TR EN

Public Disclosure Text

PUBLIC DISCLOSURE TEXT FOR PROCESSING OF PERSONAL DATA 

For us, Altınyağ Madencilik ve Enerji Yatırımları San . ve Tic. A. Ş. (here in after to be referred to as "Altınyağ" or "the company") protection of your personal data and personal data of special nature is a priority. Thus we do our utmost and take care to process and store the personal data for the persons who are related to ALTINYAĞ in accordance with law no. 6689 on the protection of personal data ("KVK"). As data controller, "Altınyağ" in all stages of handling your personal data, takes all necessary administrative and technical measures for the protection of your data and process your personal data in line with KVK law, on the terms disclosed below and within the limits set by the relevant rules and regulations. 

The personal data collected during visits to our website are processed in compliance with the rules and regulations that govern protection of personal data. for further information, please examine our confidentiality policy to be found in the said website. but we draw your attention to the fact that no guarantees are given for the data security in the websites for which links are provided in "Altınyağ" website. For this, a particular website’s policy for data security should be carefully examined. 

1. Legal Basis and Scope

Article 10 of law No 6689 on protection of personal data ("KVK") requires that the persons whose data shall be processed -data subjects- be informed while requesting consent for such processing. The title of the said article is ‘’obligation of the controller to inform’’. 

According to the provisions of KVK, "Altınyağ" is a "Data Controller". As such, it is under obligation to inform data subjects about their rights to learn about the identity of the data controller, the purpose of personal data processing, to whom and for what purpose the processed data may be transferred, the legal reasons for collection and the methods of data transfer and also about the rights mentioned in article 11 of the same law to apply to data controller making demands for updating, erasure or anonymization of data, etc. 

2. Identity of Data Controller 

In article 3, paragraph 1, subparagraph (i) of KVK law, data controller is defined as "the real or legal person who determines the purpose and means of processing personal data and is responsible for establishing and managing the data registry system". As such data controller is Altınyağ Kombinaları A.Ş. The contact details of our company are below: 

Altınyağ Kombinaları A.Ş.
Çınarlı Mh. Ozan Abay Cd. No: 10 Ege Perla Kat: 12 D: 123 Konak - İzmir, Turkey

T: +90 232 3768451
F: +90 232 376 8458
W: altinyag.com.tr 

Purpose of Processing Your Personal Data
Your personal data are processed in accordance with the general principles stated in article 4 of KVK law and the conditions for processing personal data described in articles 5 and 6 of the same law, for: 

a) planning and implementing our corporate human resources policies in the best way;
b) planning and execution of application, selection and evaluation procedures for job applicants;
c) improving the quality of the products/services that we offer and in line with prioritizing customer satisfaction, offering differentiated products/services according to the needs, preferences and habits of clients and developing proposals for this end; d) proper planning and execution of our commercial partnerships, subsidiaries and strategies;
e) ensuring the legal, commercial and physical security of our company, business partners and subsidiaries;
f) attaining highest level of personal and commercial data security, developing the necessary data processing infrastructure and data bases and taking administrative and technical measures;
g) planning and/or execution of supply chain management processes;
h) planning and/or management of data analysis, research, statistical computations, trend detection and advertising activities in order to successfully perform marketing processes for goods and services;
i) achieving proper corporate functioning of the company, managing and monitoring finance and/or accounting activities;
j) taking necessary steps to create and improve standards for matters that fall under the field of health and safety at work;
k) improving the services provided in our company’s website;
l) monitoring the demands and complaints received from data subjects and ensuring proper response;
m) ensuring our business units perform the necessary tasks in order to carry out the commercial activities of the company and relevant work processes are followed;
n) drawing up the company’s strategies and making sure that the corporate activities are in line with strategic plans and goals;
o) taking corrective steps for mistakes in our company’s website and achieving conformity to the confidentiality policy shared in the website. 

