We, as Tür-Mak Makine Sanayii Ve Ticaret Anonim Şirketi (“Tür-Mak” or the “Company”) hereby introduce this Privacy and Personal Data Protection Policy and Clarification Text (“Policy”) elucidative information and policies, set out under this Policy, concerning the purposes of processing, the methods of processing and storage, destruction and transfer processes with respect to personal data of our Customers, Local and International Business Partners, our Website Visitors, Employee Candidates and Employees.

We reserve the right to make amendments and arrangements in this Policy in consideration of regulations and other legislation which may be amended at times. In such case, we will introduce our new policy in compliance with amendments, on our website.

1. DEFINITIONS :

For the purpose of this Policy, the terms given below shall have the corresponding meanings:

1.1. Explicit Consent : means freely given, specific and informed consent.

1.2. Anonymization : means rendering personal data impossible to link with an identified or identifiable natural person, even through matching them with other data.

1.3. Data Filing System : means the system where personal data are processed by being structured according to specific criteria. 

1.4. Data Controller : means 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.

1.5. Data Processor :means the natural or legal person who processes personal data on behalf of the data controller upon its authorization.

1.6. The Law : means the Law numbered 6698 on the Protection of Personal Data.

1.7. Personal Datum/Data : means any information relating to an identified or identifiable natural person, be it citizen or foreigner.

1.8. 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.

1.9. Owner of Personal Data/Concerned Person: means the Company’s shareholders and employees, the Company’s suppliers, the Company’s officials, employee candidates, visitors, the Company’s customers, potential customers, third parties and other persons whose personal data are processed by the Company.

1.10. Special Categories of Personal Data : means 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.

2. PERSONAL DATA PROCESSED BY TÜR-MAK:

In consideration of the relation between Tür-Mak and persons or institutions whose data are processed, the data provided below may be processed in accordance with the Law:

2.1. Financial Information : Your financial information means data such as agreement between Tür-Mak and you, data regarding financial records obtained by persons with whom contract negotiations are conducted or with whom legal relationship is maintained, bank and branch name, account number, and IBAN number. 

2.2. Visual and Audial Data : means the camera records recorded limited to the purpose of security of our Company.

2.3. Identification Data : means the personal data such as name, surname, TR identity number, passport number, taxpayer identification number, place and date of birth, civil status, copy of ID card and similar data belonging to persons who are in contact with our Company due to various reasons.

2.4. Location Data : This data category means location data which are processed and which belong to Tür-Mak’s employees for the purposes of internal audit.

2.5. Contact Information : means personal data such as address, phone number, e-mail address, fax number and similar contact information belonging to persons who are in contact with our Company due to various reasons.

2.6. Customer Information : means personal data belonging to real persons such as business partners, suppliers, service providers, customers and officials, personnels with whom Türk-Mak is in commercial relation; and personal data belonging to real persons, obtained by means of documents such as tax board, trade registry entry, signature circular.

2.7. Special Categories of Personal Data: means the data categories such as health data, criminal records relating to criminal convictions concerning the Company’s employees.

2.8. Personnel Information : means data the record of which we are legally obliged to keep, and which belong to our personnel, such as identity, education, financial information, civil status and similar data.

3. PERSON GROUPS WHOSE PERSONAL DATA IS PROCESSING:

Tür-Mak may process the data belonging to the persons groups listed below:

3.1. Employee : means real persons in employment relationship with Tür-Mak by virtue of employment contract.

3.2. Employee candidate : means real persons who have pending job application before Tür-Mak.

3.3. Suppliers : means parties and their employees with whom Tür-Mak is in commercial relations for the sake of conduction of business operations, and who provides products or services to Tür-Mak in scope of their agreements with Tür-Mak.

3.4. Customer : means persons with whom Tür-Mak is in commercial relations for the sake of conduction of business operations, and to whom Tür-Mak provides services or sales products.

3.5. Potential Customer : means persons who are interested in purchasing services or products, as such those who have potential to become customer.

3.6. Company’s shareholder : means real persons who are shareholder in Tür-Mak.

3.7. Company’s official : means members of Tür-Mak’s board of managers and other real persons who are authorized in the Company.

