Protection of Personal Data

This Clarification Text is signed by As Coton Ambalaj San. Trade Inc. As (“As Coton” or “Company”), within the scope of the general principles regarding the processing of personal data stipulated by the Law on the Protection of Personal Data No. 6698 (the “Law”); You will be informed about the purposes of processing your personal data, the collection methods and legal grounds of your personal data, to whom and for what purposes, the protection and security of this data, the destruction of personal data whose processing conditions are no longer valid, the rights of the data subject on personal data and the methods of exercising these rights. designed to give.

1. Scope and Purpose of the Illumination Text

Hereby, the Clarification Text Regarding the Processing of Personal Data, by As Coton;

• Methods and legal reasons for collecting personal data,
• Which person groups' personal data are processed (Relevant Person Categorization),
• In which category the personal data of the persons concerned are processed (Data Categories) and sample data types,
• For what purposes the relevant personal data is used,
• Technical and administrative measures taken to ensure the security of personal data,
• To whom personal data can be transferred and for what purposes,
• Personal data sharing with public institutions and organizations and official authorities,
• Storage periods of personal data,
• What are the rights of the persons concerned over their personal data and how they can use these rights.

states in detail. 

2. Personal Data Collection Methods and Legal Reasons

As Coton, in accordance with the personal data processing conditions specified in the Law, and in accordance with the personal data processing conditions, through the printed form, e-mail, mail, CCTV, notifications from administrative and judicial authorities and other communication channels, in audio, electronic or in writing. It is collected in line with the legal reasons specified in the Clarification Text. These legal reasons; Regarding the contracts concluded with the following categories of related persons; The establishment and performance of the contract, the fact that the relevant personal data processing process of As Coton arises from the law, the legal obligations of As Coton are fulfilled, the establishment, exercise or protection of a right, the personal data being made public by the data subject himself and in exceptional cases are legitimate interests.

3. Relevant Person Categorization

As Coton groups the persons whose personal data it processes as follows:

        I. Customer (Customer Employee, Customer Representative)

       ii. Visitor

      iii. Online Visitor

      iv. Supplier (Supplier Employee, Supplier Official)

 

 

 

 

 

4.Data Categories and Example Data Types

 

No	Related person	Data Category	Data Types
one.	Customer (Customer Employee, Customer Representative)	Credentials	Name-Surname, TR Identity Number
		Communication information	Email, Phone
		Financial Information	Bank Account Information, IBAN Number, Payment Information
		Customer Transaction Information	Customer Satisfaction Information
		Legal Transaction Information	Contract, Signature
		Location Information	Address

 

2.	Visitor	Credentials	Name surname
		Professional experience	Institution Information
		Other	CCTV

 

3.	Online Visitor	Transaction Security Information	Device, Brand, Model, 5651 IP Logs
		Legal Transaction Information	IP Address and other data within the scope of traffic information

 

4.	Supplier (Supplier Employee, Supplier Official)	Credentials	Name-Surname, TR Identity Number, Date of Birth
		Communication information	Email, Phone / Mobile Phone
		Financial Information	Account Number, IBAN Number, Bank Account Information, Payment Information
		Professional experience	Title, Occupation, Education Certificates
		Special Quality Personal Data / Criminal Conviction and Security Measures	Criminal Records
		Legal Transaction Information	Contract, Signature
		Audio and Audio Recordings	Photograph

 

5. For What Purposes Personal Data Is Used

Personal data is used by As Coton for the following purposes;

• Carrying out the necessary work by the relevant business units for the realization of the commercial activities carried out by the company and the execution of the related business processes
• Planning and/or Execution of Efficiency/Efficiency and/or Appropriateness Analysis of Business Activities
• Planning and/or Execution of Business Continuity Activities
• Planning and Execution of Logistics Activities
• Planning and Execution of Corporate Communication Activities
• Planning and Execution of Supply Chain Management Processes
• Planning, Auditing and Execution of Information Security Processes
• Establishment and Management of Information Technologies Infrastructure
• Ensuring Transaction Security
• Follow-up of Company Finance and Accounting Affairs
• Planning and Execution of Company Operation Processes
• Planning and Execution of External and Internal Training Activities
• Execution of Strategic Planning Activities
• Management of Relationships with Business Partners and/or Suppliers
• Confirmation that the Supplier from which Service is Provided Has Sufficient Experience and Training in Compliance with the Regulations
• Follow-up of Contract Processes and/or Legal Requests
• Planning and Execution of Sales Processes of Products
• Planning and/or Execution of After Sales Support Services Activities
• Planning and Execution of Customer Relationship Management Processes
• Quotation Collection, Price Inquiry, Order Opening, Order Tracking
• Follow-up of Customer Requests and/or Complaints
• Planning and/or Execution of Customer Satisfaction Activities
• Planning and Execution of Market Research Activities for Sales and Marketing of Products and Services
• Planning and Execution of Marketing Processes of Products and/or Services
• Follow-up of Legal Affairs and Fulfillment of Legal Responsibilities
• Fulfillment of Obligations Arising from Legislation
• Giving Information Based on Legislation to Authorized Institutions
• Planning and Execution of the Operational Activities Required for the Ensuring that the Company Activities are carried out in accordance with Company Procedures and/or Relevant Legislation
• Planning and Execution of Company Audit Activities
• Presenting the Designs Made Based on the Order Forms by Contacting the Customer
• Planning and Execution of Related Processes for Obtaining the Highest Benefit from the Products or Services Offered by the Company
• Ensuring the Security of Company Campuses and/or Facilities
• Planning and/or Execution of Occupational Health and/or Safety Processes
• Ensuring the Security of Company Operations
• Supply of Company Sites and Movables
• Ensuring the Security of Company Fixtures and/or Resources
• Creating Visitor Records

 

 

6. To Whom Personal Data Can Be Transferred And For What Purpose

As Coton transfers personal data to our domestic suppliers, public institutions and organizations and official authorities only for the purposes specified in this Clarification Text and in accordance with Article 8 of the Law.

