PDP – SARGIN İnşaat ve Makine Sanayi Ticaret A.Ş.

SARGIN İNŞAAT VE MAKİNE SANAYİ TİCARET ANONİM ŞİRKETİ

UNDER THE LAW NO. 6698 ON THE PROTECTION OF PERSONAL DATA

GENERAL DISCLOSURE TEXT

As Sargın İnşaat ve Makine Sanayi Ticaret Anonim Şirketi (“SARGIN”), we show maximum sensitivity to the security of your personal data in accordance with the Law No. 6698 on the Protection of Personal Data (“KVKK” or “Law”). With this awareness, we attach great importance to the processing and storage of all kinds of personal data belonging to all persons associated with the Company, including those who benefit from our products and services as a Company, in accordance with the Law No. 6698 on the Protection of Personal Data. With the full realization of this responsibility, as Data Controller, we process your personal data as explained below and within the limits prescribed by the legislation.

Scope of Personal Data

For your safety and for our Company to fulfill its obligations under the law, your personal data may be processed in accordance with the Labor Law, Occupational Health and Safety Law, Social Insurance and General Health Insurance Law, Turkish Commercial Code, Law on Regulation of Publications on the Internet and Combating Crimes Committed Through These Publications, Within the framework of our legal obligations arising from the Law No. 6698 on the Protection of Personal Data and other relevant Legislation and Regulations, personal data (name-surname, address, occupation, education, marital status, date and place of birth, resume, e-mail, T. C. identification number, telephone number, gender, vehicle license plate number, IP address and camera recordings taken inside and outside the workplaces, e-mail signature, etc.) by automatic or non-automatic methods or in case of logging in to our website, based on your explicit consent or in accordance with the legal reasons and conditions specified in the Law, our Company will be able to obtain, record, preserve, update, reorganize personal data in order to continue its services, transfer it to third parties in the country or abroad in cases and to the extent permitted by the legislation, and process it in other ways approved by the law by taking the necessary administrative and technical measures.

Pursuant to the Law, SARGIN will store personal data in accordance with the law and the rule of honesty, accurately and, where necessary, up-to-date, for specific, explicit and legitimate purposes, in connection with the purpose for which they are processed, in a limited and measured manner, for the period stipulated in the relevant legislation or for the legal retention period required for the purpose for which they are processed or for the period required by the purpose of processing, and at the end of the period required by the purpose of processing, they will be anonymized and will continue to be used by our Company or will be destroyed in accordance with the Law and the relevant legislation in accordance with the Company Procedures.

Purposes of Processing Personal Data

Your personal data, verbally, in writing or electronically, within the framework permitted by the Law;

To liaise with real/legal persons who have a business relationship with the Company
Taking the necessary steps to make, implement and realize commercial decisions by SARGIN,
Ensuring the physical security of our workplaces and personnel safety,
Follow-up of financial and/or accounting affairs,
Ensuring that our Human Resources activities are carried out in accordance with the legislation,
Conducting occupational and worker health/safety activities,
Establishment and management of cyber security technologies infrastructure,
Establishment and protection of Intellectual and Industrial Property rights,
Contract management, establishment of legal transactions and follow-up of legal processes,
Planning, auditing and execution of information security processes in order to protect our company’s trade secrets and ensure information security,
The burden of proof as evidence in future legal disputes,
SARGIN’s ability to fully and duly fulfill its obligations arising from contracts and legislation,
To be able to evaluate and respond to the suggestions, requests, complaints and fault notifications you will send to us through our website and to carry out improvement works in accordance with the notifications

will be processed for the purposes for which they were intended.

Legal Reason and Method of Personal Data Collection

As a general rule, your personal data is processed with your explicit consent. However, it can be processed without explicit consent in the presence of conditions such as; it is clearly stipulated in the law, it is necessary for the establishment or performance of the contract, it is mandatory for the fulfillment of the legal obligation, or provided that it does not harm the fundamental rights and freedoms of the person concerned, it is mandatory for the legitimate interests of the data controller or it has been made public by you.

