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Privacy Notice on the Processing of Personal Data

PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA

The protection of your personal data and private information is valuable to us. For this reason, we show all necessary effort and diligence to ensure that the personal data belonging to persons associated with “PROTON OTOMASYON ELEKTRİK MAKİNA İNŞAAT TAAHHÜT SANAYİ VE TİCARET LİMİTED ŞİRKETİ” are processed and preserved in accordance with the Personal Data Protection Law No. 6698 (“KVKK”).
In the capacity of Data Controller, “PROTON OTOMASYON ELEKTRİK MAKİNA İNŞAAT TAAHHÜT SANAYİ VE TİCARET LİMİTED ŞİRKETİ” takes the administrative and technical measures required for the protection of your data in all operations regarding your personal data, and processes your personal data in line with the KVK Law, under the conditions explained below and within the limits stipulated in the legislation.


1. Legal Nature and Scope

Article 10 of the Personal Data Protection Law No. 6698 requires that individuals whose data are processed be informed while obtaining their consent. The title of the article is “Data Controller’s Obligation to Inform.”According to the provisions of the KVKK, “PROTON OTOMASYON ELEKTRİK MAKİNA İNŞAAT TAAHHÜT SANAYİ VE TİCARET LİMİTED ŞİRKETİ” is the “Data Controller.” In this framework, with the obligation to inform, it has imposed an obligation to inform data subjects about the identity of the data controller, the purposes of personal data processing, the persons to whom personal data are transferred and the purposes of transfer, the legal reasons for collecting personal data, to whom they can be transferred and its methods, and the rights of the personal data subject enumerated in Article 11 of the KVKK Law, such as requesting updates, erasure, or anonymization from the data controller.


2. Veri Sorumlusunun Kimliği

In paragraph (ı) of the 1st paragraph of Article 3 of the KVKK Law, the data controller is defined as “Real or legal persons who determine the purposes and means of processing personal data and are responsible for the establishment and management of the data recording system.”  
In this framework, the data controller is “PROTON OTOMASYON ELEKTRİK MAKİNA İNŞAAT TAAHHÜT SANAYİ VE TİCARET LİMİTED ŞİRKETİ”. The contact information of our Company is as follows:

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

Purposes of Processing Your Personal Data

Your personal data are processed within the scope of the general principles specified in Article 4 of the KVKK Law and the personal data processing conditions specified in Articles 5 and 6 thereof, for the following purposes:a. Planning and implementing our corporate human resources policies in the best way;
b. Planning and/or conducting the application, selection, and evaluation processes of employee candidates,
c. Increasing the quality of the products/services offered, customizing and presenting them according to the needs, tastes, and usage habits of our customers in line with our customer satisfaction priorities, and making recommendations;
d. Correctly planning and conducting our commercial partnerships, affiliates, and strategies;
e. Ensuring the legal, commercial, and physical security of our Company, our business partners, and our affiliates,
f. Ensuring the highest level of personal and commercial data security, creating the appropriate information technology infrastructure and databases for this purpose, and taking administrative and technical measures,
g. Planning and/or executing supply chain management processes,
h. Conducting data analysis, research, statistical studies, understanding trends, and planning and/or managing advertising activities in order to carry out the marketing processes of products and/or services,
i. Ensuring the corporate operation of the Company, following up and managing financial and/or accounting works,
j. Taking necessary measures to provide and improve the standards related to issues falling within the scope of occupational health and safety,
k. Developing the services offered on our Company's website,
l. Following up on requests and complaints to be made by the relevant parties and ensuring feedback is provided to them,
m. Carrying out the necessary work by our relevant business units to realize the commercial activities conducted by the Company and executing the connected business processes,
n. Determining the strategies belonging to the Company and ensuring the corporate operation of the Company in line with our strategic plans and targets,
o. Rectifying the errors occurring on our Company's website and ensuring compliance with the provisions in our Company's Privacy Policy shared on the website.


