Purpose
This Confidentiality Policy clarifies EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş.’ personal data collection methods and legal reasons of collection of the same, the personal data of which person groups are processed, under which category personal data are processed in relation with such person groups and sample data types, in which business procedure and for what purposes such personal data are used, technical and administrative taken for the purpose of ensuring safety of personal data, to whom and for what purposes the personal data may be transferred, the period of keeping personal data, what the rights of relevant persons on their personal data are and how relevant persons may use such rights and personal data sharing with official authorities
This Policy is drafted for Company Shareholders, Company Business Partners, Company Officials, Nominee Employees, Company Clients, Potential Clients and Third Parties provided that such person is a real person, and shall be applied in respect of mentioned persons. The Company informs Personal Data Owners regarding the Law by publishing this Policy on its web site. This Policy being drafted by our Company is drafted in compliance with the 6698 No Law on Protection of Personal Data (“LPPD”).
This Policy shall apply in respect of aforementioned persons provided that our Company processes such relevant persons’ Personal Data completely or partially automated or no automated ways while it should be a part of any data registration system. This Policy shall not apply if the data is not within the scope of “Personal Data” as defined below or the Personal Data Processing activity is not performed via ways set forth above.
The data being obtained from you based on your consent or other circumstances of legal compliancy being provided under the Law shall be used to increase the quality of services being offered and to improve our quality policy. Again, some data we hold are removed from being personal and anonymised. Such data are the ones being used for statistical purposes and not subject to the implementation of Law and our Policy.
Our Company is entitled to amend our Policy and Directive On Personal Data provided that such amendment shall be in compliance with the Law and to better protect personal data.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. processes personal data in compliance with the procedures and principles provided under LPPD and other relevant codes. In this context, we comply with the principles below while processing personal data.
- Being in compliance with the law and rules of honesty: EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. questions the source of data it has collected or coming from other companies, and pays attention for them to be obtained in compliance with the law and within the framework of rules of honesty.
- Being accurate and when necessary updated: EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. pays attention to the facts that all data held by the Company to be accurate, not to contain inaccurate information, and to update the same if they are submitted to the Company in case of any changes in the data.
- Being processed for certain, express and legit purposes: EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. processes data in a limited manner only for the purposes it has obtained the consent of persons while offering services. It does not process, use or have used the data out of business purposes.
- Being connected, limited and balanced with the purpose of processing: EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. uses the data only limited with the purpose they are processed and in a balanced manner as the service so requires.
- Being kept for the period provided under relevant legislation or as required for the purpose of processing: EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş.keeps the data from agreements as long as the period provided under the Law in respect of disputes and required by commercial code and tax law. It deletes the data or anonymises when such purposes disappear. It deletes or destroys such data in accordance with the Directive On Deletion of Personal Data.
- Maximum Saving Principle/Principle of Tightness
In accordance with the principle called maximum saving principle or principle of tightness, the data reaching to EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. shall be processed only as necessary. Therefore, we determine which data we shall collect, in accordance with the purpose. Other data reaching to our Company are transferred to information systems of the company in the same manner. Excess data are not recorded in the system, are deleted or anonymised. Such data may be used for statistical purposes.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. keeps the personal data it has collected during the period provided under the Article 7 and 17 of LPPD and stipulated by relevant codes under the Article 138 of Turkish Criminal Code and/or the purpose of processing required. It shall delete, destroy or anonymise such data under the provisions of Regulation on Deletion, Destruction or Anonymisation of Personal Data in case such periods expire.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. clarifies the methods regarding deletion, destruction and anonymisation and the technical and administrative measures it has taken within the scope of Policy on Keeping and Destruction of Personal Data it has drafted under the Regulation on Deletion, Destruction or Anonymisation of Personal Data.
The data being kept by EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. are processed, in principle, as declared by it upon declaration of relevant persons. Since EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. is not obligated to search the accuracy of data declared by its clients or persons contacting with EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş., this search is not performed based on law and our working principles. The declared data are accepted as accurate. The principle of accuracy and actuality of personal data has also been embraced by EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. Our Company updates personal data from official documents reaching to our Company or the personal data processed upon request by relevant person and takes measures necessary.
Personal data are confidential and EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. observes this confidentiality. Only authorised persons at the company may access to personal data. All necessary technical and administrative measures required to protect personal data being collected by EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. and prevent access by unauthorised persons and prevent the data owner to suffer damages are being taken. Within this framework, the compliancy of software with the standards, selection of third parties with diligence and compliancy with Confidentiality Policy at the company are ensured. The companies with which we legally share personal data are asked to protect the data.
Data processing shall be performed towards the purposes set forth under EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. Clarification on Processing of Personal Data.
If a contractual affair is established with the clients and possible clients then, the personal data being collected may be used without client’s consent. However, personal data are used towards contractual purposes. The data are used in balance with the better performance of the agreement and requirements of the service, and updated when necessary by contacting with the clients.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. embraces legal act while sharing data both with its business partners and solution partners. Data are shared with business and solution partners under data confidentiality warranty only as much as the service requires, and such parties are certainly asked to take measures to ensure data safety.
Personal data are processed for publicity or market and public opinion poll only when the purpose of collection of such data is in compliance with such purposes. The data owner is informed about the fact that data shall only be used for publicity purposes. The data owners may avoid giving their data, which has been informed that they would be used for publicity purposes or their consent on their processing. It is required to obtain express consent of the data owner for the data being processed for publicity purposes even though the data owner is an employee of EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. The Data Responsible may obtain express consent of the data owner via electronic consent, mail, electronic mail, SMS or by phone. Using personal data for publicity purposes without express consent of the data owner is prevented.
