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Clarification Text

CLARIFICATION TEXT

Polmot Motor Mak. San. ve Tic. A.Ş. ("Polmot Motor" and "Company"), we show maximum sensitivity regarding the security of personal data. Polmot Motor takes the highest possible security measures within the framework of the relevant legislation in order to ensure that your personal data is collected, stored and shared in accordance with the law and to protect your privacy. With the awareness of this responsibility, as a data controller within the scope of 6698 s.k., we process your personal data as explained below and within the framework of the legislation.

1) Identity of the Data Controller and Representative

Pursuant to Article 10 of the Personal Data Protection Law No. 6698 ("KVKK"), your personal data may be transferred to Polmot Motor Mak. San. ve Tic. A.Ş. in the capacity of data controller is explained below.

 


2) Purpose of Processing Personal Data

Your personal data collected may be processed by Polmot Motor for the following purposes in accordance with the basic principles stipulated by the legislation:

Carrying out the necessary studies by the business units of our Company in order to fulfil the commercial activities carried out by Polmot Motor in accordance with the legislation and Company policies and carrying out activities in this direction;
Determining the human resources policy of Polmot Motor and carrying out and executing its activities;
Determining, planning and implementing Polmot Motor's short, medium and long term commercial policies;
Ensuring the commercial, technical and legal security of the relevant persons with whom Polmot Motor has a business relationship and liaising with these real/legal persons;
Protection of Polmot Motor's commercial reputation and the trust it creates;
Compliance with the information storage, reporting and information obligations stipulated by official institutions within the scope of the relevant legislation, and fulfilment of the legal obligations we are subject to regarding the utilisation of these services;
Managing financial operations, communication, market research and social responsibility activities, purchasing operations (request, proposal, evaluation, order, budgeting), internal system and application management operations, legal operations carried out in order to determine and implement the commercial and business strategies of our company;
Analysing, evaluating and responding to requests from official authorities or relevant persons;
Ensuring the security and supervision of the physical spaces of the company with camera recording and other systems;
Fulfilment of the obligation of proof as evidence in legal disputes that may arise in the future;
It is processed within the scope of the conditions and purposes of processing personal data specified in Articles 5 and 6 of the KVKK.
In order to process the necessary work and information within the scope of our activities, your data is classified within the scope of automated decision-making. This is mandatory for the reports to be created and the documents to be submitted to the relevant organisations.

Processing of your personal data is a legal and contractual obligation, and if your data is not provided, it will become impossible for real/legal persons who have a business relationship with the company to carry out commercial activities, to fulfil the notifications and obligations required under the legislation, to ensure the execution of human resources activities, and to ensure legal-technical-commercial security.

3) To whom and for what purpose the data can be transferred/Transfer abroad

Personal data are transferred by Polmot Motor to the following persons within the scope of Article 8 and Article 9 of the KVKK, provided that it is limited to the purposes listed above:

Polmot Motor's business partners and affiliates,
Persons and institutions permitted by the provisions of the Turkish Commercial Code, Turkish Code of Obligations, Labour Law and other relevant laws and regulations,
To legally authorised institutions and organisations, administrative and legal authorities and institutions, organisations, persons and companies ordered by special legislation;
To real and legal persons from whom we receive products and services and with whom we cooperate, In case of transfer, it will be transferred by asking whether the domestic institution and / or enterprise to be transferred also has KVKK compliance and data security.

 


According to Article 9 of the Law, the transfer of your personal data abroad is subject to the explicit consent of the data subject or

In the transfer of personal data to countries with adequate protection (countries deemed safe by the Board), the existence of the conditions specified in the Law (the conditions specified in paragraph 2 of Article 5 and paragraph 3 of Article 6 of the Law),
In the transfer of personal data to countries where there is no adequate protection, in the presence of the conditions specified in the Law (the conditions specified in paragraph 2 of Article 5 and paragraph 3 of Article 6 of the Law), adequate protection may be undertaken in writing and the permission of the Board. The Personal Data Protection Board will announce the countries deemed safe.

 

4) Management and Legal Reason for the Given Gathering of Persons

Your personal data are collected by our Company through different channels (verbal, written, electronic media) in order to carry out our activities, based on legal reasons such as ensuring compliance with the legislation and Company policies, fulfilment of contracts, expressly stipulated by the law, legitimate interest of the company. Your personal data may also be processed and transferred for the purposes specified in this Clarification Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK in accordance with the basic principles stipulated by the KVKK.

5) Duration of Retention of Personal Data

Your personal data are retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed. The following criteria are taken into consideration when determining the maximum period:

The period accepted by the general custom in the sector in which the data controller operates within the scope of the purpose of processing the relevant data category,
The period of time during which the legal relationship established with the data subject and which makes it necessary to process the personal data in the relevant data category will continue,
The period during which the legitimate interest to be obtained by the data controller depending on the purpose of processing the relevant data category will be valid in accordance with the law and good faith,
The period during which the risks, costs and responsibilities of storing the relevant data category depending on the purpose of processing will continue legally,
Whether the maximum period to be determined is sufficient to keep the relevant data category accurate and, where necessary, up to date,
The period for which the data controller is obliged to store the personal data in the relevant data category in accordance with its legal obligation,

The limitation period determined by the data controller for the assertion of a right related to the personal data in the relevant data category.

6) Rights of the Personal Data Owner listed in Article 11 of the Law No. 6698

As personal data owners, you can submit your requests regarding your rights to Polmot Motor Mak. San. ve Tic. A.Ş. Personal Data Protection and Processing Policy, which has been shared with the public at the internet address of _COPY , our company will finalise the request as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board will be charged by Polmot Motor. In this context, personal data owners;

To learn whether personal data is processed or not,
Request information if personal data has been processed,
To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
To know the third parties to whom personal data are transferred domestically or abroad,
To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
Although it has been processed in accordance with the provisions of the KVKK and other relevant laws, to request the deletion or destruction of personal data in the event that the reasons requiring its processing disappear and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
To object to the emergence of a result to the detriment of the person himself/herself by analysing the processed data exclusively through automated systems,
In case of damage due to unlawful processing of personal data, they have the right to demand compensation for the damage.

In cases where the application is rejected, the response is found insufficient or the application is not responded in due time; the data subject may file a complaint to the Personal Data Protection Board within thirty days from the date of learning the response of the data controller and in any case within sixty days from the date of application. Pursuant to Article 13 of the Law, a complaint cannot be filed without exhausting the remedy.

Within the scope of international legislation, apart from the above-mentioned rights of the person concerned; there is also the right to request the restriction of the processing of personal data and to withdraw consent to the processing or transfer of personal data.

You can make your applications for your rights listed above by using the Application Form to the Data Controller on the website www.polmot.com.tr