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ION TEKSTIL LTD.
PERSONAL DATA PROTECTION AND PRIVACY POLICY

OBJECTIVE

In this Policy, the principles of processing personal data of data owners by ION TEKSTİL LTD: (“ION Tekstil” or “the Company”) are included in accordance with the order of regulation in the Personal Data Protection Law No. 6698 (“KVKK” or ‘‘the Law’’) and these explanations cover ION Tekstil employees, our active and potential customers, visitors and any other natural persons in relation with the Company. This Policy introduces the conditions and the main principles adopted by The Company for the processing of personal data. In this regard, the Policy covers all the data processing activities of ION Tekstil, all the personal data, and all the data subjects whose data ION Tekstil processes, within the scope of the Law.

The Company reserves the right to amend this Policy in line with the legal regulations. In the event that changes in Policy are substantial, data owners will be informed through various channels.

SCOPE

The main purpose of this Policy is to inform our customers, potential customers, employee candidates, employees of the entities we are in a relation for business cooperation relation with and other persons whose personal data are being processed by our Company regarding subjects such as ION Tekstil’s data processing activities, the systems we adopt for data processing activities, measures we take in that regard, rights of data subjects and the methods to use their rights.

The scope of this Policy is; all personal data of our customers, potential customers, employee candidates, employees of the entities we are in a relation for business cooperation and other persons whose personal data are being processed by our Company.

The rules about the protection of personal data relate to real people. For this reason, this Policy does not apply to the data of legal persons.

DEFINITIONS

Personal data: All the information relating to an identified or identifiable natural person.

Personal Data of Special Nature: A person’s data about race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, appearance, membership of association, foundation or trade union, health, sexual life, criminal conviction and security measures as well as biometric and genetic data.

Data Owner/Concerned Person: A natural person whose personal data is processed.

Processing Of Personal Data: Any operation performed upon personal data such as collection, recording, storage, retention, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification or preventing the use thereof, fully or partially through automatic means or provided that the process is a part of any data registry system, through non-automatic means.

Express Consent : A consent on a certain subject, based on being informed and expressed by free will.

Data Processor: A natural person or legal entity who processes personal data by virtue of the data manager on its behalf.

Data Manager: A natural person or legal entity who determines the purposes and means of processing personal data and is responsible for installing and managing a data recording system.

Personal Data Deletion: Deletion of personal data; making personal data inaccessible and non- reusable in any way for Concerned Users.

Personal Data Destruction: Process of making personal data inaccessible, non-restorable and non- reusable in any way by anybody.

Anonymizing: Rendering personal data impossible to link with an identified or identifiable natural person, even through matching them with other data.

Application Form: Application form to be used by data owners when making their applications regarding their rights in article 11 of KVKK.

Employee candidate: A natural person who applies for a position in our Company by sending a CV or by other means.

Employees, Shareholders and Authorities of Cooperating Institutions: The parties or persons who has relationships with the company as employees, shareholders and cooperating institutions.

Supplier: Parties that offer products and services to our company.

Third Person: Natural persons who are not ION Tekstil employees and not covered by any of the data subject categories mentioned herein, including those individuals and institution employees with which The Company has business relations.

Visitor: A natural person who visits ION Tekstil’s buildings, facilities, premises and website.

PRINCIPLES FOR PROCESSING OF PERSONAL DATA

Our Company processes personal data pursuant to the rules and provisions determined by KVKK. Our Company complies with all the principles in every data processing activity.

Processing in Good Faith and in Accordance with the Law
Our Company complies with the good faith principle while processing personal data and in accordance with the principles set forth under legal regulations during personal data processing activities. In that regard, our Company processes personal data pursuant to the data protection legislations and to the rules determined therein and does not conduct any processing activities beyond the scope of the purposes declared to the data subjects.

Ensuring that Personal Data Are Accurate and Up-to-Date Where Necessary
Our Company takes necessary measures to ensure that processed personal data are accurate and up- to-date.

Processing for Specific, Explicit and Legitimate Purposes
The Company processes personal data for only express and absolutely determined legitimate purposes and performs no processing activities out of these purposes.

Relevant, Limited and Proportional to the Purposes for Which They Are Processed
Our Company processes data in accordance with the KVKK and the other relevant legislation, conveniently for fulfillment of the purposes determined according to data categories, in relation with achievement of the purpose and prudently and avoids processing of unneeded personal data.