3. To Whom and For What Purpose the Processed Personal Data Can Be Transferred

a. Your personal data may be transferred, within the framework of the personal data processing conditions specified in Articles 8 and 9 of the KVKK Law, for the purposes specified above;
b. In cases where it is necessary for the performance of commercial activities conducted by the Company, to our business partners, affiliates, financial investors, consultancy firms, suppliers, private institutions and organizations, and public institutions and organizations,
c. To the relevant banks for the necessary payment and collection transactions within the scope of the establishment and performance of the contracts that are the subject of processing your personal data,
d. To the courts and public institutions and organizations requesting information in necessary cases within the scope of fulfilling the legal obligations of our Company,
e. To law firms and other consultants in order to receive legal support within the scope of the establishment, exercise, and protection of our Company's rights,
f. Pursuant to the Capital Markets and Stock Exchange legislation, to the public, for the purpose of fulfilling the public disclosure obligation and provided that it remains within the limits required by these legislations,
g. To the necessary and relevant persons and third parties with whom they cooperate, in order to ensure business continuity, provide legal, technical, and commercial business security, and plan and execute human resources and occupational health and safety processes and strategies,
h. To human resources companies from which we receive services, or to previous or subsequent employers during the recruitment and termination processes,
i. To IT, archive firms, or cloud service firms for the purpose of providing the infrastructure and services required for corporate electronic communication channels and ensuring data security; and to platforms and applications of foreign origin for the purpose of presenting services via instant messaging or online communication channels which are widely and inevitably used today,
j. To audit institutions and firms within the scope of customer audits for the purpose of conducting quality and control processes,
k. To foreign organizations, online applications, and services providing services due to the applications and software used in the office and in the field for the purpose of conducting corporate activities,
l. To our companies located domestically within the framework of the personal data processing conditions specified in Articles 8 and 9 of the KVKK Law,
m. To archive firms or cloud service firms for the purpose of ensuring data security.
n. All kinds of technical and administrative measures are taken to ensure data security during and after the process of sharing your personal data.


4. Method and Legal Reason for Collecting Personal Data

Pursuant to Articles 4, 5, and 6 of the KVKK Law No. 6698, your personal data are collected in a manner compliant with the rules of:
a. Being in compliance with the law and the rules of honesty,
b. Being accurate and up-to-date when necessary,
c. Being for specific, explicit, and legitimate purposes,
d. Being relevant, limited, and proportionate to the purpose for which they are processed,
e. Being retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

Your personal data can be obtained through lawful means by automated or non-automated methods and from different channels such as offices, call center, website, social media media, mobile applications, and similar means, verbally, in physical environment, in electronic environment, or through closed-circuit television systems and other methods.
In addition, your collected personal data may vary depending on the service, product, or commercial activity provided by our Company.
Furthermore, the Company, in its capacity as Data Controller, processes the name and Internet Protocol (IP) address of the internet service provider used to access these channels within the framework of legal legislation aimed at improving and developing websites, applications, and platforms obtained through your access to the internet from the organization's network, the start and end time of the service provided, the type of service utilized, the amount of data transferred and, if any, subscriber identity information, the pages accessed during use, and the address of the web tools providing a direct connection, the device name, MAC address, and temporary internal IP numbers belonging to devices connecting to our internal network locally or remotely, and “traffic information” data, and records them by means of electronic tools for the purpose of fulfilling its legal obligations arising from Law No. 5651 and stores them for the periods stipulated in the legislation. The processing of your personal data within the scope of the said process is carried out based on the legal reason of “legal obligation” specified in the provision of Article 5/2(ç) of Law No. 6698.
Your personal data are processed based on the following legal reasons set forth in the KVKK Law No. 6698 (in Article 5):
a. Having the explicit consent of the person, as set forth in the first paragraph of Article 5,
b. Based on the legal reason that it is “explicitly foreseen in the laws” regulated in Article 5/2(a), the legislation to which our Company is subject, primarily the Turkish Commercial Code and the Tax Procedure Law, explicitly permitting the processing of your personal data,
c. Actual impossibility regulated in Article 5/2(b),
d. Based on the legal reason of the “establishment or performance of a contract” regulated in Article 5/2(c), your personal data being processed for fulfilling the requirements of the contract that is the subject of your disclosure of personal data and ensuring its continuation, opening current accounts, and performing payment and collection transactions,
e. Based on the legal reason that “it is mandatory for the data controller to fulfill its legal obligation” regulated in Article 5/2(ç), the Company processing your personal data for issuing legal declarations and notifications, complying with the retention periods stipulated in the legislation to which the Company is subject, and fulfilling other obligations stipulated in the relevant legislation, and meeting the requests of courts and public institutions and organizations requesting information and other legal obligations,
f. It “having been made public by the data subject themselves” regulated in Article 5/2(d),
g. Based on the legal reason that “data processing is mandatory for the establishment, exercise, or protection of a right” regulated in Article 5/2(e), the Company processing your personal data to serve as evidence in potential disputes, and to obtain legal consultancy and technical support,
h. The processing of your personal data being mandatory for the legitimate interests of our Company regulated in Article 5/2(f).
For the purposes specified in this Informing Text, your special categories of personal data are processed based on the following legal reasons specified in Article 6 of the KVKK Law:
i. Explicit Consent (Art. 6/2)
ii. Being foreseen in the laws (Art. 6/3: For special categories of personal data other than health and sexual life)
iii. Processing of data regarding health and sexual life by persons under the obligation of secrecy or authorized institutions and organizations for the purposes of preventive medicine, medical diagnosis, treatment, and care services, planning and management of health services and their financing (Art. 6/3).