3. To whom and for what purposes the processed data may be transferred
Your personal data may be transferred under the conditions stipulated in articles 8 and 9 of KVK law and for the purposes described above: 

  • Where necessary for carrying out our company’s commercial activities, to our business partners, subsidiaries, financial investors, consulting firms, suppliers, private and public establishments and organizations; 
  • To banks for payments and collections to be made within the framework of the business contracts for which your personal data are processed; 
  • To courts of justice and government organizations and agencies demanding information, within the scope of the fulfillment of our company’s legal obligations, where necessary; 
  • To law firms and other consultants in order to receive legal support for establishing, exercising and protecting our company’s legal rights; 
  • To general public, in order to fulfill our obligation for informing general public as required by capital markets and stock exchange laws and regulations, within the limits set by such laws and regulations; 
  • To the persons who are needed and involved in planning and implementing the procedures and strategies for achieving uninterrupted business activity, ensuring legal, technical and commercial work security and health and safety at work and to third persons with whom these persons are collaborating; 
  • To the human resources companies whose services we use and to the former and next employers, in the process of hiring and layoff of employees; 
  • To companies providing information technology, data archiving and cloud services, in order to establish the necessary infrastructure and software for corporate electronic communication and ensuring data security and also to internet platforms and applications based abroad in order to provide online services by using online communication channels which are widely and unavoidably used in todays’ world; 
  • To inspection and certification firms and organizations during inspection visits within the framework of quality and control procedures; 
  • To entities based abroad, to online application and service providers, for the applications and software we use at office and on the field while carrying out our corporate activities; 
  • To member firms of our group domiciled in Turkey in accordance with the conditions stipulated in articles 8 and 9 of KVK law governing personal data processing; 
  • To firms providing data archiving and cloud storage services in order to ensure data security. 

During the process of sharing your personal data, all necessary technical and administrative measures are taken to ensure data security. 

4. The method and legal reasons of collection of personal data
As per articles 4, 5 and 6 of KVK law no: 6689 your personal data are collected following the principles of:

a) lawfulness and conformity with rules of bona fides
b) accuracy and being up to date, where necessary
c) being processed for specific, explicit and legitimate purposes
d) being relevant with, limited to and proportionate to the purposes for processing
e) being retained for the period of time stipulated in the relevant legislation or needed for the purpose of processing. 

Your personal data can be collected legitimately by automatic or non-automatic methods and through various channels such as offices, call centers, internet websites, social media platforms, mobile applications and other similar means; in voice recording, in physical environment, in cyber environment or through closed-circuit camera systems and other methods. The nature of the personal data of yours that are collected may vary depending on the services and products provided by or the commercial activity performed by our company. 

Moreover, the company, as a data controller, obtains while you access internet using the net belonging to the company, information about the websites, applications and platforms reached and in order to improve and develop them, records within the framework of the relevant legislation, detailed information including the name of the internet service provider and internet protocol (ip) number, sign-in and sign-off times, the nature of the service used, amount of data transferred and if available subscriber identity data, addresses of the websites visited and web instruments used that facilitate direct contact, names, mac addresses and temporary internal ip numbers of the gadgets used for reaching our internal web and ‘’traffic records’’ and also in order to fulfill the legal obligations arising from the provisions of law no: 5651, record all the above data using electronic instruments and retain for the period of time stipulated in the relevant legislation. the processing of your personal data as explained above is done for the legal reason mentioned in law no:6698 subparagraph 5/2(ç),’‘legal obligation’’. 

Your personal data are processed in accordance with the legal provisions contained in KVK law no:6698 (article 5) as explained below: 