Keeping for duration necessary for the purposes for which the data are processed or foreseen under the relevant legislation
Our Company shall keep personal data only for a duration stated under the applicable legislation or necessary for the purposes for which the data are processed. In this regard, if a duration is foreseen under the relevant legislation, personal data shall be maintained by our Company only for a period limited to such durations. If such duration is not determined by legislations or no other legal grounds are available for maintaining personal data, our Company shall keep the personal data for the duration necessary for the purposes for which they are processed.

ISSUES RELATED TO THE PROCESSING OF PERSONAL DATA

Our Company processes personal data pursuant to the rules and provisions determined by the KVKK. In this content our company process the personal data complied with the articles mentioned in below;

  1. Lawfulness and conformity with rules of bona fides.
  2. Accuracy and being up to date, where necessary.
  3. Being processed for specific, explicit and legitimate purposes.
  4. Being relevant with, limited to and proportionate to the purposes for which they are processed.
  5. Being retained for the period of time stipulated by relevant legislation or the purpose for which they are processed.

Our company informs data owners in accordance with Article 10 of KVKK. In cases where consent is required, our company requests the consent of the data owners and processes this personal data based on the principles specified in Article 4.

ISSUES RELATED TO THE PROCESSING OF PERSONAL DATA

Personal data shall be processed by ION Tekstil in compliance with one or more conditions set forth by the Law. With the exceptions listed in the law, ION Tekstil processes personal data only by receiving express consent of data owners.

In the event that the processed data is personal data of special nature, the conditions in article 10 of this Policy will be applied.

In case of existence of the following conditions listed in the law, personal data can be processed even without express consent of a data owner:

  • It is clearly provided for by the laws.
  • 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.
  • Processing of personal data belonging to the parties of a contract, is necessary provided that it is directly related to the conclusion or fulfillment of that contract.
  • It is mandatory for the controller to be able to perform his legal obligations.
  • The data concerned is made available to the public by the data subject him/herself.
  • Data processing is mandatory for the establishment, exercise or protection of any right.
  • 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.
PROCESSING AND PROTECTING PERSONAL DATA

Our Company takes necessary technical and administrative measures for ensuring the security of personal data within, preventing unlawful access to personal data and unlawful processing of personal data as regards to article 12 of the Law.

The measures taken by ION Tekstil for this are listed below:

  • ION Tekstil performs and causes to be performed necessary controls in order to ensure enforcement of the provisions of the Law in its own establishments and organizations.
  • ION Tekstil ensures compliance of data processing activities with the Law with internal policies and procedures.
  • Prevent unlawful access to personal data.
  • ION Tekstil is taking all necessary actions to inform persons who has authorization to access personal data in company.
VARIOUS CATEGORIES OF PROCESSED PERSONAL DATA

The personal datas which is collected by our company can change and vary according to legal obligations and relationship of parties with the company.

You can see personal data types in below;

  • Identity Information (Any information provided on the documents such as driver’s licence, identity document, residency, passport, advocate identity, marriage records which explicitly belongs to an identified or identifiable real person and processed wholly or partly by automatic means or by non-automatic means as a part of the data recording system.)
  • Contact Information (Information such as phone number, address and e-mail which explicitly belongs to an identified or identifiable real person and processed wholly or partly by automatic means or by non-automatic means as a part of the data recording system)
  • Location Data (Information locating the location of the vehicles and devices of the Company that are used by our employees or by the employees of institutions that we are in cooperation with; such information which explicitly belongs to an identified or identifiable real person and processed wholly or partly by automatic means or by non-automatic means as a part of the data recording system)
  • Information on Family Members and Relatives (Information relating to the family member and relatives of the data subject that are processed for the purposes of protecting the legal interests of the Company and the data subject, such information which explicitly belongs to an identified or identifiable real person and are a part of the data recording system.)
  • Physical Premises Security Information (Personal data relating to the records and documents obtained when entering to physical premises and during the stay in such premises; such information which explicitly belongs to an identified or identifiable real person and are a part of the data recording system.)
  • Financial Information ve Accounting Information (Personal data processed with respect to indicating all financial information, document and records generated based on the nature of the legal relation established between our company and the data subject; such information which explicitly belongs to an identified or identifiable real person and processed wholly or partly by automatic means or by non-automatic means as a part of the data recording system.)
  • Candidate Employee Information (Personal data processed relating to the candidates who have applied to our Company in order to become an employee or are deemed as candidate employee due to the requirements of the human resources of our company as per the customs of trade and principles of good faith; such information which explicitly belongs to an identified or identifiable real person and processed wholly or partly by automatic means or by nonautomatic means as a part of the data recording system. )
  • Legal Procedure and Compliance Information (Your personal data processed for the purposes of determining and following our legal receivables and rights and performance of our obligations and within the scope of compliance with the legal obligations of our Company and Company policies, such information which explicitly belongs to an identified or identifiable real person and processed wholly or partly by automatic means or by non- automatic means as a part of the data recording system. )
  • Personal Data Of Special Nature (Data stated under Article 6 of KVKK)
  • Security Information of Activity (Personal data processed for the purposes of ensuring administrative, legal and commercial security of both our employees and our Company during the conduct of commercial activates of our Company; such information which explicitly belongs to an identified or identifiable real person and are a part of the data recording system)

