ACCOMAR MARINE INTERIOR AS
POLICY ON THE PROTECTION AND PROCESSING OF PERSONAL DATA
Document
Name : Accomar Interior Architecture A.Ş. Policy
on Protection and Processing of Personal Data Target Group
Target
Group : Accomar Interior Architecture
A.Ş. Employees, employee candidates, suppliers, shareholders, company
officials, cooperating company employees and all similar real persons whose
personal data are processed by us.
Prepared by : Accomar
Interior Architecture Inc. Human Resources and Administrative Affairs
Department
Version : 00
Approved by :Accomar
Interior Architecture Inc. Management board
This
Policy will be updated from time to time in order to comply with the changing
legislation.
This Policy on the Protection and Processing of
Personal Data ("Policy"),
in the capacity of data controller, Accomar İç Mimarlık A.Ş. ("Accomar and/or Company") processes
supplier, visitor, agency employee, officer, employee candidates, suppliers,
shareholders, company officials, collaborating company employees and similar
interlocutor personal data.
Policy,
I. Personal data collection methods and
legal reasons,
ii. Which person groups' personal data are
processed (Data Subject Person Group Categorization),
iii. Which category of personal data is
processed in relation to these groups of people (Data Categories) and sample
data types,
iv. In which business processes and for
what purposes this personal data is used,
v. Technical and administrative measures
taken to ensure the security of personal data,
vi. To whom personal data can be
transferred, and for what purpose
vii. It explains what your rights are over
your personal data processed by Accomar and what you can use and how these rights are
1-
Definition
and Abbreviations
In this section,
special terms and phrases, concepts, abbreviations, etc. in the Policy.
briefly explained.
Explicit Consent: Consent regarding a specific subject, which
is given based on information and free will, and is limited for data processing
purposes.
Anonymization: Making personal data incapable of being
associated with an identified or identifiable natural person in any way, even
by matching with other data.
Accomar: Accomar
Interior Architecture Inc.
Employee: Accomar employee
Service Provider: Employee of the company (supplier, subcontractor,
third party, cloud service provider, etc.) from which Accomar receives and/or
provides services.
Personal Data Owner (Relevant Person): The
natural person whose personal data is processed.
Personal
Data: Any information relating to an
identified or identifiable natural person.
Processing of Personal Data: Obtaining, recording, storing, preserving, changing,
rearranging, disclosing, transferring, taking over, making available personal
data by fully or partially automatic or non-automatic means provided that it is
a part of any data recording system, All kinds of operations performed on data
such as classification or prevention of use..
Institution: Personal Data Protection Authority
Board: Personal Data Protection Board
KVKK: Law No. 6698 on the Protection of Personal
Data
Special Quality Personal Data:
Data of the nature defined in Article 6 of KVKK
Policy: Accomarİç Mimarlık A.Ş. Personal Data
Protection and Processing Policy. .
Data Processor: It is the natural or legal person who
processes personal data on behalf of the data controller, based on the
authority given by the data controller.
Data Controller: It is the natural or legal person who
determines the purposes and means of processing personal data, is responsible
for the establishment and management of the data recording system, and is
obliged to register with the Data Controllers Registry.
2-
Personal
Data Collection Methods and Legal Reasons
Accomar, in accordance with the personal data
processing conditions specified in the 5th and 6th articles of the Personal
Data Protection Law No. 6698 ("Law"),
It processes your personal data in audio, visual, electronic or written form
through notifications from administrative and judicial authorities and other
communication channels..
3-
Data
Subject Person Group Categorization
Accomar suppliers, visitors, agency employees,
officials, employee candidates, suppliers, shareholders, company officials,
collaborating company employees and similar real persons as well as other
person groups (consultants, trainers, auditors) in line with the legal reasons
specified in this Policy. ) can process your personal data.
4-
Data Categories and Sample Types
(i)
Your Identity Information: Name, surname, place of birth, date of birth,
age, photo, identity and identity
number, passport information,
(ii)
Your Contact Information: Workplace address, home address, e-mail,
telephone, mobile phone, residence, address registration system records,
(iii) Family Status : Data
on marital status, number of children, spouse and children (identity, financial
status),
(iv) Professional Life :Your
data: employment history,
employer name, graduated school, professional competencies, background
information,
(v)Special Qualified Data : Medical
Report, data on criminal convictions and security measures, membership in
associations, foundations or unions,
(vi) Banka Account Data : Bank
account data and IBAN information,
(vii) Personnel file : All
kinds of surveys, reports on performance and career development, information
regarding employment, training or interview, any fringe benefits or benefits to
be offered to employees.employee data containing information and other similar
information,
(viii) Company Security : Entry
and exit camera recordings of company buildings,
(ix) Cyber Security : Usernames,
passwords, IP address, website access logs
regarding cyber security with logs,
5-
Legal
Obligations
In accordance with KVKK, Accomar has legal
obligations within the scope of protection and processing of personal
data. These obligations are listed as follows:
5.a Disclosure Obligation
Accomar is obliged to inform the relevant
person during the collection of personal data and to inform the relevant person
about the following in this context:
·
Identity of the data controller and its
representative, if any,
·
For what purpose personal data will be
processed,
·
To whom and for what purpose the processed
personal data can be transferred,
·
Method and legal reason for collecting personal
data,
·
Rights of the person concerned.
