Privacy Disclaimer as per the Law on the Protection of Personal Data;

1. 1.     Data Controller

   This personal data privacy disclaimer is prepared by Sepiciler Çaybaşı Deri San. Tic. A.Ş. (“Sepiciler”) as the data controller within the scope of the Article 10 of the Law on the Protection of Personal Data numbered 6698 (¨the Law¨) and the Communiqué on Principles and Procedures to be Followed in Fulfillment of the Obligation to Inform.

   2.     Processing of Personal Data and the Purposes of Processing

   Sepiciler processes below-mentioned personal data belonging to the employees, employee candidates, customers, company executives, suppliers and supplier executives, third party employees, visitors and other third parties (carriers, agencies, warehouse employees, carrier drivers, third party executives etc.):

   ·       Identity: Name, surname, Turkish Republic identification number, mother’s name, father’s name, mother’s maiden name, date of birth, place of birth, marital status, identity card series order number, nationality, copy of the identity card, copy of the driver license photocopy, signature, copy of the passport, copy of the certificate of identity register, gender, electronic signature, photo on the identity card

   ·       Audio and Visual Recording: Photography

   ·       Physical Place Security: Camera recording

   ·       Contact: Mobile phone number, business phone number, home phone number, e-mail address, home address, fax number, post code, registered e-mail address (KEP), retroactive residence, company address

   ·       Finance: Credit card information, IBAN number, payment information, bank account information, salary account statement, payroll, personal account statement, copy of deed, invoice information registered in the name of a person, debt information, financial information

   ·       Personnel: curriculum vitae, payroll information, disciplinary proceeding information, entrance and exit information, performance evaluation report, assignment information, job application form, requested salary information, date of recruitment, allowance information, department, emergency contact information, dependent information, social security institution registration number, employee registration number, employment end date,  employment end code, total labor day, deserved  fee, child information, military information, vehicle registration plate, notice and severance payment amount, deserved overtime pay, social security institution payment, annual leave payment, reason of leaving, reference information, statement of employment, social security institution service list, information on attendance cards and records, information on personnel file, social security institution records, information on employment contracts, annual leave records

   ·       Professional Experience: Work experience, bachelor’s degree information, certificates, occupational health and safety education information, vocational education information, on-the-job education information, attended courses, education examination information, profession, job, title, information on previous jobs, education status, department/unit, workplace doctor certificate date and number, business card, working status

   ·       Health Information: Health report, disability status, disease or new birth information, disease, blood type, drug information, medical examination and procedure information, previous disease or surgery information, health examination dates, information on completion of health examination, congenital/chronic disease information, immunization information, family history, hemogram test, liver test, kidney test, heart test, chest radiography, ear tests, pulmonary function test, eye examination, medical history information, physical examination results, laboratory findings, opinions and results on health status, psychiatric and psychological status, urine information, diagnosis, decision, referral branch, justification for referral, treatment date, contagious disease information, mental or physical disorder information, occupational accident records, information on periodic health examination reports

   ·       Appearance: Size information

   ·       Criminal Conviction and Security Measures: Case information, criminal conviction information, criminal record

   ·       Transaction Security: User code, IP address information, website log in and exit information, information on the desktop, e-mail correspondence, other information existing in the e-mail box

   ·       Visa Information: Copy of the passport (type of passport, passport number, country that the passport is given, date of issue and end date), purpose of travel, date of departure and return of the travel, accommodation information, sponsor information, information of person travelled together, driver license information in other countries, visa information in other countries, former passport application information, education information, foreign language information, previous job information, death information, divorce information, date of marriage, date of divorce, ground for divorce, dates of arrival and departure to previous countries, copy of marriage wallet, other necessary information requested by consulates, travel information

   ·       License Plate

    

   Above-mentioned personal data are being processed by Sepiciler within the scope of the below-mentioned purposes, the personal data processing conditions and purposes set forth under the applicable personal data protection legislation and limited with such purposes. 