The above given personal data categories are not covering all types of Personal data.

PURPOSES FOR PROCESSING PERSONAL DATA

Your personal data acquired by ION Tekstil shall be processed within the scopes listed below:

  • Fulfillment of legal obligations,
  • Informing authorized person and/or institutions originating from the law,
  • Pursuance of legal affairs,
  • Pursuance of finance and/or accounting operations,
  • Creation and pursuance of the visitor records,
  • Ensuring the security of the company’s headquarters and factory,
  • HR operations,
  • Strategy, planning and business partners/supplier management,
  • Respond the information requests of regulatory and supervisory authorities or government officials,
  • To have outsourced service from 3rd parties,
  • Planning and execution of the business activities.
PERSONAL DATA OF SPECIAL NATURE

Within the scope of the law, special attention has been attributed to the personal data of special nature due to the risk of causing victimization or discrimination of individuals when processed illegally. Personal data relating to the race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, clothing, membership to associations, foundations or trade-unions, health, sexual life, convictions and security measures, and the biometric and genetic data are deemed to be personal data of special nature.

The technical and administrative measures taken by our company for the protection of personal data are also carefully applied for personal data of special nature.

In this content the health care service which is given in the company internally is collecting and processing employees health datas. This data is protected, locked and it is only accessible by doctor and nurse of the health-care service in company.

The collected data is uploaded the a health cloud system by on-site doctor. There is no access by third parties to this health cloud systems and there is no integration with another cloud systems within the company. The prescriptions written by on-site doctor is uploaded to Medula System and access by other departments is not possible.

DISCLOSURE OBLIGATION OF BARAN

Under article 10 of the KVKK, data owners must be informed prior to acquisition of personal data or at latest during acquisition thereof. Our company informs the personal data owners whilst collecting personal data in accordance with Article 10 of KVKK.

Our company inform the data owners about the following:

  • The identity of the controller and of his representative, if any,
  • The purpose of data processing;
  • To whom and for what purposes the processed data may be transferred,
  • The method and legal reason of collection of personal data,
  • Other rights referred to in Article 11.
RIGHTS OF DATA OWNERS

Data subjects are entitled to the following rights:

  • Learn whether or not data relating to him/her are being processed,
  • Request further information if his/her personal data have been processed,
  • Learn the purpose of the processing of personal data and whether or not data are being processed in compliance with such purpose,
  • Learn the third party recipients to whom the data are disclosed within the country or abroad,
  • Request rectification of the processed personal data which is incomplete or inaccurate and request such process to be notified to third persons to whom personal data is transferred,
  • Request erasure or destruction of data in the event that the data is no longer necessary in relation to the purpose for which the personal data was collected, despite being processed in line with the KVKK and other applicable laws and request such process to be notified to third persons to whom personal data is transferred,
  • Object to negative consequences about him/her that are concluded as a result of analysis of the processed personal data by solely automatic means,
  • Demand compensation for the damages he/she has suffered as a result of an unlawful processing operation.

Nevertheless, under article 28(2) of the KVKK, except the right of compensation, the above rights listed in article 11 of the KVKK shall not apply in the following cases:

  • If personal data processing is required to prevent commitment of crime or criminal investigation,
  • If personal data processed is made public by the data owner him/herself,
  • If personal data processing is required for performance of inspection or regulation tasks and disciplinary investigation or prosecution by assigned and authorized public agencies and authorities and professional organizations acting as a public agency by the virtue of the law,
  • If personal data processing is required for protection of the Government’s economical and financial interests with regard to budget, tax and financial matters.
METHODS FOR SEEKING RIGHTS OF DATA SUBJECT

Personal data owners will be able to submit their requests regarding their rights listed in Article 12 to our Company by the methods determined by the Personal Data Protection Board. They will be able to use the “Data Owner Application Form” available on our website.

