment or Performance of the Contract

     This condition may be deemed to be fulfilled if the processing of personal data is necessary, provided that it is directly related to the establishment or performance of a contract to which the data owner is a party.

Fulfillment of the Company’s Legal Obligations

     If data processing is mandatory for our company to fulfill its legal obligations, the personal data of the data owner may be processed.

Personal Data Owner’s Publicization of Personal Data

     If the data owner has made his/her personal data public, the relevant personal data may be processed on a limited basis for the purpose of publicization.

Data Processing Is Necessary for the Establishment or Protection of a Right

     If data processing is mandatory for the establishment, exercise or protection of a right, the personal data of the data owner may be processed.

Data Processing Is Necessary for Our Company’s Legitimate Interests

     Personal data of the data owner may be processed if data processing is necessary for the legitimate interests of our Company, provided that the fundamental rights and freedoms of the personal data owner are not harmed.

Collection and Procedure of Personnel / Personnel Candidate Personal Data:

     Our company will process your personal data for the purposes specified in this Information Text. If there is any change in the purpose of processing your personal data, additional permission will be obtained from you.

The personal data collected and used by our company are particularly:

CONTENT OF PERSONAL DATA:

Contact Data: Telephone number, address, country, e-mail address (including extension number and corporate e-mail address).

Identity Data: Name-Surname, T.R. Driving license, passport, identity card, blood group, health report containing information such as identification number, tax identification number, criminal record, residence record, signature/initial information, nationality information, mother’s name-father’s name, place of birth, date of birth, gender. Documents such as information and copies of documents regarding disability/disability status, if any.

Employee Candidate Information: Personal data such as resumes and interview notes of candidates who have applied for a job or intern in our company by any means.

Location Data: Determines the location of our employees and the employees of the institutions we cooperate with while using our Company’s vehicles.

Salary Data: Data included in the payroll processes paid/to be paid according to the Employment Contract, bank account information from which salaries are paid, receipts showing that payments are made.

Other Data: Data such as photographs, diplomas, graduation certificates, certificates, CV, image and/or audio recordings taken at the workplace, job references, telephone number, e-mail address, fingerprint.

Personnel Transaction Data: Data such as encryption transactions such as passwords and codes that are required and recorded within the company’s working system, and correspondence and e-mails connected to company e-mail accounts, if allocated to personnel.

Financial Data: Withheld income tax, series, sequence number, current account information, bank account information (account number, Iban number), credit card number, data included in the declaration processes

Other Data: VAT declaration notification, data on the license plate recognition screen (time, door, description, speed), authorization code, form designs, invoice number, date, VAT declaration, activity certificate, tax plate, trade registry gazette, invoice data, payment period, information in the seller identification process (code, status, correspondence language, commercial information)

Customer Transaction Data: Information such as records regarding the use of products and services and the customer’s instructions and requests required for the use of products and services (payment document type, date, series-sequence number, etc.).

Professional Experience Data: Data on the diploma, date/number of occupational medicine certificate

Request/Complaint Management Information: It means personal data regarding the receipt and evaluation of any requests and/or complaints directed to our company.

Visual and Audio Data: Data that has a visual or audio quality, such as photographs, camera/audio recordings.

Physical Space Security Information: Personal data such as camera records and visitor records regarding the records and documents taken upon entering the physical space and during the stay in the physical space.

Audit and Inspection Information: Personal data processed during internal or external audit activities within the scope of our company’s legal obligations and compliance with company policies.

     In order to fulfill its legal obligations, our Company will share with you the data you have submitted to our Company, both before and after the establishment of the contractual relationship and throughout the period, through all kinds of information documents and documents obtained in physical or electronic media and in physical or electronic environments for the reasons stipulated by law. and collects data through cameras placed in Company buildings.

Purposes of Processing Personal Data and Legal Reasons

     Your Personal Data may be processed by our Company for but not limited to the purposes stated below.

