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YILDIZ ENTEGRE AĞAÇ SANAYİ VE TİCARET A.Ş. PRIVACY POLICY

PREFACE

Under the Personal Data Protection Law, YILDIZ ENTEGRE AĞAÇ SANAYİ VE TİCARET A.Ş. prioritizes the protection of your personal data and/or special categories of personal data. We are committed to safeguarding all personal data and/or special categories of personal data that are transmitted to our company through various channels. In this context, in order to comply with the provisions of the Constitution of the Republic of Turkey and other relevant legislation, including the Personal Data Protection Law No. 6698, we, as YILDIZ ENTEGRE AĞAÇ SANAYİ VE TİCARET A.Ş., have taken the necessary technical and administrative measures. We would also like to emphasize that we will protect your rights guaranteed by the laws. In this context, you can safely share your personal data with YILDIZ ENTEGRE AĞAÇ SANAYİ VE TİCARET A.Ş. and communicate any suggestions, complaints, and concerns with us.

We are sharing with you our Privacy Policy, which has been implemented within YILDIZ ENTEGRE AĞAÇ SANAYİ VE TİCARET A.Ş. and is particularly important in terms of protecting your personal data.

YILDIZ ENTEGRE AĞAÇ SANAYİ VE TİCARET A.Ş.

DEFINITIONS

Data ControllerRefers to YILDIZ ENTEGRE AĞAÇ SANAYİ VE TİCARET A.Ş., which determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system.
Data Subject - Relevant PersonRefers to the individual whose personal data is being processed.
CompanyRefers to YILDIZ ENTEGRE AĞAÇ SANAYİ VE TİCARET A.Ş. in accordance with this policy.
LawRefers to the "Personal Data Protection Law No. 6698.
Personal DataRefers to any information related to an identified or identifiable natural person.
Special Categories of Personal Data Refers to data about an individual’s race, ethnicity, political opinions, philosophical beliefs, religion, sect, or other beliefs, their appearance or clothing, membership in associations, foundations or trade unions, health, sexual life, criminal convictions, security measures, as well as biometric and genetic data.
BoardRefers to the Personal Data Protection Board.
PolicyRefers to this "Privacy Policy.
Processing of Personal DataRefers to any operation performed on personal data, whether automated or not, such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, acquiring, making available, classifying, or preventing the use of the data.
Explicit ConsentRefers to consent that is based on information and expressed freely on a specific subject. 
DestructionRefers to making personal data inaccessible, irretrievable, and unusable by anyone in any way. 
DeletionRefers to making personal data inaccessible and unusable for the relevant users.
AnonymizationRefers to making personal data unidentifiable, even when combined with other data, and preventing its association with any identified or identifiable natural person. 
DisposalRefers to the deletion, destruction, or anonymization of personal data. 
DataRefers to both personal data and special categories of personal data.

PURPOSE OF THE PRIVACY POLICY

The protection of personal data and compliance with the law is our fundamental principle. As YILDIZ ENTEGRE AĞAÇ SANAYİ VE TİCARET A.Ş. (hereinafter referred to as "YILDIZ ENTEGRE AĞAÇ SANAYİ" or "the Company"), all personal data and/or special categories of personal data obtained from you in the course of our work are kept confidential and have not been shared with third parties. In this regard, our company has always shown the necessary sensitivity to the protection of personal data and/or special categories of personal data. Furthermore, in accordance with the Personal Data Protection Law No. 6698 (hereinafter referred to as the "Law" or "KVKK"), our internal regulations have been revised, and technical and administrative measures have been taken. Moving forward, as YILDIZ ENTEGRE AĞAÇ SANAYİ, we accept, declare, and commit to complying with all obligations imposed by the law.

SCOPE OF THE PRIVACY POLICY

This Privacy Policy has been prepared in accordance with the Personal Data Protection Law No. 6698.
Your personal data and/or special categories of personal data are processed with your consent or in accordance with legal compliance situations. The data in question is used for the following purposes:

  • Ensuring the security of the company,
  • Providing you with comprehensive services,
  • Conducting our commercial activities,
  • Resolving your issues quickly,
  • Improving our quality.