Within the scope of Accomar's lighting
obligation; will inform the related persons about the processing of their
personal data by different means. In addition, Accomar attaches
importance to making public policies understandable by personal data
owners. The Accomar website contains information on the above-mentioned
issues.
Which tools will be used regarding how to
inform the relevant persons are determined in the relevant texts.
5.b Information Obligation
Pursuant to Articles 11 and 13 of the KVKK,
Accomar evaluates the requests regarding the said rights; is obliged to
inform the relevant persons, and this notification will be made within the
period determined within the scope of the legal legislation.
Such requests must be submitted to Accomar in
writing by the relevant persons or by other methods determined by the
Board. In order not to contradict the Board's decision on this issue,
Accomar tries to provide the relevant person with more opportunities to apply.
5.c Obligation to Ensure Data Security
Accomar, as a data controller, fulfills its
obligations regarding data security arising from Article 12 of the KVKK.
5.d Obligation to Register with the Data
Controllers Registry
Accomar is obliged to register with the Data
Controllers Registry within the period determined and announced by the Board,
pursuant to Article 16 of the KVKK.
Pursuant to article 16/3 of KVKK; An
exception may be made to the obligation to register in the registry, taking
into account the objective criteria to be determined by the Board, such as the
nature and number of processed personal data, the legal origin of data
processing or the transfer to third parties.
5.e Principles to be complied with regarding the
processing of personal data
All collected personal data must be processed
in accordance with the principles listed in Article 4 of the KVKK and in
accordance with the conditions specified in Articles 5 and 6. Accomar,
pursuant to Article 4 of the KVKK; is responsible for processing personal
data by keeping it for the period required by the relevant legislation or for
the purpose for which it is processed, in accordance with the law and the rules
of honesty regarding the processing of personal data, accurately and, when
necessary, for up-to-date, specific, clear and legitimate purposes, in
connection with the purpose, in a limited and measured manner.
6-
Purposes
of Use of Personal Data
Accomar processes personal data limited to the
purposes and conditions within the processing conditions of personal data and
special quality personal data specified in Articles 5 and 6 of the KVKK.
These purposes and conditions are as follows:
·
It is clearly stipulated in the law for Accomar
to carry out relevant activities regarding the processing of personal data,
·
The processing of personal data by Accomar is
directly related to and necessary for the establishment or performance of a
contract,
·
The processing of personal data is mandatory
for Accomar to fulfill its legal obligation,
·
Provided that the personal data has been made
public by the relevant persons; processed by Accomar in a limited manner
for the purpose of publicizing,
·
The processing of personal data by Accomar is
mandatory for the establishment, exercise or protection of the rights of
Accomar or the relevant persons or third parties,
·
It is mandatory to process personal data for
the legitimate interests of Accomar, provided that it does not harm the
fundamental rights and freedoms of the persons concerned,
·
Processing personal data by Accomar is
necessary for the protection of the life or physical integrity of the personal
data owner or anyone else, and in this case, the personal data owner is unable
to express his consent due to actual or legal invalidity,
·
It is stipulated in the laws in terms of
special quality personal data other than the health and sexual life of the
personal data owner,
·
In terms of sensitive personal data regarding
the health and sexual life of the personal data owner, persons or authorized
institutions and organizations that are under the obligation of confidentiality
for the purpose of protecting public health, conducting preventive medicine,
medical diagnosis, treatment and care services, planning and managing health
services and financing processed by
In this context,
Accomar processes your personal data for the following purposes:
·
Creation and storage of the personnel file in
the establishment, performance and termination processes of your employment
contract.
·
fulfillment of obligations of legal arising
from the employment contract and the legislation to which our company is
subject.