Your personal data collected on these legal grounds can only be processed and transferred for the purposes specified in this Informing Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK Law.


5. Rights of the Personal Data Subject

As personal data subjects, if you submit your requests regarding your rights to our Company through the methods regulated in the next article of this Informing Text, our Company will finalize the request free of charge as soon as possible and within thirty days at the latest, depending on its nature. However, if the transaction requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board may be charged. Pursuant to Article 11 of the KVKK Law, the personal data subject has the right to:a. Learn whether personal data is processed or not,
b. Request information thereon if personal data has been processed,
c. Learn the purpose of processing personal data and whether they are used in accordance with their purpose,
d. Know the third parties to whom personal data is transferred domestically or abroad,
e. Request correction of personal data if it is processed incompletely or incorrectly and request notification of the operation performed within this scope to third parties to whom personal data has been transferred,
f. Request erasure or destruction of your personal data in the event that the reasons requiring its processing disappear, despite it having been processed in accordance with the Law and other relevant law provisions, and request notification of the operations performed within this scope to third parties to whom your personal data has been transferred,
g. Object to the occurrence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,
h. Request compensation for the damages in case of suffering damages due to the unlawful processing of personal data.


6. Making an Application and the Right to Receive Information

If you have any hesitation regarding your personal data, please apply to “PROTON OTOMASYON ELEKTRİK MAKİNA İNŞAAT TAAHHÜT SANAYİ VE TİCARET LİMİTED ŞİRKETİ,” whose address and contact information are shown above.
Pursuant to paragraph 1 of Article 13 of the KVK Law, you may submit your request regarding the exercise of your rights specified in Article 11 of the same law, in writing or by using a registered electronic mail (KEP) address or the electronic mail address previously notified to our company by you and registered in our system, to the address protonotomasyon@hs03.kep.tr.
In the application, it is mandatory to have:
a) Your name, surname, and signature if the application is in writing,
b) Your T.R. identity number if you are a citizen of the Republic of Turkey; your nationality, passport number, or identity number if any, if you are a foreigner,
c) Your residence or workplace address basis for notification,
ç) Your electronic mail address, telephone, and fax number basis for notification, if any,
d) Your subject of request. Information and documents related to the subject must be added to the application.

Our Company will finalize your requests within this scope free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the Board may be charged. In addition, only the part of your applications related to you will be answered, and an application made about your spouse, relative, or friend will not be accepted.