     Duties, Authorities, Responsibilities and Training of Personnel, Labor Law, Commercial Law, Law of Obligations, Occupational Health and Safety Law, Tax Procedure Law, Income Tax Law, Corporate Tax Law, Stamp Tax Law, Value Added Tax Law and the mentioned legislations. In particular, in order to fulfill legal obligations and requirements;

For our customers and suppliers:

– Making stamp tax declaration notification,

– Notification regarding purchases and sales of goods and services,

– Notification of withholding tax return,

– Notification of value added tax return, provisional tax return, corporate tax return,

For the purpose of establishing and executing the contract, in particular;

– Recruitment/supply of personnel,

– Conducting employee employment/periodic examination,

– Conducting employee examination,

– Preparation, approval and recording of progress payments,

– Keeping the minutes and recording of the work done and delivered,

– Processing invoices from vendors and invoices sent to purchasing customers,

– Opening a record in the system for the seller or buyer,

– Following up purchase and sales orders,

In accordance with the legitimate interest of the data controller and for the implementation of our Company’s policies, in particular;

Physical Space Security Data / Camera Recordings

– Monitoring camera footage inside the building and factory,

– Monitoring vehicle entries and exits and parking lot usage

In terms of our employees and employee candidates;

– Submitting SSI declaration,

– Notification of the Stamp tax declaration of the Employment Contract,

– Supervising the duties and authority given to personnel in the company,

– Ensuring the operation of the company,

For the purpose of establishing and executing the contract, in particular;

– Evaluation of personnel CV and work experience

– Conducting employee employment/periodic examination,

– Submission of SSI monthly declarations,

– Payment of salaries and other labor rights, if any

– Payment of salaries and other labor rights, if any

– Keeping the personnel personnel file physically and electronically, provided that it remains within the employer retention and submission obligation periods in accordance with the Occupational Health and Safety, Social Security Law and Labor Law,

– Recording all the above-mentioned matters,

In particular, for the legitimate interest of the data controller and for the implementation of our Company’s policies;

Physical Space Security Data / Camera Recordings

– Monitoring camera footage inside the building and construction site,

– Ensuring workplace and construction site safety,

– Monitoring vehicle entrances and exits and parking lot usage,

     Your personal data will be retained for a reasonable period of time specified in the relevant legislation or until the purpose of processing ceases, and in any case, for the legal statute of limitations.

Transfer of Personal Data to Third Parties

     In order to fulfill legal obligations and employment contract requirements, including but not limited to the Income Tax Law, Corporate Tax Law, Tax Procedure Law, Labor Law and Social Security Law, Occupational Safety and Health Law and these legislations; It can be transferred to the Revenue Administration, the General Directorate of Security, the relevant employees of our Company, the relevant companies and the group company.

4.1. Transfer of Personal Data to Third Parties Domestic;

In particular, in order to fulfill legal obligations in accordance with the Income Tax Law, Corporate Tax Law, Tax Procedure Law, Labor Law, Social Security Law, Occupational Safety and Health Law and the relevant legislation, laws, regulations and communiqués in force;

– Evaluation of personnel CV and work experience,

– Conducting employee employment/periodic examination,

– Submission of SSI monthly declarations,

– Payment of salaries and other labor rights, if any

– Keeping the personnel personnel file physically and electronically, provided that it remains within the employer retention and submission obligation periods in accordance with the Occupational Health and Safety, Social Security Law and Labor Law,

– Recording all the above-mentioned matters,

– Making stamp tax declaration notification,

– Notification regarding purchases and sales of goods and services,

– Notification of withholding tax return, value added tax return, provisional tax return, corporate tax return,

– It can be transferred to the relevant OHS expert or legal entity regarding the Social Security Institution and Occupational Health and Safety.

In order to implement our company’s policies, especially;

     It can be transferred to our Company’s group companies for the purpose of receiving financial affairs services.

Ensuring the Security and Confidentiality of Personal Data

     In accordance with Article 12 of the KVK Law, our company takes all necessary technical and administrative measures to prevent unlawful processing of personal data and unlawful access to personal data, and to ensure the appropriate level of security to ensure the preservation of personal data.

5.1. Technical Measures Taken to Ensure Lawful Processing of Personal Data and Prevent Unlawful Access to Personal Data

– Taking technical precautions to the extent technology allows

– Employing people who are experts in technical matters

– Inspecting the implementation of the measures taken at regular intervals

– Creating the necessary software and infrastructure to ensure security

– Limiting access to data being processed within the company

– Using a backup program in accordance with the law to ensure safe storage of personal data

– Using software containing virus protection systems

     The company has taken all kinds of technical and technological security measures to protect your personal data and has protected your personal data against possible risks.

