Clarification Text

CLARIFICATION TEXT FOR PROTECTION AND PROCESSING OF PERSONAL DATA

As CCN Investment Holding and Group companies, the confidentiality and security of your personal data are given importance and the principles of securing fundamental rights and freedoms guaranteed by the Constitution, especially the confidentially of private life, are observed with utmost precision.

According to the 6698 numbered Law on Protection of Personal Data, all kinds of personal data you submit (name, surname, TR No, address, place of birth, date of birth, etc.) and any other special quality data (health information, biometric and genetic information, costume, association, foundation, union membership, criminal conviction, data on security measures all kinds of religious, ethnic etc. data), all kinds of information and document, are processed, recorded, retained by CCN Investment Holding and Group countries with the title of Data Responsible in line with the provisions of relevant legislation, they may be updated to continue the services, stored, may be transferred to third parties, may be shared and anonymized.

CCN Investment Holding and Group Companies take all necessary administrative and technical measures to protect personal data processed in accordance with the relevant laws and regulations. According to 6698 numbered Law on Protection of Personal Data (“Law”), data are processed in line with principle of honesty, the accuracy of the data is ensured and updated when necessary. Attention is paid to ensure that the data is processed for specific, clear and legitimate purposes, linked to the purpose for which they are processed, limited and metered processing, the time stipulated in the relevant legislation, or the time required for the purpose for which they are processed.

In case the processed data are personal data of a special nature as defined in the Law, personal data other than health and sexual life may be processed without the explicit consent of the person concerned, in cases provided for by law. Personal data related to health and sexual life, however, for the purpose of protecting public health, preventive medicine, conducting medical diagnosis, treatment and care services, planning and managing health services and financing, without seeking explicit consent of the relevant person or authorized institutions and organizations.

A. Purposes and Legal Reasons for Processing Personal Data

Your personal data are processed within the terms and purposes specified in Articles 5 and 6 of the Law and all information and documents are processed in line with Law and regulations with the purpose of carrying out, maintaining, executing, developing our activities, carrying out promotion, campaign and similar activities for services and activities, invitation, notification of new applications, fulfilling the requirements of contracts arranged or will be arranged, making surveys for planning, statistics, satisfaction, in the e-mail environment, e-mails, e-bulletin memberships, social media posts, printed forms filled in events organized, during the face-to-face interview with the candidates or in case they send a written application form, digital application form electronically or send their CVs by e-mail, cargo, and similar methods, or personal data collected through recruitment processes due to controls and investigations that confirm the information transmitted by the candidate, such as consulting firms or by phone and special personal data collected according to the nature of the job are again processed for providing you reliable and uninterrupted service with the purposes of maintenance of the legal and commercial confidentiality of people in business relationships, determining and implementing legal and financial affairs and similar commercial and business strategies, human resources, execution of accounting policies, ensuring physical security and supervision, compliance with domestic and international legislation, information transfer required by public institutions or other authorities, compliance with retention, reporting obligations.

B. Retention Period for Personal Data

CCN Investment Holding and the Group Companies retain personal data only for the time required by the relevant legislation or for the purpose for which they are processed. Within this framework, it determines first whether a period is foreseen for the retention of personal data in the relevant legislation, if any, it acts in accordance with this period, and if it has not been determined, it retains personal data for the time required for the purpose for which they were processed.

Personal data is deleted, terminated or anonymized if the period expires or the reasons that require the processing disappear.

C. Collecting Method for Personal Data

Your Personal Data may be collected verbally, in writing or electronically, through automated or non-automated methods, through our website, social media channels, business partners and / or other channels that we receive complementary services for, our activities, contracted organizations and other similar channels.

D. Transferring of Personal Data

Your personal data may be transferred within the framework of the activities of CCN Investment Holding and Group Companies, for fulfilling the purposes, strategy determination and implementation, ensuring the execution of human resources policies to company officers, shareholders, employees, business partners, service providers or third parties, legal, financial and tax consultants, auditors, consultants, organizations or individuals, authorities such as SSI, all public institutions and organizations that are legally authorized, such as ministries and jurisdictions and/or to abroad in the framework of the conditions and purposes listed in Articles 8 and 9 of the Law. When transferred abroad personal data to be transferred is required to have adequate protection in foreign countries, in case of absence of adequate protection, data responsible in Turkey and relevant foreign country shall make a written commitment about protection and Personal Data Protection Authority shall provide permission.

E. Rights of Personal Data Owner relevant to Article 11 of Law

As personal data owner, you have the right to demand below mentioned issues from CCN Investment Holding and Group Companies:

a) to learn whether his personal data are processed or not,
b) to request information if his personal data are processed,
c) to learn the purpose of his data processing and whether this data is used for intended purposes,
d) to know the third parties to whom his personal data is transferred at home or abroad,
e) to request the rectification of the incomplete or inaccurate data, if any,
f) to request the erasure or destruction of his personal data under the conditions laid down in Article 7,
g) to request notification of the operations carried out in compliance with sub-paragraphs (d) and (e) to third parties to whom his personal data has been transferred,
h) to object to the processing, exclusively by automatic means, of his personal data, which leads to an unfavorable consequence for the data subject,
i) to request compensation for the damage arising from the unlawful processing of his personal data.

It is important for the correctness and up-to-date retention of the information / data you share, the use of the rights held on the data in terms of the Law and other relevant legislation, and the responsibility arising from giving false information is entirely yours.

It is important that the information / data you share is correct and transferred correctly, which is necessary for you to exercise your rights and you are responsible for giving false or incorrect information. We reserve the right to request your expenses for the fulfillment of your requests in accordance with the tariff regulated in the Article 13 of the Law titled Application to the Data Controller.

F. Cases According to Law, Personal Data Can Be Processed Without the Explicit Consent of The Relevant Person

a) it is clearly provided for by the laws.
b) it is mandatory for the protection of life or physical integrity of the person or of any other person who is bodily incapable of giving his consent or whose consent is not deemed legally valid.
c) processing of personal data belonging to the parties of a contract, is necessary provided that it is directly related to the conclusion or fulfilment of that contract.
d) it is mandatory for the controller to be able to perform his legal obligations.
e) the data concerned is made available to the public by the data subject himself.
f) data processing is mandatory for the establishment, exercise or protection of any right.
g) it is mandatory for the legitimate interests of the controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.

G. Principles Established in the Law on Protection and Processing of Personal Data

CCN Investment Holding and Group Companies act in accordance with the Constitution, the general principles contained in the Law and other relevant legislations regarding the protection and processing of personal data; as well as respects the following principles with significant care and attention:

a. Lawfulness and conformity with rules of bona fides.
b. Accuracy and being up to date, where necessary.
c. Being processed for specific, explicit and legitimate purposes.
d. Being relevant with, limited to and proportionate to the purposes for which they are processed.
e. Being retained for the period of time stipulated by relevant legislation or the purpose for which they are processed.

H. Methods of Exercising Rights of Personal Data Owners / Ways to Apply

In case the relevant person requests information on the matters specified in Article E above, the application will be answered within thirty days at the latest after the written application is made to our institution as Data Controller.

If the transaction requires additional cost, we reserve the right to charge the fees set by the Personal Data Protection Authority.