4. THE METHOD AND LEGAL BASIS OF COLLECTION OF PERSONAL DATA:

In consideration of the relation between Tür-Mak and persons whose data are processed, limited to the purposes listed below, based on justifications set out under paragraph 2, Article 5 of the Law and other articles therein; if no such justification is laid down, based on explicit consent, personal data may be processed by Tür-Mak:

• In circumstances where personal data collection is required due to the legal obligations under domestic or foreign legislation to which Tür-Mak is subject (e.g. tax/finance legislation)

• In circumstances where personal data of the parties of a contract is necessary, for the purposes of providing products and services, or carrying out the obligations under contract, provided that it is directly related to the establishment or performance of the contract between Tür-Mak and Supplier, Customer and/or Potential Customer,

• In circumstances where processing of data is necessary for Tür-Mak to comply with legal obligations to which it is subject

• In circumstances where the relevant personal data has been made public by person or institution whose data are processed by besides the Tür-Mak.

• In circumstances where it is necessary for Tür-Mak to process data in accordance with legal legislation,

• Without prejudice to fundamental rights and freedoms, in circumstances where it is necessary to process data for the legitimate interests of Tür-Mak (e.g. in the event of security camera recording in the Company’s headquarter)

• Names, surnames, address and contact information on business cards shared, during organizations and fairs, based on Potential Customers or Suppliers (whereby the data on the business card are to be admitted as made public) may be processed for the purposes of launching business relations

5. THE PURPOSES OF PROCESSING PERSONAL DATA BY TÜR-MAK:

Your Personal Data may be processed by Tür-Mak for the purposes given below:

5.1. For Customers ; Tür-Mak may process data, concerning its products, in scope of sales and purchase and other contractual relations established with its customers as real and legal persons, for the purposes listed below:

• Conducting After Sales Support Services for Products/Services
• Conducting Sales Processes for Products/Services
• Conducting Consumer Relations Management Processes
• Conducting Activities for Customer Satisfaction
• Conducting deeds and operations in scope of business/contractual relations, and carrying out financial and legal obligations
• Request / Complaint Follow-up
• Carrying out legal obligations
• Carrying out guarantee obligations in scope of producer responsibility
• Conducting legal processes
• Advertising and marketing activities

5.2. For Potential Customers ; Information on your identity and contact which is directly provided by you to Tür-Mak through business cards in various fairgrounds and events (the data on the business card are to be admitted as made public) may be processed in accordance with paragraph 2, Article 5 of the Law for the purposes of making proposal for demanded products, establishment of contract, management of your requests and complaints; and based on your consent, for the purposes of informing you on our Company’s products and services, and for offering you special products in line with marketing purposes, if you are not merchant or tradesman.

5.3. For Employees ; personal data may be processed in scope of creating personnel file due to the reasons set out under relevant legislation, establishing employment contract and legitimate interests of Tür-Mak, for the purposes listed below:

• Conducting Employee Satisfaction and Engagement Processes
• Carrying out Obligations towards Employees Stemming From Employment Contract and Legislation
• Conducting Processes of Fringe Benefits and Interests for Employees
• Conducting Educational Activities
• Conducting Access Authorizations
• Conducting Finance and Accounting Work
• Ensuring the Security of Physical Location
• Conducting Task Appointment Processes
• Following-up and Conducting Legal Deeds
• Planning of Human Resources Processes
• Conducting and Auditing Business Operations
• Conducting Occupational Health and Safety Activities
• Receiving and Assessing Suggestions Concerning Amelioration of Business Processes
• Conducting Performance Assessment Processes
• Conveying Information to Authorized Persons, Institutes and Bodies, Serving Necessary Legal Notification to Government Agencies, Benefitting from Subsidies Allocated by Government Agencies, Notifying Relevant Authorities in scope of Government Bodies Inspections
• Conducting Human Resources Operations and In Particular, Personnel Activities,
• Carrying out Employee’s Audit and Conducting Data Processing Activities Necessary for Employer’s Right to Govern

5.4. For Suppliers ; In scope of business relation between you and Tür-Mak, personal data belonging to your company’s officials, shareholdersand employees may be processed in scope of establishment and performance of contracts, carrying out legal obligations, and our Company’s legitimate interests as set out under Article 5 of the Law, in compliance with the fundamental principles and conditions for processing personal data prescribed under the Law, for the purposes provided below:

• Conducting Contract Processes
• Conducting Finance and Accounting Work
• Carrying out and Following-up Responsibilities Stemming from the Legislation and Legal Processes
• Strategy Planning and Management of Business Partners/Suppliers
• Conducting Logistics Activities
• Conducting Supply Chain Management Processes
• Protection of Information which must be Stored according to the relevant Legislation; Copying and Backing Up to Prevent Information Loss; Ensure and Control the Accuracy of your Information; Taking all Necessary Technical and Organizational Measures for the Security of our Database and your Information

5.5. For Visitors ; Concerning your visits to our Company and other workplaces, in addition to ensuring your and our Company’s security, based on carrying out our legal obligations and legitimate interests, your visual data which are collected by means of security camera in physical locations, may be processed for the purposes provided below:

• Carrying out Audit and Security Activities
• Ensuring the Security of Physical Location
• Conveying Information to Authorized Persons, Institutes and Bodies

6. PARTIES TO WHICH PERSONAL DATA ARE TRANSFERRED AND THE PURPOSES OF TRANSFER :

Personal data processed by Tür-Mak may be transferred to the persons given below, for the purposes provided for in this Policy and in scope of the Law and other legislation:

• Suppliers and business partners for the purposes of the performance of contract,
• Lawyers, auditors, consultants and service providers,
• Authorized institutes or bodies or persons determined by them.

7. CONDITIONS FOR PROCESSING OF SPECIAL CATEGORIES OF PERSONAL DATA:

In data processing process, Tür-Mak avoids processing personal data to the full extent, if not legally obligatory; and may process such data, in so far as necessary, based on explicit consent by the concerned person or in circumstances where such processing is explicitly provided for in relevant legislation such as creating personnel file.

8. YOUR RIGHTS CONCERNING PERSONAL DATA:

You have the following rights concerning your personal data which are processed or which you think are processed:

• to learn whether his/her personal data are processed or not, to demand for information as to if your personal data have been processed,
• to learn the purpose of the processing of your personal data and whether these personal data are used in compliance with the purpose,
• to know the third parties to whom your 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 your personal data under the conditions referred to under the Law and relevant legislation,
• to request reporting of your requests for the erasure and/or destruction to third parties to whom his/her personal data have been transferred,
• to object to the occurrence of a result against you by analysing the data processed solely through automated systems,
• to claim compensation for the damage arising from the unlawful processing of your personal data.
• You can convey your requests to Tür-Mak, through the address on turmak.com, along with documents having wet-ink signature that enable the identification by hand, or by registered letter.

9. DESTRUCTION OF PERSONAL DATA :

Personal data belonging to our employees will be destroyed after 10 years following the termination of employment contract.

Personal data which belong to suppliers, customers, business partners and which are processed due to reasons arising from tax legislation will be destroyed after 5 years.

Personal data belonging to persons with whom we are in contractual relation will be destroyed after 10 years, which is prescribes as general time-bar.

Camera records recorded for security will be destroyed after 7 days.

10. DATA SECURITY :

To ensure that personal data are processed lawfully and in compliance with processing purposes, and to prevent of acquisition of such data by non-authorized persons, Tür-Mak signs commitment letter on behalf of employments, business partners, customers, suppliers when necessary, has encryption systems in all computers, employs and benefits from penetration test, intrusion detection and prevention systems, log entries, up-to-date antivirus systems. Considering each concrete case, all necessary technical and organizational measures are duly taken.

11. ENFORCEMENT OF THE POLICY :

This Privacy and Personal Data Protection Policy drawn up by Tür-Mak came into force on 07/02/2022, is published on www.turmak.com, and is made accessible for concerned persons at the request by owners of personal data.

Contact Information :

Tür-Mak Makine Sanayii Ve Ticaret Anonim Şirketi

ADDRESS: Yesilce Mahallesi Celik Caddesi no 63 – Kagithane 34418 Istanbul, Turkey

PHONE: +90 212 2815104

CENTRAL REGISTRATION SYSTEM (MERSIS) NO: 0881003293200017

WEB ADDRESS: www.turmak.com

E-MAIL: turmak@turmak.com