DISCLOSURE ONPROCESSING OF PERSONAL DATA

CLARIFICATION NOTICE

We, Adilna İlaç San. ve Tic. A.Ş., Arven İlaç San. ve Tic. A.Ş., Aset İlaç San. ve Tic. A.Ş., Batoflora Tarım Ürünleri San. ve Tic. A.Ş., İstanbul Galenos Ecza Deposu Tic.ve San. A.Ş., Mayes Elektrik Üretim A.Ş., Montero Gıda San. ve Tic. A.Ş., Verano İlaç San. ve Tic. A.Ş., Verano Veteriner Ecza Deposu Tic. ve San. A.Ş., Sanovel İlaç San. ve Tic. A.Ş., Sanset Gıda Turizm San. ve Tic. A.Ş., Vinero Bağcılık San. ve Tic. A.Ş., Yema Elektrik Üretimi A.Ş., Zeema Elektrik Enerjisi Toptan Satış A.Ş., Rell Yazılım Ve Donanım Bilgi Sistemleri Sanayii Ticaret A.Ş., (hereinafter referred to as Toksöz Group), attach great importance to the protection of your personal data of whom make contact with us Within this scope, as per Personal Data Protection Law No. 6698 (KVKK), we process your personal data as “data supervisor” in accordance with KVKK and within the scope of purposes and limits specified below and take great attention on taking required administrative and technical precautions. Therefore, we would like you to be informed regarding our process your personal data and rights within KVKK by this "Clarification Notice on Processing of Personal Data"(“Notice”).

What is our Legal Reason for Collecting Your Personal Data?

Your personal data refers to all sorts of information and documents you submit to us verbal/or written, and/or electronically during and/or after you contact us, including your sensitive personal data and those information is stored in physical and digital media. Your personal data maybe processed in domestic or abroad with real persons and legal entities indicated in this Notice, compliance with fundamental principles set forth by KVKK, within the scope of terms and purposes of processing personal data specified in Article 5 and Article 6 of KVKK, and transmitted in domestic or abroad.

 

Method of Collecting and Processing Your Personal Data

Within the scope of the fulfillment of requirements on the matter you contact with Toksöz Group, as per the purposes stated in Article III of Notice, your personal data may be collected and processed by Toksöz Group by automatic or non-automatic methods to fulfill all its obligations, including legal obligations.

Toksöz Group acts compatible with data processing principles and obligations indicated in the relevant legislation notably the Constitution of the Republic of Turkey, international agreements of which our country is a party to and Law of Protection of Personal Data.

 

The Purposes of Processing Your Personal Data

Your personal data is processed for the purposes specified below:

  1. To perform required actions on the subject you contact with Toksöz Group,
  2. To fulfill the legal obligations and/or comply with law under related regulation,
  3. To meet the demands of authorized institutions and organizations,
  4. To inform you regarding information, activities and services you may request for,
  5. To copy-out/back-up to prevent data loss,
  6. To provide the fulfillment of legal obligations as the legal regulations requires or obliges and for other purposes specified in KVKK.

 

Domestic or Cross-Border Transfers of Your Personal Data

Your personal data collected in accordance with KVKK and Article I and Article II specified above may be transferred to Toksöz Group and its affiliated domestic/cross-border companies/institutions and the domestic/foreign business partners, suppliers, service providers, natural and/or legal person shareholders of these companies, legally authorized public institutions and private persons, including the domestic/international companies/institutions where the shareholders of Toksöz Group companies may become shareholders in the future, in accordance with the basic principles stipulated by KVKK and within the scope of the personal data processing conditions and purposes specified in Article 8 and Article 9 of KVKK and for the purposes mentioned above. Additionally, whereas Toksöz Group works with outside companies in order to provide information technology, cleaning, food, security, transportation, clothing services and so forth, those outside companies may, from time to time, access the company software and therefore your Personal Data under this software so that they could provide support to perform their services. Your personal data may, also, be transferred to administrative institutions such as Social Security Institution or judiciary, if required, under legal obligations.

Process Period of Your Personal Data

Your personal data processed for the purposes specified in this Notice, in accordance with KVKK, shall be deleted, destroyed or kept on being used by being anonymized by us when the purpose for processing your personal data according to Article 7/f.1 of KVKK has disappeared and/or the statute of limitations we are required to follow in processing your data has expired.

 

Surveillance of Toksöz Group Facilities by Camera

The entrances and exits, corridors, common areas and exteriors of Toksöz Group facilities are monitored by cameras for the safety of the facility and occupational health and safety purposes, and these records are only accessible to Toksöz Group's Security Unit and related departments and those records are kept for a certain period for security purposes and destroyed at the expiry of this period.

 

Your Rights as a Data Owner under KVKK

Within the scope of KVKK and relevant legislation, you are entitled to:

  1. Learn whether your Personal Data is processed,
  2. Request for information if your Personal Data is processed,
  3. Learn the purpose of processing of Personal Data and whether those are used as per the purpose,
  4. Know the third parties of whom your Personal Data is transmitted in the country or abroad,
  5. Request for the correction of your personal data in the case that those are processed deficiently or incorrectly,
  6. Request for your personal data to be deleted or destroyed pursuant to the conditions stipulated by KVKK,[1]
  7. Request for the transactions carried-out within the scope of sub-clauses (e) and (f) to be notified to the third parties of whom your Personal Data is transferred to,
  8. Object the processed datas arising against you by menas of being exclusively analyzed on automatic systems,
  9. Request for the indemnification in case of any damages arising from your Personal Data processed against KVKK

 

Cases where Toksöz Group can Process your Personnel Data without Your Explicit Consent as per KVKK:

Pursuant to Article 5 of KVKK, Toksöz Group is entitled to process your personal data mentioned above and obtained in accordance with the law without your explicit consent:

  • Cases expressly provided by law,
  • Being unable to express your consent as a data owner due to the practical impossibility, or the obligatory of the process of your personal data to protect yourself or the life or the body integrity of another person where your consent is not legally valid,
  • Requirement of personal data of process, pertaining to the parties of the agreement, provided that being directly concerned, the agreement executed or performed between the shareholders  of Toksöz Group of companies  and the domestic/ cross-border companies/ organizations and subsidiaries that those shareholders may become a shareholder in the future,
  • When it is mandatory for Toksöz Group to perform one of its legal obligations,
  • When your personal data is publicized by you,
  • When data processing is mandatory for the establishment, exercise or protection of a right,
  • When process data is mandatory for the legitimate interests of Toksöz Group without prejudice to your fundamental rights and freedoms.

 

How to Apply Toksöz Group regarding Your Rights

In order to exercise your rights mentioned above in accordance with Article 11 of KVKK, you may contact with Toksöz Group by completely filling in the Application Form specified on link and submiting this form, personally, to the address of İstinye Mahallesi Balabandere Caddesi No: 14 34460 Sarıyer/İSTANBUL or via registered letter with return receipt by a Notary Public. Toksöz Group will finalize your request within the shortest time and in any case within thirty (30) days at the latest according to the status of the request. In the case that the transaction requires an additional cost, we will charge you according to the tariff set by the Personal Data Protection Board. Nowithstanding, you may inform us the amendments and/or updates of your Personal Data by sending e-mail to kisiselveri@toksozgrup.com.tr or by personally applying the address of İstinye Mahallesi Balabandere Caddesi No:14 34460 Sarıyer/İSTANBUL.

 

Kindly submitted for your attention.

 


[1] The legal purpose of processing personal data should be removed, the legal retention period should expire or statutory of limitations should expire for this request to be fulfilled. Your request for deletion shall not be fulfilled before these periods have expired.