In order to carry out the activities of our Company, your personal data are collected and stored in verbal, written and electronic media by automatic or non-automatic methods. Your legal data is processed by the following methods, including but not limited to those specified herein:

For the purposes of ensuring legal, technical, physical and commercial business security, ensuring occupational health and safety and general employee safety; entrance doors, building exterior, dining hall, cafeteria, cafeteria, visitor waiting room, parking lot, security booth and floor corridors in our service buildings and construction sites are recorded by means of security cameras in the service area and the recording process is supervised by the technical unit. The aforementioned camera recordings are processed automatically based on the legal reason “it is mandatory for the data controller to fulfill its legal obligation” and “data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject”.

Although our company does not use any cookies in the use of the website, the IP address and User-Agent information that your internet browser sends to our servers are recorded anonymously in the log records and are not processed for any purpose other than ensuring the proper functioning of the website.

In addition, your personal data that you share with us can also be processed through e-mails you send to our Company’s e-mail addresses or employees’ corporate e-mail addresses or phone numbers, sms you send to social media channels, calls and documents you deliver physically or by mail.

For security purposes, visitor registration at building entrances is requested only verbally in the form of name and surname to be notified to the person concerned without being recorded by any means.

To whom and for what purpose personal data can be transferred

Our Company may process your personal data within the framework of the personal data processing conditions and purposes specified in Articles 5, 8 and 9 of the Law and in this text. Within the framework of the personal data processing conditions and purposes specified in the articles and this text; In order to carry out the activities of the Company, to resolve legal disputes or in accordance with the relevant legislation, our direct / indirect domestic / foreign affiliates, legal and real persons, suppliers, subcontractors, business partners, shareholders, legal, financial and tax consultants, auditors, audit companies or public institutions or organizations, judicial authorities or relevant law enforcement agencies authorized to request this data as required by a legal obligation, and other persons or institutions for these purposes.

Rights of the Relevant Person Listed in Article 11 of Law No. 669

As the people concerned;

Learn whether personal data is being processed,
Request information if their personal data has been processed,
To learn the purpose of processing personal data and whether they are used for their intended 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 KVKK No. 6698 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 analyzing the processed data exclusively through automated systems,
In case of damage due to unlawful processing of personal data, you have the right to demand compensation for the damage.

Application Method to the Data Controller

You can submit your requests regarding your rights listed above by filling out the application form available at “https://www.sargininsaat.com” and using one of the methods described below. It is important that the information/data you share with our Company is correct and transferred to our Company correctly, and this is important for you to exercise your rights. In order for a person other than the personal data owner to make a request, there must be a special power of attorney issued by the personal data owner on behalf of the person who will make the application.

Application Method	Application Address	Subject to be specified in the application submission
In Person Application (The applicant must come in person and apply with a document certifying his/her identity)	İlkbahar Mahallesi 608. Sokak No:9 06550 Çankaya/Ankara	“Information Request within the scope of the Law on the Protection of Personal Data” will be written on the envelope.
Notification via notary public	İlkbahar Mahallesi 608. Sokak No:9 06550 Çankaya/Ankara	“Information Request within the scope of the Law on the Protection of Personal Data” will be written on the notification envelope.
KEP address Your registered e-mail address	sargin@hs01.kep.tr info@www.sargininsaat.com.tr	“Information Request within the scope of the Law on the Protection of Personal Data” will be written in the subject section of the e-mail notification.

Following the application of the relevant person, our Company will finalize the application of the relevant person free of charge within a legal period of 30 days. In cases that require additional cost calculation for the fulfillment of the relevant person’s requests, our Company reserves the right to charge the relevant person 1 Turkish Lira for each page in written responses over 10 pages, and the cost of the recording medium in case of a response on recording media such as CD, flash memory, etc.

Our Company reserves the right to make changes in this disclosure statement due to changes that may occur in the Law and new methods or regulations that may be determined by the Personal Data Protection Board.

Your personal data we collect must be accurate and, where necessary, up-to-date. Therefore, in case of any change in your personal data, you are obliged to notify our Company of this matter. The responsibility arising from the provision of incorrect or inaccurate information belongs to the party transmitting the information/data to our Company.

Changes to Data Privacy Principles

Since there may be changes in the above-mentioned matters depending on legislative, technological and commercial changes, we recommend that you visit our website regularly in order to be informed about these changes.

Click here for the Data Subject Application Form.