Some of the personal data and/or special categories of personal data provided by you are de-identified and anonymized in accordance with the procedures stipulated by the Law. Data used for statistical purposes is not currently covered by the regulation of the Law or the scope of our policy. As YILDIZ ENTEGRE AĞAÇ SANAYİ, we reserve the right to amend this policy in order to protect personal data in compliance with the Law.

The Privacy Policy aims to protect the data of individuals and legal entities, including the business partners, customers, employees, and all other individuals whose data is obtained through any means, in cooperation with YILDIZ ENTEGRE AĞAÇ SANAYİ. In this context, it includes various provisions to achieve the intended goal.

BASIC PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA

The basic principles related to the processing of personal data and/or special categories of personal data are as follows. In this context, the principles will apply to the data processed by YILDIZ ENTEGRE AĞAÇ SANAYİ, either based on explicit consent or under legal compliance situations.

  • Compliance with the Law: YILDIZ ENTEGRE AĞAÇ SANAYİ ensures that the personal data and/or special categories of personal data it collects from individuals and legal entities through various means are obtained from lawful sources and are in compliance with the law. In this regard, obtaining data in a lawful manner is crucial for YILDIZ ENTEGRE AĞAÇ SANAYİ.
  • Compliance with the Rules of Honesty: YILDIZ ENTEGRE AĞAÇ SANAYİ checks the source of personal data and/or special categories of personal data it collects from individuals and legal entities through various means. In this context, it is important for YILDIZ ENTEGRE AĞAÇ SANAYİ to obtain data in accordance with the rules of honesty.
  • Limited, Proportionate, and Relevant to the Purpose of Processing: YILDIZ ENTEGRE AĞAÇ SANAYİ uses personal data and/or special categories of personal data obtained through various means in a manner that is appropriate to the purpose for which they were processed, limited to the purpose of processing, proportionate, and to the extent required for the provision of the service.
  • Accuracy of Personal Data and/or Special Categories of Personal Data: YILDIZ ENTEGRE AĞAÇ SANAYİ values the accuracy of personal data and/or special categories of personal data it collects from individuals and legal entities through various means, ensuring that they do not contain incorrect information. However, YILDIZ ENTEGRE AĞAÇ SANAYİ is not obligated to verify the accuracy of personal data and/or special categories of personal data provided by its customers or individuals and legal entities it interacts with, as this is not feasible in accordance with legal requirements and our working principles.
  • Up-to-Date When Necessary: YILDIZ ENTEGRE AĞAÇ SANAYİ places importance on ensuring that if there are any changes to the personal data and/or special categories of personal data it has obtained through various means, these changes are communicated to the company, and if such changes are communicated, the data is updated.
  • Processed for Specific and Legitimate Purposes: YILDIZ ENTEGRE AĞAÇ SANAYİ processes personal data and/or special categories of personal data based on the explicit consent of the data subject or within the framework of legal exceptions stipulated by law, without requiring explicit consent. Each data processing purpose is specific, and personal data is not processed for any unlawful purposes.
  • Retention for the Duration Stipulated by the Law and/or as Necessary for the Purpose of Processing: YILDIZ ENTEGRE AĞAÇ SANAYİ retains personal data and/or special categories of personal data for the periods specified by the relevant laws and/or for the duration necessary for the purpose of processing. Once the relevant purposes are fulfilled, the company anonymizes, destroys, or deletes the data.

DELETION, DESTRUCTION, AND ANONYMIZATION OF PERSONAL DATA

Your personal data and/or special categories of personal data are deleted, destroyed, or anonymized once the statutory limitation periods and retention periods specified by the Law have expired, judicial processes are completed, or other requirements for the purpose are fulfilled. Deletion, destruction, and anonymization of data are carried out either upon the request of the relevant data subject or automatically (ex officio) by YILDIZ ENTEGRE AĞAÇ SANAYİ.

