Halaman Privacy Policy

Last updated: 09 December, 2024

INFORMATION NOTICE REGARDING THE PROTECTION OF PERSONAL DATA

Dear customers, esteemed business partners, job applicants, and visitors; as Halaman Printing and Packaging Industry Inc. (“Company”), the privacy and security of your personal data are among our top priorities. Under the provisions of Law No. 6698 on the Protection of Personal Data (“KVKK”), any information that identifies or can identify your identity, including your sensitive personal data, is considered Personal Data and will be processed by our Company as the Data Controller within the scope described below and under the framework explained in the law. This includes collecting, recording, storing, retaining, updating, modifying, reorganizing, sharing, transferring, and classifying your data, anonymizing it, and processing it in other ways listed in the law. We would like to inform you about the use and protection of your personal data under KVKK and your rights in this regard to safeguard your fundamental rights and freedoms.

Details about the personal data processed for our employees, interns, shareholders, and company officials are published in a manner accessible only to them, and they are thoroughly informed on this matter.

A. For Our Customers:

1. Your Processed Data:

The following personal data of individuals or, in the case of legal entities, their authorized representatives who have used or are using the products and services provided by our Company, regardless of whether there is a contractual relationship, are processed:

• Identity Information: Name, surname, Turkish Citizenship Number (TCKN).
• Contact Information: Mobile number, work number, address, email address.
• Customer Transaction Information: Order and invoice details, delivery process information, transaction history, request and complaint details, promissory note, check details, receipt details, customs declarations.
• Legal Process Information: Correspondence details with authorized individuals, institutions, and organizations, information in legal and enforcement case files, legal request details.
• Audio Recording Information: Recordings of conversations with our Company.
• Financial Information: Bank account number, IBAN number, account balance details.

2. Purposes and Methods of Processing Your Personal Data:

• Identity, Contact, Financial, and Customer Transaction Information: Collected directly from you via contractual relationships, agreements, signature circulars, forms, and commitments for the purposes of:
  • Managing processes for establishing and executing contracts,
  • Conducting and auditing finance and accounting processes,
  • Running and auditing the Company’s business operations,
  • Managing billing processes,
  • Conducting logistics and cargo activities and tracking delivery processes,
  • Managing communication activities,
  • Carrying out sales processes for goods and services,
  • Managing legal affairs,
  • Managing customer relationship processes,
  • Providing information to authorized individuals, institutions, and organizations.
• Legal Process Information: Collected directly from you under contractual relationships via agreements, signature circulars, forms, and commitments for the purposes of:
  • Managing processes for establishing and executing contracts,
  • Conducting and auditing the Company’s business operations,
  • Ensuring compliance with regulations,
  • Managing legal affairs,
  • Providing information to authorized individuals, institutions, and organizations.
• Audio Recording Information: Collected during phone conversations with our Company, with prior notice of “recording,” for the purposes of:
  • Managing processes for establishing and executing contracts,
  • Managing communication activities,
  • Improving and enhancing the products and services offered by our Company,
  • Evaluating requests, complaints, and suggestions related to our products and services,
  • Ensuring compliance with regulations,
  • Managing customer relationship processes,
  • Managing legal affairs,
  • Providing information to authorized individuals, institutions, and organizations.

3. Legal Grounds for Processing Your Personal Data:

Your personal data is processed by the Company for the purposes listed above in accordance with the relevant legislation and Article 5 of the KVKK, based on the following legal grounds:

• Explicitly stipulated in the law,
• Necessary for the establishment or performance of a contract involving the parties,
• Mandatory for the exercise, establishment, or protection of a right,
• Mandatory for the fulfillment of the Data Controller’s legal obligations,
• Necessary for the legitimate interests of the Data Controller, provided it does not harm the fundamental rights and freedoms of the individual.

