GDPR
PDPL Clarification Text
The Clarification Text on the Processing of Personal Data of FANSA GROUP
KAĞIT VE TEKSTİL SAN.TİC.LİMİTED ŞİRKETİ
This Clarification Text has been prepared by FANSA GROUP KAĞIT VE
TEKSTİL SAN. TİC.LİMİTED ŞİRKETİ (“the Company“)
for the purpose of clarifying the Company’s customers regarding the processing
of their personal data by the Company within the scope of the Personal Data
Protection Law No. 6698 (“the PDPL“).
Detailed information regarding the processing of your personal data within
the scope of this Clarification Text can be found at [www.proftr.com.tr] Personal
Data Protection and Processing Policy of FANSA GROUP KAĞIT VE TEKSTİL SAN.
TİC.LİMİTED ŞİRKETİ.
- a) The Method and
Legal Reason for Collecting Personal Data
Your personal data is collected electronically or physically. Your personal
data collected for the legal reasons specified in this Clarification Text can be
processed in line with the following purposes and within the scope of the
personal data processing conditions and purposes specified in Articles 5 and 6
of PDPL.
- b) Purposes for
Processing Personal Data
Within the parameters of the personal data
processing conditions specified in Articles 5 and 6 of the Law, your personal data is processed in order to plan and carry out the activities necessary
for the recommendation and promotion of the products and services offered by the
Company to the relevant persons by customizing them to their likes, usage
habits, and needs; to perform the tasks required by
the business units in order for the relevant persons to profit from the
products and services provided by the Company and to carry out the
necessary business procedures; to conduct the
necessary research by the relevant business units in order to fulfill the
Company’s commercial activities and carry out related business processes; to plan and carry out the business and/or marketing
strategies of the Company and to ensure the Company’s legal,
technical, and commercial-occupational safety as well as the safety of the
relevant persons in its business relationships.
- c) To Whom and
for What Purposes the Processed Personal Data can be Transferred
Within the parameters of the personal data processing conditions specified
in Articles 8 and 9 of the Law, your personal data may be shared with the
Company’s business partners and suppliers, legally authorized institutions
and organizations and legally authorized private law legal entities in order to
plan and carry out the activities necessary for the recommendation and
promotion of the products and services offered by the Company to the
relevant persons by customizing them to their likes, usage habits, and needs;
to perform the tasks required by the business units in order for the relevant
persons to profit from the products and services provided by the Company
and to carry out the necessary business procedures; to conduct the necessary
research by the relevant business units in order to fulfill the Company’s
commercial activities and carry out related business processes; to plan and
carry out the business and/or marketing strategies of the Company and
to ensure the Company’s legal, technical, and
commercial-occupational safety as well as the safety of the relevant persons in
its business relationships.
- d) The Rights of
Data Owners and Exercise of These Rights
As personal data owners, if you submit your requests regarding your rights
specified below to the Company through the methods specified under the
heading of Exercise of The Rights by Data Owners, your requests will be
evaluated and concluded by our Company as soon as possible and in any case
within 30 (thirty) days.
In accordance with Article 11 of the Law, you have the following rights as
a personal data owner:
- To learn whether your
personal data is processed or not,
- If your personal data has been
processed, to request information about it,
- To learn the purpose of
processing your personal data and whether they are used in accordance with
their purpose,
- To know the third parties to
whom your personal data is transferred at home or abroad,
- In case your personal data
is processed incompletely or incorrectly, to request their correction and
to request that the transaction carried out within this scope be notified
to the third parties to whom the personal data are transferred,
- To request the deletion or
destruction of your personal data if the circumstances no longer warrant
its processing even though it is done in accordance with the Law and other
applicable laws, and to request that the third parties to whom the
personal data are transferred be informed of the transaction,
- To object to the occurrence
of a result against the person themselves by analyzing the processed data
exclusively by means of automated systems,
- To request the compensation
of the damage if your personal data is damaged due to unlawful processing.
Article 28, paragraph 2 of the Law lists the situations in which data
owners do not have the right to request and in this context, if;
- The processing of personal
data is necessary for the prevention of crime or for the investigation of
crime,
- Processing of personal data
made public by the person concerned,
- The processing of personal
data is required for the performance of supervisory or regulatory duties,
for disciplinary investigations, or for criminal prosecution by authorized
public institutions and organizations, as well as professional
organizations that are public institutions based on the authority granted
by the law,
- The processing of personal
data is necessary for the protection of the economic and financial
interests of the Government in relation to budget, tax and financial
matters,
In such cases, the rights specified above for the
data shall not be exercised.
According to Article 28, paragraph 1 of the Law, the
requests of the data owners will not be processed in relation to these data
since they fall outside the purview of the Law in the following circumstances:
- Processing of personal data
by real persons within the scope of activities related to themselves or
other members of their family living in the same residence, provided that
they are not given to third parties and that the obligations regarding
data security are complied with.
- Processing of personal data
for purposes such as research, planning and statistics by anonymizing them
with official statistics.
- Processing of personal data
for artistic, historical, literary or scientific purposes or within the
scope of freedom of expression, provided that it does not violate national
defense, national security, public security, public order, economic
security, privacy of private life or personal rights or does not
constitute a crime.
- Processing of personal data
within the scope of preventive, protective and intelligence activities
carried out by public institutions and organizations mandated and authorized
by law in order to ensure national defense, national security, public
security, public order or economic security.
- Processing of personal data
by judicial or enforcement authorities in connection with investigation,
prosecution, trial or execution proceedings.
Exercise of Rights by Data Owners
To exercise the aforementioned rights, data owners can use the “Form for Applications to be Made
by the Personal Data Owner to the Data Controller” found at the [www.proftr.com.tr] link.
Applications will be made by one of the following methods, together with
documents that will determine the identity of the data owner concerned:
- Filling out the form and
sending the wet signed copy to [İnönü Mah. 156 Sokak No:10 Torbalı
İzmir.-Turkiye] by hand, notary or registered letter with return receipt,
- Signing the form with a
secure electronic signature issued within the scope of the Electronic
Signature Law No. 5070 and sending it by electronic mail to
[fansagroup@hs06].kep.tr,
- Following a method
prescribed by the Personal Data Protection Board.
Within a maximum of thirty (30) days as specified
in the Law, the Company responds to data owners who wish to exercise
these rights within the restrictions set forth in the Law. Third parties cannot
submit applications on behalf of personal data owners without a special power
of attorney that has been signed by the data owner on behalf of the applicant
and notarized.
Applications from data owners are typically
processed without charge, though fees in accordance with the Personal Data
Protection Board’s rate[1] may be assessed.
The Company may request information from the applicant in order
to confirm whether or not they are the owner of the personal data. It may ask
the owner of the personal data about the application in order to clarify the
issues mentioned in the application.
[1] In accordance with the “Notification on
the Procedures and Principles of Application to the Data Controller”
published in the Official Gazette dated 10.03.2018 and numbered 30356, there is
no fee for the first ten pages of an answer to the data owners’ application if
it is submitted in writing. For every additional page over ten, a transaction
fee of 1 Turkish Lira may be applied. The fee that may be demanded by the
Authority cannot be greater than the cost of the recording medium if the
response to the application is provided on a recording medium, such as a CD or
flash memory.