CLARIFICATION TEXT ON PERSONAL DATA PROTECTION LAW OF DAP GAYRİMENKUL GELİŞTİRME ANONİM ŞİRKETİ
In accordance with the Law No. 6698 on the Protection of Personal Data ("KVKK"), this clarification text has been prepared by DAP Construction Development Anonim Şirketi for the purpose of providing the necessary clarification to control the data of third parties whose data are processed, excluding our employees. Our company, as the data controller, may process, store, classify, update the Personal Data/Sensitive Personal Data of third parties in accordance with the law within the scope of the purposes explained below and, where permitted by the legislation.
1.Definitions
Law; the Law on the Protection of Personal Data (KVKK) No. 6698.
Personal Data; any information relating to an identified or identifiable natural person.
Sensitive personal data; Personal data relating to the race, ethnic origin, political opinion, philosophical belief, religion, religious sect or other belief, appearance, membership to associations, foundations or trade-unions, data concerning health, sexual life, criminal convictions and security measures, and the biometric and genetic data are deemed to be special categories of personal data.
Processing of personal data; means any operation which is performed on personal data, wholly or partially by automated means or non-automated means which provided that form part of a data filing system, such as collection, recording, storage, protection, alteration, adaptation, disclosure, transfer, retrieval, making available for collection, categorization, preventing the use thereof.
Data Owner/ Data Subject; the natural person, whose personal data are processed.
Data Processor; the natural or legal person who processes personal data on behalf of the data controller upon its authorization.
Data Controller; the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data filing system.
2. Purpose of Processing Personal Data/Sensitive Personal Data
Personal data /Sensitive personal data obtained by DAP Construction Development Anonim Şirketi will be processed within the scope of the following:
*Conducting Emergency Management Processes, Information Security Processes, Employee Candidate/Intern/Student Selection and Placement Processes, Application Processes of Employee Candidates, Auditing Ethics & Culture, Training Activities, Access Authorizations, Conduct of Activities in accordance with the Legislation, Finance and Accounting Processes, Implementing Financial/Product/Service Commitment Processes, Ensuring Physical Security, Conducting Assignment Processes, Following-up and Conducting Legal Activities, Conduct of Audit/Investigation/Intelligence Activities, Communication Activities, Human Resources Planning, Recruitment and Evaluation Processes, Auditing Business Activities, Conducting Occupational Health/Safety Activities, Business Partnership/Purchase-Sale Contract Negotiations and Contracts, Taking and Evaluating Suggestions for Improving Business Processes, Ensuring Business Continuity, Conducting Logistics Activities, Goods & Service Purchase Processes, Goods & Service After Sales Support Services, Goods & Service Production and Operation Processes, Customer Relationship Management Processes, Customer Satisfaction-Oriented Activities, Organization and Event Management, Conducting Marketing Analysis, Performance Evaluation Processes, Advertising / Campaign/Promotion Processes, Risk Management, Goods/Service Purchasing and Activities, Contract Processes, Sponsorship Activities, Strategic Planning Activities, Follow-Up of Requests/Complaints, Ensuring the Security of Movable Goods and Resources, Conducting Supply Chain Management Processes, Wage Policy, Marketing Processes of Products/Services, Managing the Process of Procurement of Power of Attorney and Signature Circular, Ensuring the Security of Data Controller Operations, Conducting Investment Processes, Talent/Career Development Activities, Providing Information to Authorized Persons, Institutions and Organizations, and the Execution of Management Activities.
3. Transfer of Personal Data/Sensitive Personal Data
Personal data processed within the scope of the explained purposes can be transferred to our business partners, shareholders, affiliates and subsidiaries, suppliers, Group Companies, authorized public institutions and organizations, to the companies from which you can find support services and to real persons and independent audit companies within the framework of legal obligations and legal limitations, in accordance with the basic principles stipulated in the KVKK and within the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK.
4. Transfer of Personal Data/Sensitive Personal Data Abroad
Personal data is not transferred abroad by DAP Construction Development Anonim Şirketi. In case of transfer of data abroad, the necessary information will be provided by our company and if it requires obtaining the explicit consent of the data subject due to the law, the necessary information will be provided to the data subject and explicit consent of the data subject will be obtained; only after this process, the transfer can be made.
5. Method of Collecting Personal Data/Sensitive Personal Data
Personal data is collected through applications to the Company, contacting via e-mail or different channels in order to carry out business activities by DAP Construction Development Anonim Şirketi, based on the legal reasons mentioned below.
6. Legal Reasons for the Processing of your Personal Data by the Company;
Personal data are collected, used, recorded, stored and processed within the framework of the principle of proportionality, in connection with and limited to the above-mentioned legitimate purpose, by clearly and comprehensibly informing the personal data owners in writing and obtaining their explicit consent if necessary, in order to establish an employment contract, to exercise the data subject's rights arising from the law and the contract, and in order for the Company to fulfill legal obligations in accordance with the law and the rules of honesty. Your personal data collected in this process are collected securely in physical and electronic environment during the beginning and continuation of the contractual relationship in order to carry out the above-mentioned processes and to carry out our commercial and business activities. In addition, if a special retention period is foreseen in the laws related to the relevant data, this data will be stored securely in physical and electronic environment for the foreseen retention period. In this context, special categories of personal data/personal data can be processed and transferred without explicit consent in the light of the principles stipulated in Article 4(2) of the KVKK or in the presence of the situations stipulated in Articles 5 (2) and 6(3).
7.Ensuring Protection of Personal Data
The Company takes all necessary measures stipulated in the 1st paragraph of Article 12 of the KVKK to provide an appropriate level of security for the protection of personal data.
8. Your Data Subject Rights within the Scope of KVKK
As per article 11 of KVKK, the rights of the data subject are as follows:
-
to learn whether his/her personal data are processed or not,
-
to demand for information as to if his/her personal data have been processed,
-
to learn the purpose of the processing of his/her personal data and whether these personal data are used in compliance with the purpose,
-
to know the third parties to whom his personal data are transferred in country or abroad,
-
to request the rectification of the incomplete or inaccurate data, if any,
-
to request the erasure or destruction of his/her personal data under the conditions referred to in Article 7,
-
to request reporting of the operations carried out pursuant to sub-paragraphs (d) and (e) to third parties to whom his/her personal data have been transferred,
-
to object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems,
-
to claim compensation for the damage arising from the unlawful processing of his/her personal data.
9. For Questions and Requests
Please send your requests regarding your rights mentioned in the above articles to the following email address
eltesins@hs01.kep.tr or to our company address: Altayçeşme Mahallesi, Zeytindalı Sokak, No:16 B Blok Maltepe / Istanbul Your request will be completed free of charge no later than thirty (30) days. However, if the process requires an additional cost, the fee in the tariff determined by the Board will be charged.