PRİNCİPLE OF MAXİMUM EFFİCİENCY

The principle of maximum efficiency, ensures that personal data and/or special categories of personal data, obtained through various means, are transferred into our company's system. According to this principle, data is processed into the system only as necessary.

The data to be collected by YILDIZ ENTEGRE AĞAÇ SANAYİ is determined according to the specific purpose and may vary. In this context, data is collected in alignment with the intended purpose, and data that does not align with this purpose is not collected. Any excessive data outside the purpose is neither stored in the company's system nor retained. Instead, it is deleted, destroyed, or anonymized. However, such data may be used for statistical purposes.

DATA CONFIDENTIALITY AND SECURITY

At YILDIZ ENTEGRE AĞAÇ SANAYİ, we prioritize the confidentiality of your personal data and/or special categories of personal data. In this regard, any personal data and/or special categories of personal data that are sent to our company through various means are kept confidential. YILDIZ ENTEGRE AĞAÇ SANAYİ ensures the confidentiality of such data at every stage of its commercial operations. Therefore, full compliance with this company’s confidentiality policy is maintained.

To prevent personal data and/or special categories of personal data collected through various means from falling into the hands of unauthorized individuals, and to ensure that the data subject's rights are not violated, necessary technical and administrative measures are taken to protect the data. Furthermore, in line with legal compliance, we request data protection from third parties with whom we share personal data and/or special categories of personal data, when necessary. Additionally, our software programs are updated and continuously renewed. Technological requirements are met, and compliance with standards is ensured to provide high-level protection.

DATA ACCURACY

The principle of accuracy is fundamental at YILDIZ ENTEGRE AĞAÇ SANAYİ. Personal data and/or special categories of personal data obtained through various means can be updated when necessary or upon request. The necessary measures for updating are also taken by YILDIZ ENTEGRE AĞAÇ SANAYİ.

ACCURACY OF DATA

The principle of accuracy of the declared personal data and/or special categories of personal data is adopted by YILDIZ ENTEGRE AĞAÇ SANAYİYILDIZ ENTEGRE AĞAÇ SANAYİ is not obligated to verify the accuracy of the personal data and/or special categories of personal data declared by its customers or individuals with whom it is in contact. This is not feasible in accordance with legal requirements and our operational principles. In this context, transactions are carried out based on the assumption that the declared data is accurate.

PURPOSES OF PROCESSING PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA

The processing of personal data and/or special categories of personal data is carried out in line with the purposes stated in YILDIZ ENTEGRE AĞAÇ SANAYİ’s Clarification Texts. These texts may vary depending on the type of personal data and/or special categories of personal data being processed. In parallel with the differences in the Clarification Texts, the purposes for processing personal data and/or special categories of personal data may also vary.

PROCESSING PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA FOR ADVERTISING PURPOSES

Approval must be obtained from the recipient for advertising purposes in electronic communications. In this context, advertising electronic communications can only be sent to individuals who have previously given their consent. This matter is explicitly regulated in the Law on the Regulation of Electronic Commerce and the Regulation on Commercial Communication and Commercial Electronic Messages.

YILDIZ ENTEGRE AĞAÇ SANAYİ acts in accordance with the aforementioned regulatory provisions when sending advertising electronic commercial communications. Additionally, consent is obtained and the details of the consent are adhered to in compliance with the relevant laws. This consent can be obtained through any electronic communication means or in writing in a physical environment. The key principle of the consent is that the recipient of the commercial electronic communication has expressed a positive declaration of intent to accept the receipt of commercial electronic communications, and it includes their electronic communication address and full name.

The consent obtained from the recipient covers all commercial electronic communications sent to their electronic communication addresses with the aim of marketing and promoting the company's goods and services, promoting its business, increasing its recognition, and for purposes such as greetings, congratulations, and similar content.

In addition, before sending electronic commercial communications, individuals are informed that their data may be processed, and their explicit consent is obtained when necessary. During the sending of these commercial communications, all actions are carried out in accordance with the provisions of the Personal Data Protection Law No. 6698.