Depending on the content and scope of the service received from third parties; In all cases where there is no need to transfer the personal data of the person concerned, the transfer is made using Pseudonymous data (pseudonymous data).

In addition to the technical measures to ensure their security, the personal data subject to domestic transfer we mentioned above; Considering that the other party of the legal relationship is a data controller or a data processor, it is also legally protected thanks to the Law-compliant provisions included in our contracts.

No	Related person	With whom and for what purpose is Personal Data Shared?
one.	Customer (Customer Employee, Customer Representative)	Sharing customer personal data with suppliers for plate production, processing of designs; During company audits, there are processes such as sharing the relevant data with the auditor companies within the scope of the audit.
2.	Supplier Employee, Supplier Official	There is no personal data sharing in the processes of notifying the error in the goods/services supplied and resolving the problem; Sharing the current, full and BA/BS reconciliations with the third party (financial advisor) from whom the service is received for electronic media; During company audits, there are processes such as sharing the relevant data with the auditor companies within the scope of the audit.

 

7. Personal Data Sharing with Public Institutions and Organizations and Official Authorities

No	Related person	With whom and for what purpose is Personal Data Shared?
one.	Customer (Customer Employee, Customer Representative)	It is shared with official persons, institutions and organizations in order to fulfill the obligations stipulated in the legislation and contracts and to follow the legal proceedings.
2.	Visitor / Online Visitor	In cases where As Coton has a legal or administrative obligation to notify or provide information, traffic information such as personal data and navigation information related to visiting the websites is within the scope of legal obligations (such as the fight against crime, the threat of state and public safety, and similar but not limited to this). ) sharing this information with public institutions and organizations that are legally authorized to request this information; Sharing log records with official institutions; and camera recordings are shared with official institutions such as the prosecutor's office and the court upon request.
3.	Supplier Employee, Supplier Official	Sharing personal data with relevant public institutions and notaries for the purpose of realizing the legal notifications required by accounting; Sharing invoices and collection receipts with representatives of the Ministry of Finance during tax audits; Sharing financial data with a lawyer in order to fulfill the payment obligation arising from the current commercial relationship; and sharing it with official persons, institutions and organizations in order to fulfill the obligations stipulated in the Legislation and the contracts concluded with the Supplier.

 

8. Storage Periods of Personal Data

As Coton preserves the personal data it processes in accordance with the Law for the periods stipulated in the relevant legislation or required by the purpose of processing. These periods included in the Personal Data Storage and Disposal Policy are as follows:

Data Type	Storage Time	Legal Basis
Personal Data Regarding Customers	10 years from the end of the legal relationship	Law No. 6102, Law No. 6098, Law No. 213
Personal Data Regarding Visitors (Camera Records)	15 days	Ensuring Security
Personal Data Regarding Online Visitors	2 years	Law No. 5651
Personal Data Regarding Suppliers	10 years from the end of the legal relationship	Law No. 6102, Law No. 6098 and Law No. 213
All Records Related to Accounting and Financial Transactions	10 years	Law No. 6098

 

9. What are the Rights of the Relevant Persons on their Personal Data and How They Can Use These Rights

The rights of the Relevant Persons pursuant to Article 11 of the Law are as follows:

(1) Learning whether personal data is processed or not,

(2) If personal data has been processed, requesting information about it,

(3) Learning the purpose of processing personal data and whether they are used in accordance with their purpose,

(4) To know the third parties to whom personal data is transferred in the country or abroad,

(5) Requesting correction of personal data in case of incomplete or incorrect processing,

(6) Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in Article 7 of the KVK Law,

(7) Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,

(8) Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,

(9) To request the compensation of the damage in case of loss due to unlawful processing of personal data.

 In order to exercise your rights over your personal data, you can perform necessary changes, updates and/or deletion operations and related requests via As Coton's official e-mail address  kvkk@ascotonambalaj.com .

10. Terms of Deletion, Destruction and Anonymization of Personal Data

As Coton, collects and processes personal data from physical, electronic, website, and e-mail channels within the scope of business processes, and stores it for the periods stipulated by the relevant laws and/or for the periods required by the purpose of processing, pursuant to Article 7, 17 and Article 138 of the Turkish Penal Code. In the event that these periods expire, it will delete, destroy or anonymize Personal Data in accordance with the provisions of the Regulation on the Deletion, Destruction or Anonymization of Personal Data and the Guide for Deletion, Destruction or Anonymization of Personal Data.

Deletion of personal data by As Coton means the process of making personal data inaccessible and unusable for the relevant users in any way.

Destruction of personal data by As Coton refers to the process of making personal data inaccessible, unrecoverable and reusable by anyone.

Anonymization of personal data by As Coton means that personal data cannot be associated with an identified or identifiable natural person in any way, even if it is matched with other data.

As Coton explains in detail the methods of deletion, destruction and anonymization and the technical and administrative measures it has taken within the scope of the Personal Data Storage and Disposal Policy prepared in accordance with the Regulation on the Deletion, Destruction or Anonymization of Personal Data.

 

11. Changes to be Made in the Clarification Text Regarding the Processing of Personal Data

As Coton can always make changes in the Clarification Text Regarding the Processing of Personal Data. These changes will become effective immediately with the publication of the amended Clarification Text on the Processing of Personal Data. In order for you to be aware of the changes in this Clarification Text, necessary information will be provided to you through appropriate channels.

 

 

Click to download the  relevant person application form .