Personal Data Protection

İHLAS GAZETECİLİK ANONİM ŞİRKETİ
PROTECTION AND PROCESSING OF PERSONAL DATA CLARIFICATION TEXT

Data Controller : İhlas Gazetecilik A.Ş.
Yenibosna Merkez Mahallesi, 29 Ekim Caddesi,
İhlas Plaza No:11 A/41, 34197,
Bahçelievler / İstanbul

 

İhlas Gazetecilik A.Ş., hereinafter referred to as the “COMPANY”, pays the utmost attention to the security of your personal data. With this awareness, as the Company, we attach great importance to the processing and preservation of the personal data of individuals associated with our Company, including our customers, consumers, and employees who benefit from our products and services, in accordance with the legislation, primarily the Constitution of the Republic of Türkiye, international conventions on human rights to which our country is a party, and the Law on the Protection of Personal Data No. 6698 (“KVKK”).

In this context, in our capacity as the “Data Controller” as defined under the KVKK, we would like to inform you.

With full awareness of this responsibility, we process your personal data in the manner explained below and within the boundaries prescribed by the legislation. Your personal data shared with our Company in the capacity of consumer, subscriber, customer, supplier, visitor, intern, and employee may be processed in accordance with the KVKK, in connection with and proportional to our operational and service purposes, transferred to third parties in Türkiye and abroad, stored, used for profiling, and classified.

  1. Collection, Processing, and Processing Purposes of Personal Data:
    Within the scope of your utilization of our Company’s products and services, your personal data listed below are processed through our website and other channels;

    • Your explicit identity data such as name, surname, Turkish ID Number, date of birth, place of birth,
    • Your address, telephone number, e-mail address, and other contact data,
    • Personnel file details provided for employment contracts made with our employees,
    • All kinds of information including details regarding the service you purchased, as well as your payment information related to these,
    • Information obtained from İŞKUR and private employment agencies for our intern candidates,
    • Other personal data you personally convey within the scope of your requests, suggestions, and complaints,
    • In the event that you use our websites, your behavioral and digital footprint data obtained through cookies,
    • Your voice call recordings kept in accordance with Company standards,
    • In the event that you visit our workplaces, your camera recordings and vehicle information.

    Special Categories of Personal Data relating to individuals’ race, ethnic origin, political opinions, philosophical beliefs, religion, sect or other beliefs, attire, membership to associations, foundations or trade unions, health, or sexual life are not processed in our Company.

    Although your personal data may vary depending on the services provided by our Company and our Company’s commercial activities; it can be collected verbally, in writing, or electronically through automatic or non-automatic methods, via our Company units, website, social media channels, mobile applications, and similar means. Your personal data may be processed by being generated and updated as long as you benefit from the products and services offered by our Company and İhlas Grubu Şirketleri.

    Furthermore, your personal data may be processed when you use our call centers or website to use the services of the Company or İhlas Grubu Şirketleri, when you visit our Company or website, or when you attend training sessions, seminars, or organizations organized by our Company.

    Within the conditions and purposes of personal data processing, it will be processed:

    • In accordance with the law and rules of good faith,
    • In a limited, relevant, and proportionate manner to the purposes of processing,
    • Accurately and up to date,
    • For specified, explicit, and legitimate purposes.

     

    Your collected personal data will be processed for the purposes of:

    • Enabling you to benefit from the products and services offered by our Company and İhlas Grubu Şirketleri; understanding your preferences, usage habits, and needs regarding the offered products and services to respond to your requests faster, improving our communication with you to provide better service, and offering more personalized products, services, and offers; performing analyses to achieve these; informing you about our products and services; measuring your satisfaction with our products and services; developing and diversifying our products and services in line with your requests and needs,
    • Ensuring the legal and commercial security of our Company, İhlas Grubu Şirketleri, and persons who are in a business relationship with our Company (administrative operations for communication carried out by our Company, ensuring the physical security and inspection of locations belonging to the Company, İhlas Grubu Şirketleri customer evaluation / complaint management processes, reputation research processes, event management, legal compliance process, audit, financial affairs, etc.),
    • Determining and implementing our Company’s commercial and business strategies,
    • Ensuring the execution of our Company’s human resources policies; as well as the data of our employees, for the purpose of increasing performance levels and employee satisfaction, ensuring occupational safety and labor peace, in addition to the obligations stipulated by the Labor Law, labor and social security legislation, and other applicable legislation, within the scope of Articles 5 and 6 of the KVKK specified explicitly below:

     

    ARTICLE 5- Conditions for processing personal data

    (1) Personal data cannot be processed without the explicit consent of the data subject.

