PERSONAL DATA PROTECTION LAW

TOHUM HOLDİNG ANONİM ŞİRKETİ

PRIVACY NOTICE REGARDING PERSONAL DATA PROCESSING

The main purpose of the Personal Data Protection Law no. 6698 (“KVKK”), which was published in the Official Gazette and entered into force on April 7, 2016, is to protect the fundamental rights and freedoms of individuals, especially privacy, in terms of personal data processing.

With this Clarification Text, we aim to inform you about your personal data processed by our Company TOHUM HOLDİNG ANONİM ŞİRKETİ (“Tohum Holding A.Ş.” or “Company”).

1.IDENTITY OF DATA CONTROLLER

Tohum Holding A.S. have the title of “Data Controller” within the scope of KVKK and related regulations, It is possible to reach us through the contact information given below,

Adress     : Cumhuriyet Mah. Coşkun Sok. No:31 Üsküdar/İstanbul

Phone  : +90 216 335 50 00

Fax          : 0216 335 53 28

E-Mail   : kvkk@en.tohumholding.com.tr

 

  1. PROCESSED PERSONAL DATA

Your personal data, Although it may vary in relation to the product, service or commercial activity offered by our Company, it is processed by our Company in order to ensure that the products and services are offered in the best possible way.

The following personal data are processed within the scope of your relationship with Tohum Holding A.S; your identity and contact information, personal data, professional experience, risk management, customer transaction, transaction security data, legal transaction data, physical space security, finance, data and general and health information, and criminal convictions and security measures, and your sensitive personal data.

 

  1. PURPOSE OF PROCESSING PERSONAL DATA

Your personal data obtained within the scope of your relationship with Tohum Holding AŞ are processed for the purposes listed below.

  • Planning or execution of Emergency Management Processes
  • Execution of Information Security Processes
  • Fulfillment of Employment Contract and Legislative Obligations for Employees
  • Execution of Benefits and Benefits Processes for Employees
  • Execution of Audit / Ethical Activities
  • Conducting Training Activities
  • Execution of Access Authorizations
  • Execution of Activities in Compliance with the Legislation
  • Execution of Finance and Accounting Works
  • Providing Physical Space Security
  • Execution of Assignment Processes
  • Follow-up and Execution of Legal Affairs
  • Execution of Communication Activities
  • Planning of Human Resources Processes
  • Execution / Supervision of Business Activities
  • Execution of Occupational Health / Safety Activities
  • Execution of Business Continuity Ensuring Activities
  • Execution of Goods / Services Procurement Processes
  • Organization and Event Management
  • Execution of Risk Management Processes
  • Execution of Storage and Archive Activities
  • Execution of Contract Processes
  • Execution of Wage Policy
  • Ensuring the Security of Data Controller Operations
  • Execution of Investment Processes
  • Providing Information to Authorized Persons, Institutions and Organizations
  • Execution of Management Activities

 

  1. TRANSFER OF PROCESSED PERSONAL DATA

Collected personal data may be transferred to our shareholders domestic or abroad, our subsidiaries, judicial authorities and similar legally authorized public/private institutions and organizations, correspondent banks, our business partners, and our vendors in accordance with the basic principles envisaged under KVKK and pursuant to the rules regarding the transfer of personal data specified in Articles 8 and 9 of the KVKK and the legal reasons for the processing of personal data stipulated in Articles 5 and 6 of the KVKK.

 

  1. COLLECTION METHODS AND LEGAL REASONS OF PERSONAL DATA

Provide your personal data from you, third parties and legal authorities during the establishment of your legal relationship with Tohum Holding AŞ and during the continuation of the said relationship; It is collected, stored and processed through the internet, telephone, e-mail and physical, written, verbal and electronic media, within the scope of the above-mentioned purposes, based on the reasons for compliance with the law listed in the provisions of Articles 5, 6 and 8 of the Law.

  • Having your explicit consent,
  • Especially; Labour Law, Occupational Health and Safety Law, Social Insurance and General Health Insurance Law, Obligations Law, Tax Procedure Law, Turkish Commercial Code, Identity Declaration Law, Income Tax Law, Corporate Tax Law, Check Law, Private Pension Savings and Investment System and other legislations which our firm is subjected, It is clearly stipulated in these legislations
  • To comply with the national and international principles and principles regarding the recognition of customers, to comply with the information storage, reporting and disclosure obligations stipulated by the legislation and official authorities.
  • Provided that it is directly related to the conclusion or performance of a contract, it is necessary to process the personal data of the parties to the contract, the products and services requested comply with the national and international principles and principles regarding the recognition of customers, to comply with the information storage, reporting and disclosure obligations stipulated by the legislation and official authorities.
  • Obligatory in order to fulfill the legal obligation
  • Being publicized by the person concerned
  • Data processing is mandatory for the establishment, exercise or protection of a right,
  • It is necessary to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

Your sensitive personal data is collected, stored and processed based on the following legal compliance reasons:

Having your express consent,

Personal data other than health, without seeking explicit consent in cases stipulated by law,

Personal data related to health, on the other hand, can only be collected for the purposes of protecting public health, performing preventive medicine, medical diagnosis, treatment and care services, planning and managing health services and financing, by persons or authorized institutions and organizations under the obligation of secrecy, without seeking the explicit consent of the person concerned.

 

  1. RIGHTS OF THE RELATED PERSON whose PERSONAL DATA IS PROCESSED

We hereby declare that you are entitled to the following rights in accordance with Article 11 of the Law:

  • To learn whether your personal data are being processed,
  • To request information if your personal data have been processed,
  • To learn the purpose of the processing of your personal data and whether they have been used accordingly,
  • To learn which third parties domestic or abroad your personal data has been transferred to,
  • To request rectification in case your personal data has been processed incompletely or inaccurately and to demand the operations in this regard be reported to third parties your personal data has been transferred to,
  • To demand the erasure or destruction of your personal data in case the reasons necessitating the processing have disappeared even though it was processed in accordance with the Law and other relevant provisions and to demand the operations in this regard be reported to third parties your personal data has been transferred to,
  • To object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems,
  • To demand compensation for the damages that you have suffered as a result of an unlawful processing of your personal data.

 

  1. IF YOU WANT TO CONTACT US FOR YOUR RIGHTS AND REQUESTS

You can send the Application Form below, which includes your identity information required to exercise your rights, the right you want to use and your detailed explanation about the subject of your request, by using one of the methods specified in this Application Form.

Applications to be made within this scope will be accepted following the identity verification to be made by us, and your requests will be finalized as soon as possible and within 30 days at the latest, depending on the nature of the request. In case of a written response to the application, no fee will be charged for up to 10 pages, and a processing fee of 1 Turkish Lira may be charged for each page over 10 pages. If the response to the application is given in a recording medium such as CD or flash memory, a fee may be charged in the amount of the cost of the recording medium.

Personal Data Owner Application Form