COLLECTION AND PROCESSING OF PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA WITHIN THE FRAMEWORK OF A CONTRACTUAL RELATIONSHIP

If a contractual relationship has been established with customers or potential customers, the personal data collected under the contract may be processed by YILDIZ ENTEGRE AĞAÇ SANAYİ without obtaining explicit consent. In cases where the processing of special categories of personal data is involved, data can be processed based on explicit consent or legal grounds under Article 6 of the Law. These data are used within the framework of the execution of the goods and/or services, the performance of the contract, and the conduct of commercial activities. Such data may always be updated by communicating with customers.

PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA PROCESSED THROUGH AUTOMATED SYSTEMS

Data obtained through automated systems without the explicit consent of individuals cannot be used against the individuals. YILDIZ ENTEGRE AĞAÇ SANAYİ acts in accordance with the relevant legal provisions regarding personal data and/or special categories of personal data processed through automated systems.

PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA BELONGING TO EMPLOYEES OF YILDIZ ENTEGRE AĞAÇ SANAYİ

PROCESSING UNDER LEGAL OBLIGATIONS
Personal data belonging to employees may be processed by YILDIZ ENTEGRE AĞAÇ SANAYİ without explicit consent if there is a clear provision in the relevant law regarding the processing of the data or if the data controller needs to fulfill its legal obligations.

PROCESSING PERSONAL DATA IN ACCORDANCE WITH THE EMPLOYMENT CONTRACT AND EMPLOYMENT RELATIONSHIP
Personal data of employees may be processed by YILDIZ ENTEGRE AĞAÇ SANAYİ without obtaining explicit consent, as long as it is necessary for the establishment of the employment relationship with the employees and in accordance with the principle of proportionality. YILDIZ ENTEGRE AĞAÇ SANAYİ undertakes to protect the personal data of employees, maintain its confidentiality, and take the necessary measures in this regard. 

PROCESSING OF SPECIAL CATEGORIES OF PERSONAL DATA OF EMPLOYEES
In accordance with the Law No. 6698 on the Protection of Personal Data, the processing of special categories of personal data requires the explicit consent of the person whose data is being processed, along with the necessary precautions specified by the Personal Data Protection Authority. YILDIZ ENTEGRE AĞAÇ SANAYİ processes special categories of personal data in compliance with the Law No. 6698 and the guidelines set by the Authority, ensuring that, when necessary, both the explicit consent of the data subject and the required precautions set by the Authority are obtained. However, special categories of personal data can be processed without the explicit consent of the data subject under the exceptional circumstances provided in the Law, as long as it is limited and proportional. 

PERSONAL DATA PROCESSED THROUGH AUTOMATIC SYSTEMS
Some personal data of employees may be processed through automated systems. These data are used for performance evaluations of employees, statistical data tracking, promotions, and scoring within the company. Employees have the right to object to any adverse results that arise regarding their own data. The objection must be made in accordance with the internal rules and procedures of the company. The objection will be subject to internal evaluation within the company. 

PROCESSING OF PERSONAL DATA IN FAVOR OF EMPLOYEES
Personal data of employees may be processed by YILDIZ ENTEGRE AĞAÇ SANAYİ without obtaining explicit consent, within the framework of the relationship provided by the employment contract, for processes that benefit the employee. Additionally, in cases of disputes related to the employment relationship with YILDIZ ENTEGRE AĞAÇ SANAYİ, the company may process personal data of employees. 

INTERNAL COMMUNICATION, INTERNET, AND TELECOMMUNICATION WITHIN THE COMPANY:
In order to facilitate the execution of work, YILDIZ ENTEGRE AĞAÇ SANAYİ may provide its employees with computers, phones, vehicles, applications, software, and email. YILDIZ ENTEGRE AĞAÇ SANAYİ has the authority to monitor and control personal data on the provided devices. However, in this context, YILDIZ ENTEGRE AĞAÇ SANAYİ also fulfills its Lighting Obligation.