5.2. Administrative Measures Taken to Ensure Lawful Processing of Personal Data and Prevent Unlawful Access to Personal Data

– Training and raising awareness of company employees regarding the KVK Law,

– In cases where personal data is transferred, ensuring that a record is added to the contracts concluded with the persons to whom personal data is transferred, stating that the party to which personal data is transferred will ensure data security,

– Determining what needs to be fulfilled in order to comply with the KVK Law and preparing internal policies for their implementation,

5.3. Measures to be taken in case of disclosure of personal data through illegal means

     If the processed personal data is obtained by others through illegal means, our Company will notify the relevant data owner and the Board as soon as possible.Deletion, Destruction and Anonymization of Personal Data

     Pursuant to Article 7 of the KVK Law, although personal data has been processed in accordance with the relevant legislation, if the reasons requiring processing are eliminated, personal data is deleted, destroyed or anonymized by our Company ex officio or upon the request of the personal data owner.

     The procedures and principles regarding this matter will be fulfilled in accordance with the KVK Law and the secondary legislation that will be established based on this Law.

6. Deletion, Destruction and Anonymization of Personal Data

     Pursuant to Article 7 of the KVK Law, although personal data has been processed in accordance with the relevant legislation, if the reasons requiring processing are eliminated, personal data is deleted, destroyed or anonymized by our Company ex officio or upon the request of the personal data owner.

     The procedures and principles regarding this matter will be fulfilled in accordance with the KVK Law and the secondary legislation that will be established based on this Law.

6.1. Deletion and Destruction Techniques of Personal Data

     Example: physical destruction, secure deletion from software, secure deletion by expert, etc.

6.2. Techniques for Anonymization of Personal Data

     It refers to making personal data impossible to associate with an identified or identifiable natural person in any way, even by matching it with other data.

Rights of Personnel/Personnel Candidates

     In accordance with Article 11 of the KVK Law, you can contact our Company and make requests regarding the following issues regarding your personal data:

Learning whether personal data is being processed or not,

Requesting information if personal data has been processed,

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

Learning about third parties to whom personal data is transferred domestically or abroad,

Requesting correction of personal data in case of incomplete or incorrect processing and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,

Requesting the deletion, destruction or anonymization of personal data in case the reasons requiring the processing of personal data disappear, and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,

Object to the emergence of a result that is unfavorable to the data owner by analyzing the processed personal data exclusively through automatic systems,

Request compensation for damages in case of damage due to unlawful processing of personal data.

Rights of the Customer / Supplier

In accordance with Article 11 of the KVK Law, you can contact our Company and make requests regarding the following issues regarding your personal data:

Learning whether personal data is being processed or not,

Requesting information if personal data has been processed,

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

Learning about third parties to whom personal data is transferred domestically or abroad,

Requesting correction of personal data in case of incomplete or incorrect processing and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,

Requesting the deletion, destruction or anonymization of personal data in case the reasons requiring the processing of personal data disappear, and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,

Object to the emergence of a result that is unfavorable to the data owner by analyzing the processed personal data exclusively through automatic systems,

Request compensation for damages in case of damage due to unlawful processing of personal data.

Data Controller

Turconn Metal Industry and Trade Inc. (Shortly referred to as “Company”), we hereby inform you that we process your personal data as the data controller within the scope of the Personal Data Protection Law No. 6698 (hereinafter referred to as “KVKK”) and other relevant legislation.

DATA CONTROLLER: Turconn Metal Sanayi ve Ticaret A.Ş.

ADDRESS: İ.T.O.S.B. 4th Ave. No:10 Tepeören Tuzla Istanbul

CONTACT: T:+902165933634-35

                      F:+902165933774

                      info@turconn.com

     Our company will fulfill your requests arising from the KVK Law through the “Personal Data Owner Application Form”. “Personal Data Owner Application Form” …. You can access it from the link. In accordance with Article 13 of the KVK Law, our company will finalize your application requests free of charge, depending on the nature of the request and within 30 (thirty) days at the latest. If the request is rejected, you will be notified of the reason(s) for rejection in writing or electronically.

     This Information Text may be revised by our Company when deemed necessary. In case of revision, our clarification text will be published on our address https://www.turconn.com/, indicating the revision date.