    (2) In the presence of one of the following conditions, it is possible to process personal data without seeking the explicit consent of the data subject:

    1. Explicitly provided for in the laws.
    2. It is mandatory for the protection of life or physical integrity of the person or someone else, who is physically unable to express his/her consent or whose consent is not granted legal validity.
    3. It is necessary to process the personal data of the parties to a contract, provided that it is directly related to the establishment or performance of the contract.
    4. It is mandatory for the data controller to fulfill its legal obligation.
    5. It has been made public by the data subject himself/herself.
    6. Data processing is mandatory for the establishment, exercise, or protection of a right.
    7. Data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

     

    ARTICLE 6- Conditions for processing special categories of personal data

    (1) Data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect, or other beliefs, appearance and dress, membership to associations, foundations, or trade unions, health, sexual life, criminal convictions, and security measures, as well as biometric and genetic data, are special categories of personal data.

    (2) Processing of special categories of personal data without the explicit consent of the data subject is prohibited.

    (3) Personal data other than health and sexual life listed in the first paragraph may be processed without the explicit consent of the data subject in cases stipulated by law. Personal data relating to health and sexual life, on the other hand, may only be processed without seeking the explicit consent of the data subject by persons under a confidentiality obligation or authorized institutions and organizations for the purpose of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing.

    (4) In the processing of special categories of personal data, taking adequate measures determined by the Board is also mandatory.

  1. To Whom and For What Purposes Processed Personal Data May Be Transferred
    Your collected and processed personal data may be transferred, in accordance with the KVKK and applicable legislation, for the purposes listed in Article 1 of this document, to:

    • Our indirect/direct domestic affiliates or subsidiaries,
    • Domestic public/private institutions and organizations, companies, and other 3rd persons or organizations from which service/support/consultancy is received, collaborated with, or project/financing partners,
    • Our Company’s subsidiaries, consultants, shareholders, or other group companies as solution partners,
    • Central Securities Depository (Merkezi Kayıt Kuruluşu) and other authorized institutions and organizations,

    including but not limited to these; to our business partners in line with the purpose of the service we provide, or to regulatory/supervisory authorities and official bodies in cases stipulated by the relevant legislation, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK, domestically or abroad.

  2. Method and Legal Basis of Personal Data Collection
    Your personal data may be obtained by our Company through various means (written, oral, audio or video recording, or in other physical or electronic media, etc., via the Company’s headquarters, branches, sales offices, offices and other physical environments where you can communicate with other subcontractors or business partners, call centers, websites, mobile applications, and similar electronic transaction platforms, social media, or other publicly available channels, by participating in trainings, conferences, and similar environments organized by them, through investigation methods, or through other group companies or other contracted persons and organizations). Your personal data is obtained in all kinds of written, oral, audio or video recording, or other physical or electronic media, for the purpose of presenting the products and services offered by the Company within the determined legal framework in line with the purposes set forth above, and enabling our Company to fulfill its contractual and statutory responsibilities completely and accurately. Your personal data is collected orally, in writing, or electronically through tools such as websites, call centers, digital channels, various contracts, mobile applications, e-mail, application forms, written or oral communications with our Company, etc., by our Company or real/legal persons processing data on behalf of our Company, including but not limited to those listed. Your personal data collected for these purposes and legal reasons can also be processed and transferred for the purposes specified in Articles (1) and (2) of this text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK.
  3. CASES WHERE THE “COMPANY” MAY PROCESS YOUR PERSONAL DATA WITHOUT EXPLICIT CONSENT PURSUANT TO KVKK
    Pursuant to paragraph 2 of Article 5 of the KVKK, in the following cases, the COMPANY may process your personal data obtained in accordance with the Law without seeking your explicit consent:

    1. It is explicitly provided for in the laws,
    2. It is mandatory to process your personal data for the protection of life or physical integrity of yourself or another person when you are physically unable to express your consent as the data subject or where legal validity is not granted to your consent,
    3. It is necessary to process personal data belonging to the parties to a contract, provided that it is directly related to the establishment or performance of a contract,
    4. It is mandatory for the “COMPANY” to fulfill its legal obligations as the data controller,
    5. Your personal data has been made public by yourself,
    6. Data processing is mandatory for the establishment, exercise, or protection of a right,
    7. Data processing is mandatory for the legitimate interests of the “COMPANY” as the data controller, provided that it does not harm your fundamental rights and freedoms.

     

     

  4. RIGHTS OF THE PERSONAL DATA SUBJECT ENUMERATED IN ARTICLE 11 OF THE KVK LAW
    As personal data subjects, your rights are specified below; Personal data subjects have the right to:

    • Learn whether personal data is processed,
    • Request information if personal data has been processed,
    • Learn the purpose of processing personal data and whether they are used appropriately for their purpose,
    • Know the third parties to whom personal data is transferred domestically or abroad,
    • Request correction of personal data if it is incomplete or incorrectly processed and request notification of the transaction made within this scope to third parties to whom personal data has been transferred,
    • Request the deletion or destruction of personal data in the event that the reasons requiring its processing cease to exist, despite having been processed in accordance with the provisions of the KVK Law and other relevant laws, and request notification of the transaction made within this scope to third parties to whom personal data has been transferred,
    • Object to the occurrence of a result against the person himself/herself by analyzing the processed data exclusively through automated systems,
    • Request compensation for damages in case of suffering damage due to unlawful processing of personal data.

    Pursuant to paragraph 1 of Article 13 of the KVK Law, you may submit your request regarding the exercise of your above-mentioned rights to our Company in writing or by other methods determined by the Personal Data Protection Board.

    We kindly remind you that in this application, which contains explanations regarding the right you request to exercise as a personal data subject to use your rights specified above; the matter you request must be clear and understandable, the subject you request must be related to your person, or if you are acting on behalf of someone else, you must be specifically authorized in this regard and document your authorization, additionally it must contain identity and address information, and documents certifying your identity must be attached to the application.

    Within this whole framework, the channels and procedures through which you will submit your application in writing to our Company within the scope of Article 11 of the KVK Law are explained below.

    To exercise your above-mentioned rights, you may fill out the (“PERSONAL DATA SUBJECT APPLICATION FORM”) at the address www.ihlasgazetecilik.com.tr in accordance with the information text at the beginning of the form, along with necessary information identifying your identity and your explanations regarding the right you request to exercise among the rights specified in Article 11 of the KVK Law, and deliver a signed copy of the form in person with documents identifying your identity to the address:

    İhlas Gazetecilik A.Ş. Yenibosna Merkez Mahallesi 29 Ekim Cadde No: 11a/41 Bahçelievler / İstanbul

    via a notary public, send it by other methods specified in the KVK Law, or forward the relevant form to the address ihlasgazetecilik@hs03.kep.tr.

    Our Company will conclude your requests in the application free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, the fee in the tariff determined by the Board will be charged. In this context, if the data subject’s application is responded to in writing, no fee will be charged up to ten pages, and a processing fee of 1 TL will be charged for each page above ten pages. If the response to the application is given in an electronic recording medium such as CD or flash memory, the fee that may be requested by our company will not exceed the cost required by the recording medium.

    I have read and understood this Clarification Text prepared regarding who will process my personal data, for what purpose, to whom and for what purpose the processed personal data can be transferred, the method and legal basis of personal data collection, and my rights specified in Article 11 of the Law, pursuant to Article 10 titled “Data Controller’s Obligation to Inform” of the Law on the Protection of Personal Data No. 6698, and I have been informed in detail on this matter by the

    “COMPANY” holding the status of data controller.

 

İhlas Gazetecilik Personal Data Protection and Processing Policy

Application Form