4. Transfer of Your Personal Data:

Your personal data may be shared with:

• Our business partners, suppliers, banks, and financial advisors for billing processes,
• Tax offices and authorized institutions to fulfill tax obligations,
• Customs brokers, lawyers, and authorized institutions for quality control, complaint management, and product/service sales,
• Attorneys, auditors, forensic experts, cybersecurity consultants, tax consultants, and other third-party consultants and service providers under legal obligations,
• Regulatory and supervisory authorities, courts, and enforcement offices,
• Other public institutions or organizations authorized to request your personal data,
• Affiliates and subsidiaries within and outside Turkey, our suppliers, business partners, contracted banks, and third-party service providers.

B. Our Business Partners:

1. Your Processed Data:

The following personal data of individuals, including employees, shareholders, and authorized representatives of institutions with which our Company engages in any business relationship (e.g., business partners, suppliers) are processed:

• Identity Information: Name, surname, Turkish Citizenship Number (TCKN), signature circulars.
• Contact Information: Mobile number, work number, address, email address.
• Customer Transaction Information: Invoice details, transaction history, request and complaint details, promissory note, check details, receipt details.
• Legal Process Information: Correspondence with authorized individuals, institutions, and organizations; information in legal and enforcement case files; legal request details.
• Audio Recording Information: Audio recordings of conversations with our Company.
• Financial Information: Bank account number, IBAN number, account balance details.

2. Purposes and Methods of Processing Your Personal Data:

• Identity, Contact, Financial, and Customer Transaction Information: Collected directly from you under contractual relationships via agreements, signature circulars, forms, and commitments for the purposes of:
  • Managing processes for establishing and executing contracts,
  • Conducting and auditing finance and accounting processes,
  • Running and auditing the Company’s business operations,
  • Managing billing processes,
  • Managing communication activities,
  • Conducting sales processes for goods and services,
  • Managing customer relationship processes,
  • Managing legal affairs,
  • Providing information to authorized individuals, institutions, and organizations.
• Legal Process Information: Collected under contractual relationships via agreements, signature circulars, forms, and commitments for the purposes of:
  • Managing processes for establishing and executing contracts,
  • Ensuring compliance with regulations,
  • Managing legal affairs,
  • Providing information to authorized individuals, institutions, and organizations.
• Audio Recording Information: Collected during phone conversations with our Company, with prior notice of “recording,” for the purposes of:
  • Managing processes for establishing and executing contracts,
  • Managing communication activities,
  • Improving and enhancing the products and services offered by our Company,
  • Evaluating requests, complaints, and suggestions related to our products and services,
  • Ensuring compliance with regulations,
  • Managing legal affairs,
  • Providing information to authorized individuals, institutions, and organizations.

3. Legal Grounds for Processing Your Personal Data:

Your personal data is processed by the Company for the purposes listed above in accordance with the relevant legislation and Article 5 of the KVKK, based on the following legal grounds:

• Explicitly stipulated in the law,
• Necessary for the establishment or performance of a contract involving the parties,
• Mandatory for the exercise, establishment, or protection of a right,
• Mandatory for the fulfillment of the Data Controller’s legal obligations,
• Necessary for the legitimate interests of the Data Controller, provided it does not harm the fundamental rights and freedoms of the individual.

4. Transfer of Your Personal Data:

Your personal data may be shared with:

• Business partners, suppliers, banks, and financial advisors for billing processes; tax offices and authorized institutions to fulfill tax obligations,
• Attorneys, auditors, forensic experts, cybersecurity consultants, tax consultants, and other third-party consultants and service providers under legal obligations,
• Regulatory and supervisory authorities, courts, and enforcement offices,
• Other public institutions or organizations authorized to request your personal data,
• Affiliates and subsidiaries within and outside Turkey, our suppliers, business partners, contracted banks, and third-party service providers.
• Necessary for the legitimate interests of the Data Controller, provided it does not harm the fundamental rights and freedoms of the individual.