Personal data may be processed without obtaining consent when processing is expressly stated in relevant legislation or for the purpose of performing a legal liability stipulated under the legislation. The type and scope of data transactions should be necessary for the data processing activity allowed legally and in compliance with relevant legal provisions.
Personal data may be processed towards the service offered and legit purposes of the company. However, data may not be used for illegal services in any manner whatsoever.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. takes all sufficient measures being determined by the Board for the processing of private personal data. Private data being processed at our Company are processed in accordance with the “Policy on the Protection and Processing of Private Personal Data”.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. acts in compliance with the Law regarding data being processed through automated systems. The information being obtained from such data without express consent of the persons may be used against such persons. However, EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. may take decisions about persons regarding whom transaction shall be made by using the data in its system.
Relevant persons are informed regarding confidentiality and if necessary cookies in case personal data are collected, processed and used at web sites and other systems or applications of EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş.
The persons are informed regarding our implementations on web sites. Personal data shall be processed in compliance with the law.
The personal data of our employees may be processed without obtaining consent as necessary in respect of work relations and health insurance. However, EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. guarantees the confidentiality and safety of employee data.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. may process employee personal data without obtaining further consent in case processing is expressly set forth under relevant legislation or for the purpose of performing a legal liability being determined by the legislation. This matter is limited with the liabilities arisen from the law.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. may process personal data for transactions, which are in favour of company employees such as private health insurance. EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. may also process employee data in respect of disputes arisen from employment affairs.
In accordance with the Law, the race, ethnical origin, political view, philosophical belief, religion, and sect or other beliefs, clothing, membership to association, foundation or union, sexual life, criminal conviction and security measures related data and biometric and genetic data of a person are private personal data.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. also takes sufficient measures being determined by the Board apart from relevant person’s consent in respect of processing private personal data. Private personal data may be processed without person’s consent only in relation and as limited with cases permitted under the Law.
The employee data being processed in relation with automated systems may be used for promotions and performance assessments at the company. Our employees are entitled to object the result and make this objection in compliance with the internal procedures. The objections of the employees are evaluated in the company.
The computer, phone, e-mail and other applications being allocated to employees at the company have been allocated only for business purposes. The employee may not use any of these allocated means for private purposes and communication. The Company may check and supervise all data on such means. The employee warrants that it shall not keep any data or information apart from business data and information on the computer, phone or other means allocated from the date of employment.
Personal data may be shared by EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. with shareholders, group company and also with business and solution partners for the rendering of services.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. may transfer personal data to the suppliers of EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. as limited to ensure necessary services outsourced from suppliers and to ensure such services are provided for the Company to perform its business activities.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. is authorised to transfer the personal data within the limits being determined by the Board in compliance with the other conditions provided under the Law and depending on the consent of the person, in the country and abroad.
The rights of the Data Owner on the personal rights being processed by EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. under the Article 11 of LPPD are as follows. In order to facilitate enjoying such rights, an application form has also been drafted by EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. and submitted on the web site.
The persons whose personal data are processed are by applying individually to our relevant officer being announced on the web site by EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. entitled to:
- learn whether your personal data processed,
- demand information if your personal data have been processed,
- learn the purpose of processing personal data and whether such personal data have been used in compliance with the purpose,
- know third parties to whom your personal data have been transferred in the country or abroad,
- request correction if personal data have been processed deficiently or defectively, and the transaction made to be informed to third parties to whom your personal data have been transferred,
- request deletion or destruction of your personal data, and the transaction made to be informed to third parties to whom your personal data have been transferred, under the conditions provided in Article 7, if reasons requiring personal data to be processed are revoked despite the fact that the personal data have been processed in compliance with the provisions of LPPD and other relevant codes,
- object any result arisen against the owner after the analysis made exclusively by automated systems on processed data,
- claim remedy of damages if you suffer loss due to illegal processing of your personal data.
On the other hand, persons hold no right regarding the data anonymised in the Company. EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. may share personal data under an employment and agreement relation with relevant authorities and agencies, for the purpose of a judicial or governmental authority to enjoy its legal rights.
Personal data owners may submit their requests to our Company regarding their aforementioned rights by filling the application form you may find on the official web site of the Company as complete and by hand-signing the same through reply paid registered letter and along with identity card copy (only the copy of front page of the identity card). Your applications shall be responded as soon as possible, or within 30 days from the date of its arrival depending on the content of your application. You are required to make your applications via reply paid registered letter. Also, only the part related with yourself of your application shall be responded; and an application made for your spouse, relative or friend shall not be accepted. EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. may request information and documents from applicants.
The data of both employees and other persons kept by EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. are confidential. No individual may use, copy, duplicate, transfer such data for any purpose and use the same for purposes other than business purposes, without compliancy with an agreement or the law.
All technical and administrative measures required to protect personal data being collected by EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. and prevent unauthorised access and our clients and nominee clients to suffer losses. In this context, it is ensured that software to be in compliance with the standards, to select third parties in diligence and complying with Confidentiality Policy at the company. Safety measures are regularly renewed and improved.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. performs / has had performed necessary internal and external audits on the protection of personal data.
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş. acts with the awareness that it has to refer to LPPD Board without delay and within 72 hours from the date when the occurrence of any violation regarding personal data has been notified; minimises the loss of relevant person and gives notice to the Personal Data Protection Board when personal data are acquired by unauthorised persons.
With due respect,
EN GÜMRÜK MÜŞAVİRLİĞİ LOJİSTİK DEPOLAMA İTHALAT VE İHRACAT TİCARET A.Ş.