   ·       Ensuring the physical place security

   ·       Conducting information security processes

   ·       Executing technical service processes

   ·       Carrying out activities in accordance with the legislations

   ·       Informing authorized persons, institutions and organizations

   ·       Carrying out education activities

   ·       Organization and event management

   ·       Executing/auditing business activities

   ·       Executing good sales processes

   ·       Ensuring the security of data controller’s operations

   ·       Conducting foreign trade processes

   ·       Executing production and operation processes of goods

   ·       Fulfillment of contractual and legislative obligations for employees

   ·       Carrying out side benefit and interest processes for employees

   ·       Carrying out the application process of the candidate employees

   ·       Carrying out occupational health and safety activities

   ·       Monitoring and executing legal affairs

   ·       Planning human resources processes

   ·       Conducting audit activities

   ·       Creating and tracking visitor records

   ·       Carrying out the purchase process of goods/services

   ·       Carrying out contract processes

   ·       Carrying out customer relationship management processes

   ·       Carrying out the marketing processes of goods

   ·       Conducting supply chain management process

   ·       Conducting visa process

   ·       Carrying out management activities

   ·       Executing necessary examinations during the beginning of the employment due to legal obligations

   ·       Carrying out annual periodic examination due to legal obligations

   ·       Providing annual education to employees due to legal obligations

   ·       Carrying out prescribing processes

   ·       Carrying out examination and hospital referral processes

    

   Data subject’s personal data will be transferred to physical archives and information systems and will be stored in both digital and physical environments and will be subject to deletion, destruction or anonymization within the framework of Sepiciler procedures in accordance with the Law and related legislation at the end of the period required by the processing purpose.

   3.     Parties to Whom the Personal Data are Transferred and the Purposes of Transfer

   The personal data obtained by Sepiciler will be only transferred to competent public institutions and organizations, business partners, suppliers, certificate institutions in Turkey and abroad, lawyers, courts, human resources consultancy companies, public notaries, travel agencies, consulates in Turkey and abroad, airline businesses, specialist doctors, emergency polyclinics, real persons and private legal entities in Turkey and abroad that Sepiciler are cooperating or will be cooperating and to the mutual databases which Sepiciler use with these parties merely based on the reasons specified under the Article 2 of this privacy disclaimer and the reasons necessary to be transferred within the scope of the regulations regarding the Law and limited with such reasons.

   4.     Methods and Legal Grounds of Collecting Personal Data

   Personal data are being collected using automated or non-automated ways via oral or written information transmitted to Sepiciler by data subject within the framework of legal grounds specified as; (i) explicit consent, (ii) expressly prescribed by laws, (iii) processing of personal data of the parties of a contract is necessary provided that it is directly related to the establishment or performance of the contract, (iv) it is necessary for compliance with a legal obligation to which the data controller is subject, (v) data processing is necessary for the establishment, exercise or protection of any right and (vi) legitimate interest of the data controller under the Article 5 of the Law and within the framework of legal grounds set forth under the Article 6 and the Article 9 of the Law.

   5.     Rights of Data Subject’s Towards the Protection of Personal Data

   Pursuant to the Article 11 of the Law, data subjects are entitled to;

   a) to learn whether his/her personal data are processed or not,

   b) to demand for information as to if his/her personal data have been processed,

   c) to learn the purpose of the processing of his/her personal data and whether these personal

   data are used in compliance with the purpose,

   d) to know the third parties to whom his personal data are transferred in country or abroad,

   e) to request the rectification of the incomplete or inaccurate data, if any,

   f) to request the erasure or destruction of his/her personal data under the conditions referred to in Article 7,

   g) to request reporting of the operations carried out pursuant to sub-paragraphs (d) and (e) to third parties to whom his/her personal data have been transferred,

   h) to object to the occurrence of a result against the person himself/herself by analyzing the data processed solely through automated systems,

   i) to claim compensation for the damage arising from the unlawful processing of his/her personal data.

   Data subjects may convey to Sepiciler their requests regarding the Law via ¨Data Subject Application Form¨ on www.sepici.com.tr or with an application containing the mandatory information as per the Communiqué on the Principles and Procedures for the Request to Data Controller by using one of the below channels:

   ·       To Mustafa Kemal Atatürk Mah. Aydın Cad. No: 110 Torbalı / İZMİR  address in person by verifying your identity,

   ·       To sepicilercaybasi@hs03.kep.tr e-mail address,

   ·       To kvkk@sepici.com.tr e-mail address with secure electronic signature or mobile signature by verifying your identity and within the other methods set forth under the Law and related legislation.

    

   Sepiciler will conclude the application requests at the latest within 30 (thirty) days and free of charge by taking into account the nature of the demand in conformity with the Communiqué on the Principles and Procedures for the Request to Data Controller. If the request is rejected, rejection reason will be justified in writing or in electronic environment. In case the process requires additional expenditure, the tariff set forth on the Communiqué on the Principles and Procedures for the Request to Data Controller will be applied.