C. Job Applicants:

1. Your Processed Data:

The following personal data of individuals who have applied for a job with the Company by any means or have made their CVs and related information available for review are processed:

• Identity Information: Name, surname, marital status, date of birth, place of birth.
• Contact Information: Mobile number, address, email address.
• Employment Information: Military service status, reference details (with explicit consent), CV details.
• Professional Experience Information: Education and work history, diploma details, foreign language proficiency, computer skills, position/title information.
• Health Information: Disability status (with explicit consent).
• Audio Recording Information: Audio recordings of conversations with our Company.

2. Purposes and Methods of Processing Your Personal Data:

• Identity, Contact, Employment, and Professional Experience Information: Collected via CVs sent to our Company through email, Private Employment Agencies (e.g., İŞKUR, Kariyer.net), other platforms (e.g., LinkedIn), your statements, and electronic or physical application forms provided during the application process. These are processed for the purposes of:
  • Managing recruitment, placement, and application processes for job applicants,
  • Planning human resources policies and processes,
  • Conducting interview processes,
  • Managing communication activities,
  • Conducting business activities,
  • Managing contract processes,
  • Managing salary policies.
• Health Information: Collected via CVs sent to our Company through email, Private Employment Agencies (e.g., İŞKUR, Kariyer.net), other platforms (e.g., LinkedIn), your statements, and electronic or physical application forms provided during the application process. These are processed for the purposes of:
  • Managing recruitment, placement, and application processes for job applicants,
  • Planning human resources policies and processes,
  • Conducting business activities.
• Audio Recording Information: Collected during phone conversations with our Company, with prior notice of “recording,” for the purposes of:
  • Managing recruitment, placement, and application processes for job applicants,
  • Conducting interview processes,
  • Conducting business activities,
  • Managing contract processes,
  • Managing salary policies.

3. Legal Grounds for Processing Your Personal Data:

Your personal data is processed by the Company for the purposes listed above in accordance with the relevant legislation and Article 5 of the KVKK, based on the following legal grounds:

• Explicitly stipulated in the law,
• Necessary for the establishment or performance of a contract involving the parties,
• Mandatory for the exercise, establishment, or protection of a right,
• Mandatory for the fulfillment of the Data Controller’s legal obligations,
• Necessary for the legitimate interests of the Data Controller, provided it does not harm the fundamental rights and freedoms of the individual.

For health information and references (part of employment information), processing is carried out based on Article 6 of the KVKK, which stipulates that:

• Personal data regarding health and sexual life may be processed without explicit consent by persons or authorized institutions and organizations under confidentiality obligations for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, and planning and managing health services and financing.

Such data will only be processed beyond the limitations set by Article 6 with your explicit consent.

4. Transfer of Your Personal Data:

• During the interview phase, your data may be shared with subsidiaries and affiliated entities.
• During interviews and placement processes, your information may be stored in programs and systems provided or made available by our technology infrastructure suppliers.

D. Visitors:

1. Your Processed Data:

The following personal data of individuals visiting the Company’s physical premises for various purposes or browsing our websites are processed:

• Identity Information: Name, surname.
• Contact Information: Phone number, email address.
• Audio Recording Information: Audio recordings of conversations with our Company.
• Physical Security Information: Camera recordings.
• Transaction Security Information: IP address details, cookie data.

2. Purposes and Methods of Processing Your Personal Data:

• Identity and Contact Information: Collected directly from you through your statements and forms during workplace or website visits. These are processed for the purposes of:
  • Managing communication activities.
• Audio Recording Information: Collected during phone conversations with our Company, with prior notice of “recording,” for the purposes of:
  • Managing communication activities,
  • Ensuring compliance with regulations,
  • Providing information to authorized individuals, institutions, and organizations.
• Physical Security Information: Collected through cameras during workplace or website visits. These are processed for the purposes of:
  • Managing emergency processes,
  • Conducting auditing activities,
  • Ensuring physical security,
  • Providing information to authorized individuals, institutions, and organizations.
• Transaction Security Information: Collected during website visits via cookies, with your consent. These are processed for the purposes of:
  • Managing information security processes,
  • Managing access authorizations.