Employees are not permitted to use the assigned devices for personal purposes. They are required to use them solely for the purpose of fulfilling their work duties. Additionally, from the moment the employee begins their employment with YILDIZ ENTEGRE AĞAÇ SANAYİ, they acknowledge, declare, and commit that no data or information unrelated to work will be stored on the devices provided.

15. TRANSFER OF PERSONAL DATA AND/OR SPECIAL CATEGORIES OF PERSONAL DATA TO DOMESTIC AND ABROAD: YILDIZ ENTEGRE AĞAÇ SANAYİ may transfer personal data and/or special categories of personal data both domestically and internationally, in accordance with the conditions prescribed in the Personal Data Protection Law and in line with the principles set forth by the Board, either within the scope of compliance with the law or with the explicit consent of the relevant person.

YILDIZ ENTEGRE AĞAÇ SANAYİ complies with Articles 8 and 9 of the Law No. 6698 when transferring personal and/or special categories of personal data.

AUDIT AND OPERATION SECURITY

Necessary technical and administrative measures are taken to ensure that personal data and/or special categories of personal data collected through various means do not fall into the hands of unauthorized individuals, that the rights of the data subjects are not harmed, and that the data is protected. Additionally, in accordance with legal compliance, we request data protection from the companies with which we share personal data and/or special categories of personal data, where applicable. Furthermore, our software programs are continuously updated, renewed, and improved. All technological requirements are fulfilled, and compliance with standards is ensured to provide high-level protection. In parallel with these efforts, YILDIZ ENTEGRE AĞAÇ SANAYİ conducts all necessary internal and external audits to ensure the protection of personal data and/or special categories of personal data.

NOTIFICATION OF DATA BREACHES

In the event of any data breach, YILDIZ ENTEGRE AĞAÇ SANAYİ will immediately take action to address the breach reported to it. Necessary measures will be taken to minimize the harm to the data subject. To report any breaches, you may follow the procedures indicated on our company's website. Additionally, if personal data and/or special categories of personal data are accessed by unauthorized third parties, the company will directly notify the Personal Data Protection Authority (KVKK) regarding the matter.

RIGHTS OF THE DATA SUBJECT REQUESTING INFORMATION

Article 11 of the Personal Data Protection Law No. 6698 outlines the rights of the data subject. In accordance with the law, YILDIZ ENTEGRE AĞAÇ SANAYİ acknowledges that before processing data, the relevant person must be informed, and where necessary, their explicit consent must be obtained. After the data is processed, the relevant person has the right to request information about their data, update, delete, erase, and anonymize it. Data subjects can request information regarding their data through the "Information Request Form under the Personal Data Protection Law No. 6698."

a) Learn whether personal data is being processed,

b) Request information if personal data has been processed,

c) Learn the purpose of processing personal data and whether it is being used in accordance with its purpose,

ç) Know the third parties to whom personal data has been transferred, both domestically and internationally,

d) Request the correction of personal data if it has been processed incompletely or inaccurately,

e) Request the deletion or destruction of personal data in accordance with the conditions outlined in Article 7 of the law titled "Deletion, Destruction or Anonymization of Personal Data,"

f) Request the notification of third parties to whom personal data has been transferred about the correction of incomplete or inaccurate data, or the deletion or destruction of data upon the request of the data subject,

g) Object to the outcome that occurs as a result of the personal data being analyzed solely by automated systems, which may be detrimental to the individual,

h) In case of damage caused by the unlawful processing of personal data, request the compensation for the damage.

These are the rights of the data subject.

"Requests for information made on behalf of someone else will not be answered by the company. If it is determined by YILDIZ ENTEGRE AĞAÇ SANAYİ that a request has been made on behalf of someone else, YILDIZ ENTEGRE AĞAÇ SANAYİreserves the right to take any legal action or claim. The requests of the data subject will be responded to as soon as possible, and no later than thirty days from the date YILDIZ ENTEGRE AĞAÇ SANAYİ receives the request. If deemed necessary, YILDIZ ENTEGRE AĞAÇ SANAYİ may request additional information and documents from the requesting individual.

UPDATE 

Changes made to this Privacy Policy are listed and shown in the table below.

Policy Update DateChanges