  • Article 5 paragraph 1 requires explicit consent of the data subject for personal data processing, exceptions being: 
  • Subparagraph5/2 (a) for the legal reason of ‘’ being clearly provided for by the laws’’ your personal data are processed as clearly permitted by the laws and regulations to which our company is subject, especially by Turkish commercial code and taxation procedures law, 
  • Subparagraph5/2(b) for ‘’physical incapability’’ , 
  • Subparagraph 5/2(c) for being necessary for ‘’conclusion and execution of business contracts’’, in order to fulfill the contractual obligations arising from the contract for which you disclose your personal information and ensure the continuity of fulfillment, opening current accounts and making payments and collections, 
  • Subparagraph 5/2(ç)for being ‘’mandatory for the data controller to be able to perform its’ legal obligations’’, using your personal data for preparing legal declarations and statements, retaining them forthe periods of time stipulated in laws to which the company is subject, for fulfillment of other obligationsarising from the relevant legislation, to comply with demands for information from courts of justice and other official establishments and organizationsand to fulfill other legal obligations, 
  • Subparagraph 5/2(d) for ‘’personal data being made public by the data subject himself/herself’’, 
  • Subparagraph 5/2(e) for being ‘’mandatory for the establishment, exercise or protection of any right’’, the company using your personal data as evidence in any probable dispute, making it possible to receive legal advise and technical support, 
  • Subparagraph 5/2(f) for being ‘’mandatory for the legitimate interests of the controller’’ -the company processing your personal data-. 

For the purposes stated in this general disclosure statement, your personal data of special nature are processed on the basis of the legal reasons mentioned in article 6 of KVK law as follows: 

a) paragraph 6/2: explicit consent of data subject required,
b) paragraph 6/3: exemption for cases provided for by relevant laws (for personal data of special nature excluding those concerning health and sexual life),
c) paragraph 6/3: personal data of special nature pertaining to health and sexual life to be used for purposes of provision of medical diagnosis, treatment and care services, of preventive medicine, protection of public health and planning and management of health care and finance , 

Your personal data collected on the basis of the legal reasons explained above are processed and transferred only in accordance with the conditions and purposes for processing personal data stipulated in articles 5 and 6 of KVK law and only for the purposes explained in this public disclosure text. 

5. The rights of data subject
As a data subject, if you lodge an application to our company following the rules set out in the following article of this public disclosure text and make demands concerning your rights, our company shall respond/reply in the shortest possible time, depending on the nature of the demand, but within 30 days at the latest and free of charge. However, if the response in question incurs any cost, the corresponding fee stated in the tariff set by personal data protection board may be payable.The data subject has the rights mentioned in article 11 of KVK law: 

  • To learn whether or not his/her personal data are processed, 
  • To request data information in case his/her personal data are processed, 
  • To learn the purpose of his/her data processing and whether the data is used for the intended purposes, * to know the third parties in Turkey or abroad to whom his/her personal data are transferred, 
  • To request correction of personal data records in case of incompleteness or inaccuracy and that the third partiesto whom such data are transferred be notified about the corrective action,
  • In case the legitimate reasons for processing of your personal data no longer exist, to request erasure or destruction of such personal data, even though they were processed in accordance with the KVK law and other relevant lawsand that the third parties to whom such data are transferred be notified about the action taken,
  • To object to the processing of his/her personal data exclusively by automatic means which has an unfavorable consequence for him/her,
  • To demand compensation in case unlawful processing of his/her personal data leads to damages. 

6. Lodging application and right to request information
If you have any doubts concerning your personal data, please apply to Altınyağ Kombinaları A.Ş. the address and contact information of which are shown in our internet website.You may lodge your application for exercising your rights described in article 11 of KVK law, in accordance with article 11 paragraph 1 of the same law, in writing or by sending e-mail to info@altinyag.com.tr from your registered e-mail address (kep) or from the e-mail address you have previously advised us which we have in our files. You may reach the necessary explanations and the application and information request form using the link provided here. 

In your application, it is necessary to state:
a) Your name, family name and signature (if printed)
b) If you are Turkish citizen, yourTurkish identity number, if not your nationality, passport number or your identity number -if available-
c) Your residential or workplace address for delivery of reply
ç) Your e-mail address-if available, telephone and fax number)
d) The subject matter of your request. Please attach detailed information and relevant documents to your application. Our company shall deal with the demands made in your application within the shortest possible time, depending on the nature of your request, and within thirty days at the latest and free of charge. However, if the action requested has a cost, the corresponding fee in the tariff issued by the board may be collected. Only that part of your application that concerns yourself shall be dealt with and applications for your spouse, relatives or friends will not be accepted.