·
Ensuring business continuity and planning and
executing business activities,
·
Planning, execution and reporting of human
resources processes
·
Planning and execution of financial and social
rights,
·
Creation and management of information security
infrastructure,
·
Planning and executing the access
authorizations of the employees, keeping logs of their entrance and exit to the
places they have access,
·
Camera recording in designated areas in order
to ensure the safety of the Company,
·
Follow-up of cases to which the company is a
party, responding to requests from judicial and administrative authorities,
sending notices and warnings, issuing a power of attorney on behalf of the
employee, if necessary,
·
Preparation of necessary documents in
accordance with the General Assembly and Board of Directors resolutions,
·
Determination of working hours and disability,
disability status,
·
Planning and evaluation of training activities,
·
Participating in events such as conferences,
seminars, invitations, award ceremonies, promotions,
·
Taking photos and videos in social activities,
·
The use of photos and videos on the Company
website, documents, the Company's social media accounts and other company
events,
·
Planning domestic or international travel and
accommodation, conducting visa and passport application processes,
·
Making Supplementary and Private Health
Insurance, Personal Accident Insurance and Liability Insurance,
·
Performing disciplinary and investigation
procedures in accordance with legal regulations and internal company
procedures,
·
Financial reporting and accounting controls,
·
Realization of compulsory private pension
transactions,
·
Taking workplace health and safety measures,
making entry-return examinations, periodic examinations, disease examinations,
pregnancy follow-up examinations by the workplace physician,
·
Sending congratulation/condolence or get well
soon messages in case of birth, death, marriage, serious illness and surgery to
employees and their family members,
·
Counseling and support activities.
7-
Technical
and Administrative Measures Taken to Ensure the Security of Personal Data
Personal data will be kept confidential in the
database in Accomar in accordance with Article 12 of the Law and will not be
shared with third parties for commercial purposes.
Accomar, in order to ensure the security of the
personal data it processes, to prevent unlawful access and to prevent unlawful
data processing; takes encryption, transaction log, access management and
physical security measures to ensure that information systems containing personal
data are protected against unauthorized access and illegal data processing.
Although Accomar takes the necessary
information security measures, personal data is damaged or passed into the
hands of third parties as a result of attacks on the website and system.
In case of an attack Accomar immediately
notifies the persons whose personal data has been damaged, and the Personal
Data Protection Board, in accordance with the Board's Decision dated 24.01.2019
and numbered 2019/10.
8-
To
whom and for what purpose the processed personal data can be transferred
Your personal data; In line with the
purposes detailed in the "Purposes of Use of Personal Data" heading,
it may be transferred to the following persons/organizations:
I.
Third parties at home and/or abroad with whom
Accomar has a contractual relationship,
II.
To public institutions and organizations that
are legally authorized to request personal data regarding physical visitors, in
case of request,
III.
Personal data regarding suppliers, companies,
subsidiaries and related public institutions with which business is done within
the scope of the contract regarding the goods, products or services provided,
IV.
To all institutions and organizations permitted
by the provisions of the legislation.
9-
Rights
of Data Owner
The rights you have on your personal data you
have shared with us within the scope of the purposes and processing methods of
personal data set forth in this Policy, pursuant to Article 11 of the Law, are
as follows:
1
i.
Learning whether personal data is processed or
not,
ii.
If personal data has been processed, requesting
information about it,
iii.
Learning the purpose of processing personal
data and whether they are used in accordance with their purpose,
iv.
To know the third parties to whom personal data
is transferred in the country or abroad,
v.
To request correction of personal data in case
of incomplete or incorrect processing,
vi.
Requesting the deletion or destruction of
personal data within the framework of the conditions stipulated in Article 7 of
the Law,
vii.
Requesting notification of the transactions
made pursuant to clauses 7.(v) and 7.(vi) to third parties to whom personal
data has been transferred,
viii.
Objecting to the emergence of a result against
the person himself by analyzing the processed data exclusively through
automated systems,
ix.
To request the compensation of the damage in
case of loss due to unlawful processing of personal data.
To use these rights; Pursuant to Article
11 of the Law, you can submit your requests regarding your personal data
together with information/documents confirming and confirming your identity,
provided that you comply with the procedures and principles set forth in the
Communiqué on Application Procedures and Principles to the Data Controller;
I.
You can apply to our company address in writing
with a petition.
II.
You can send an e-mail from your KEP address to
the Registered E-mail address (accomar@hs01.kep.tr) on our company's website.
III.
You can send an e-mail to "kisiselveri@accomar.com.tr" with a
secure electronic signature or from the e-mail address you have given to our
Company and registered in our system.
10-Update Period
In case of changes in line with the economic
and commercial decision of Accomar or the decisions of the Personal Data
Protection Board, our members whose data are recorded will be notified by the
way they are registered.
11-Enforcement
This data policy enters into force on the date
of publication and remains in effect until it is removed from the website.
© Accomar Interior Architecture Inc. 2022
This document cannot be reproduced or distributed without the
written permission of Accomar İç Mimarlık A.Ş.
