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Privacy Notice On Camera Recordings

PRIVACY NOTICE ON CAMERA RECORDINGS

PROTON OTOMASYON ELEKTRİK MAKİNA İNŞAAT TAAHHÜT SANAYİ VE TİCARET LİMİTED ŞİRKETİ (“Company”), in its capacity as the data controller, has prepared this text in accordance with the Law on the Protection of Personal Data No. 6698 (“KVKK”) in order to inform you regarding the collection, processing, and transfer of personal data via camera recording belonging to employees, visitors, subcontractor employees, suppliers, and other relevant persons within the factory premises, production lines, warehouse and shipment areas, administrative building, indoor and outdoor parking lots, entry-exit control points, and other service areas around the facility (“Camera Recording Locations”).

1. Methods and Legal Grounds for Collecting Personal Data

The camera monitoring and recording activity carried out by our Company is executed by capturing images through a closed-circuit television system (CCTV). This activity is based on the following legal grounds:

  • Fulfillment of our legal obligations arising from the relevant legislation, particularly the Labor Law No. 4857 and the Occupational Health and Safety Law No. 6331,
  • Being explicitly provided for in the laws pursuant to Article 5/2 (a) of the KVKK,
  • Being mandatory for the legitimate interests of the data controller (ensuring facility and production safety, preventing occupational accidents) pursuant to Article 5/2 (f) of the KVKK.

2. Purposes of Processing Personal Data

Considering the high-risk factors carried by our Company as a machinery production, design, and R&D facility, the collected personal data are processed for the following purposes:

  • Occupational Health and Safety (OHS): Auditing compliance with occupational safety rules in hazardous material production areas and detecting/preventing potential occupational accidents,
  • Production and Operation Safety: Ensuring the safety of production processes, machinery or product shipments, and warehouse areas,
  • Physical Space Security: Establishing the security of Company fixtures, products, and employees, and preventing theft and unauthorized entries,
  • Legal Processes: Meeting information/document requests from judicial and administrative authorities and serving as evidence in potential legal disputes.

Our Company strictly does not conduct monitoring in areas where individual privacy is paramount, such as locker rooms, restrooms, prayer rooms, and resting areas.

3. Announcement of Camera Monitoring Activity

In accordance with Article 10 of the KVKK, the Company ensures transparency by hanging warning signs stating "This area is monitored by camera" at the entrances of the monitored areas and by making this privacy notice accessible to the relevant persons.

4. Data Security and Retention Period

Only authorized units (IT, Security, and HR managers) have limited access to camera recordings. The obtained recordings are retained for the period required by the processing purpose (generally 24 days); at the end of this period or unless there is a legal request, they are automatically deleted or anonymized by the system.

5. Transfer of Personal Data

Camera recordings may only be transferred in the following cases and limitedly:

  • Authorized Public Institutions: To judicial authorities in line with the legal requests of the police, prosecutor's office, or courts,
  • Business Partners/Service Providers: To the private security firm that ensures the security of the facility or to technical service providers responsible for the maintenance of the camera system (within the framework of Articles 8 and 9 of the KVKK).

6. Rights of the Data Subject

By applying to our Company pursuant to Article 11 of the KVKK, you have the right to learn whether your personal data are processed, request information if processed, request deletion, and request indemnification of damages in case you incur damages.

Application Channels

Headquarters Address : Akçeşme Mahallesi Bozburun Yolu No:2 Merkezefendi/Denizli
Telephone : 0258 372 11 33
Web Address : https://www.proton.com.tr/
Email Address : info@proton.com.tr
KEP Address : protonotomasyon@hs03.kep.tr