Our Company may request additional information in order to verify the applicant is the subject of personal data or if the qualification of request cannot be understood from the content of application form.

It is required to submit a notarised power of attorney together with Form in case applications are made by a third person on behalf of the data owner and as for applications made on behalf of children under custody/guardianship, the documents certifying the custody/guardianship relation should be submitted together with Form. Requests made by unauthorized third parties will not be considered as official request.

In accordance with Article 13 of the KVKK, the Company acting in the capacity of data controller, shall respond to written access request of the data subject within the shortest time possible depending on the content of the request and within thirty (30) days at the latest. Your requests will be concluded by Our Company complimentarily and in case the responding process causes a cost, a fee may be charged as set out in the applicable legislation.

In order to the application to be accepted as an official request, concerned person must provide the following information. Otherwise, the application will not be considered as official request.

  • Name, surname and signature if the application is in writing,
  • Turkish Republic Identity Number for Turkish Citizens or Passport or Identity Number for Citizens of other Countries,
  • Notification Address,
  • E-mail address, phone and fax number for notification,
  • Subject Request.
TRANSFER OF PERSONAL DATA

Our Company may transfer personal data to third parties by taking necessary security measures. While doing so, ION Tekstil shall pay special attention to the rules set forth in Articles 8 and 9 of the KVKK and fulfill the additional requirements introduced by the Personal Data Protection Board.

Our Company may transfer personal data under the following conditions:

  • If expressly provided in the laws,
  • If it is required to process personal data of parties to a contract, provided that it is directly related to execution or performance of that contract,
  • If required for the data manager to fulfill its legal obligation,
  • If it is required to process data to establish, exercise or protect a right,
  • If it is required to process data for the legitimate interests of the data manager provided that the data owner’s fundamental rights and freedoms are not injured.
TO WHOM AND FOR WHICH PURPOSE THE PROCESSED PERSONAL DATA MAY BE TRANSFERRED

According to Articles 8 and 9 of Law, our Company may transfer personal data to the third parties. Scope of the third parties and data transfer purposes are stated here below.

Categories of Data Sharing Parties Data Transfer Purposes
Legally Authorised Private Body Sharing of personal data limited to the purpose of meeting the information request sent by private bodies within the scope of their legal authority.
Suppliers To ensure services which are obtained from suppliers or outsourced from suppliers and necessary for the Company to perform commercial activities are provided to our Company,
Shareholders To design and inspect strategies for our Company’s commercial activities in accordance with the provisions of the Law regarding our shareholders.
The State Institutions and Organizations For the purposes requested by the state institutions and organi- zations within the scope of the legal authority of the state insti- tutions and organizations.
PERSONAL DATA PROCESSING ACTIVITIES UNDERTAKEN IN BUILDINGS, FACILITY ENTRANCES AND INSIDE THE PREMISES

ION Tekstil is processing data to track visitor entrances and exits at the point of entry to ensure security. All visitors are informed about the processing of personal data within our company.

Our company can conduct camera surveillance activity within the Company buildings and facilities in order to provide security. With the scope of the camera monitoring activity, our Company aims to provide security for company, employees and other persons, prevention and detection of criminal behavior. Necessary technical and administrative measures are taken by our company to ensure the security of personal data obtained by camera surveillance.

STORAGE TIME OF PERSONAL DATA

Your personal data will be processed and stored only through the periods of time either required by applicable laws or to the extent needed for the purposes of processing. In case of expiry time is not determined by legislations for maintaining personal data, the duration periods for maintaining data shall be determined as per each purpose for data processing.

ERASURE, DESTRUCTION OR ANONYMISATION OF PER- SONAL DATA

In accordance with Article 138 of the Turkish Penal Code, Article 7 of the KVKK and the “Regulation on the Deletion, Destruction and Anonymization of Personal Data”, except where it is allowed or required to store personal data for prolonged periods, when the purpose for processing personal data no longer exists, ION Tekstil shall delete, destroy or anonymize the data upon request of the data owners or on periodic destruction dates.