3. Legal Grounds for Processing Your Personal Data:

Your personal data is processed by the Company for the purposes listed above in accordance with the relevant legislation and Article 5 of the KVKK, based on the following legal grounds:

• Explicitly stipulated in the law,
• Necessary for the establishment or performance of a contract involving the parties,
• Mandatory for the exercise, establishment, or protection of a right,
• Mandatory for the fulfillment of the Data Controller’s legal obligations,
• Necessary for the legitimate interests of the Data Controller, provided it does not harm the fundamental rights and freedoms of the individual.

4. Transfer of Your Personal Data:

• Your personal data may be shared, within the scope of the above-listed purposes, with subsidiaries, affiliates, and business partners in compliance with our agreements and the law.
• To fulfill our legal obligations, data may be shared with authorized individuals and official institutions under the relevant regulations and legislation.
• Your data may also be stored in or transferred to systems and programs provided by our technology infrastructure suppliers.

STORAGE AND DESTRUCTION OF YOUR PERSONAL DATA:

The Company has established a Retention and Destruction Policy for the storage and deletion of personal data. The retention and destruction of your personal data are carried out under this policy. If a retention period for the data is specified under KVKK, relevant laws, or other applicable legislation, the data must be stored for at least this duration.

To account for possible delays in legal requests from courts or administrative authorities or potential disputes involving the Company, the retention period for your data is extended by 6 months to 1 year beyond the legally required periods. At the end of this period, the data is deleted, destroyed, or anonymized.

If no retention period is specified in the legislation for the data we process, your data will be deleted, destroyed, or anonymized 10 years after the termination of our legal relationship, considering possible disputes and the 10-year statute of limitations for legal claims. This will occur without requiring any request from you.

If the conditions for processing personal data no longer exist, or the declared or legislatively defined retention period has expired, your data will be deleted, destroyed, or anonymized during the first periodic destruction process or within six months at the latest. If you request the deletion of your data for a valid reason, your data will be deleted within 30 days to the extent legally possible. However, if the retention period for your data is mandated by law, your request to delete or destroy such data before the end of the legally defined period cannot be fulfilled.

YOUR RIGHTS UNDER ARTICLE 11 OF KVKK:

Under KVKK and related legislation, you have the right to:

• Learn whether your personal data is being processed,
• Request information if your personal data has been processed,
• Understand the purpose of processing and whether your data is used in accordance with the stated purpose,
• Know the third parties to whom your data has been transferred,
• Request correction if your data is incomplete or incorrect,
• Request deletion or destruction of your data under the conditions stipulated in KVKK,
• Request notification to third parties to whom your data has been transferred about corrections, deletions, or destruction of your data,
• Object to results arising exclusively from automated processing of your data that negatively impact you, and
• Claim compensation if you suffer damage due to unlawful processing of your data.

APPLICATION METHODS:

You may exercise these rights and submit your requests regarding your personal data by using the Application Form, which you can obtain physically from the workplace or electronically via the Company’s website. You may submit your application through the methods outlined in the table below:

In accordance with the “Communiqué on the Principles and Procedures for Application to the Data Controller,” your applications must include your full name, signature, Turkish Citizenship Number (TCKN), residential address for notification, and, if applicable, your email address, phone number, and details of your request.

When submitting an application, you must clearly and explicitly specify the right you wish to exercise and include relevant information and documents. The subject of your request must be directly related to you. If you are acting on behalf of another person, you must provide documentation (such as a special power of attorney) verifying your authority to act on their behalf. Additionally, your application must include your identity and address details, along with proof of identity. Requests made by unauthorized third parties on behalf of others will not be considered.

Requests regarding your personal data will be evaluated, and you will receive a response within 30 days at the latest from the date your application is received by the Company. If your application is denied, the reasons for denial will be communicated to you at the email or postal address provided, or if possible, via the method of submission.

The Company reserves the right to update this notice at any time in line with changes to applicable legislation.