ODINE SOLUTIONS
WEB PRIVACY AND DATA PROTECTION TERMS
1.PURPOSE AND SCOPE
Web Privacy and Data Protection Terms (“Terms”) presented herein, expresses the principles followed by Odine Solutions Teknoloji Tic. ve San. A. Ş. (“ODINE”, “Company” or “Data Controller”) on the protection of personal data, specifies the principles of the processing of the personal data of Potential Employee, Customer, Potential Customer, Third Person and Supplier Employee/Official (“Data Subject Groups”) and informs Data Subject Groups pursuant to the Turkish Law. No: 6698 on the Protection of Personal Data (“Law”).
2.DATA PROCESSING PRINCIPLES
ODINE, as the Data Controller, processes your personal data in compliance with the principles listed below.
2.1 Lawfulness and Conformity with Rules of Bona Fides
We respect the principles envisioned by the legislation and the general reliability and Bona Fides rules when processing your personal data.
2.2 Accuracy and Being Up to Date, Where Necessary
We run periodical checks and audits and take appropriate measures in order to ensure that the personal data processed is accurate and where necessary, up to date, taking into consideration your legitimate interests. In this context, ODINE incorporates systems aiming at checking the accuracy of the personal data and making necessary adjustments.
2.3 Being Processed for Specific, Explicit and Legitimate Purposes
Your personal data are processed for specific, explicit and legitimate purposes.
2.4 Being Relevant with, Limited to and Proportionate to the Purposes for Which They Are Processed
Your processed personal data are relevant with, limited to and proportionate to the purposes for which they are processed and the processings that are unrelated to the realization of the purpose or unnecessary are avoided.
2.5 Being Retained for the Period of Time Stipulated by Relevant Legislation or the Purpose for Which Whey Are Processed
Your personal data are stored only for the periods envisioned by the relevant legislation or to the extent that it is necessary for the purposes of the data processing. In this respect, ODINE establishes if the relevant legislation stipulates a storage period and if yes, respects the period specified, and if not, retains the personal data to the extent necessary for the purpose which they are processed for. Following the end of the time period or the cease of the reasons which the personal data are processed for, personal data are erased, destroyed or anonymized according to the ODINE Personal Data Deletion and Retention Policy.
3. CONDITIONS FOR PROCESSING OF PERSONAL DATA
3.1 When It Is Clearly Provided For by the Laws
Your personal data may be processed when it is clearly provided for by the laws.
3.2 When It Is Mandatory for the Protection of Life or Physical Integrity of the Person or of Any Other Person Who Is Bodily Incapable of Giving His Consent or Whose Consent Is Not Deemed Legally Valid
Your personal data may be processed when it is mandatory for the protection of life or physical integrity of the person or of any other person who is bodily incapable of giving his consent or whose consent is not deemed legally valid.
3.3 When Processing of Personal Data Belonging to the Parties of a Contract, is Necessary Provided That It Is Directly Related to the Conclusion or Fulfilment of That Contract
Your personal data may be processed when processing of personal data belonging to the parties of a contract, is necessary provided that it is directly related to the conclusion or fulfilment of that contract.
3.4 When It Is Mandatory for the Controller to be Able to Perform his Legal Obligations
Your personal data may be processed when it is mandatory for the controller to be able to perform his legal obligations.
3.5 When the Data Concerned Is Made Available to the Public by the Data Subject Himself
Your personal data may be processed when the data concerned is made available to the public by the data subject himself.
3.6 When Data Processing Is Mandatory for the Establishment, Exercise or Protection of Any Right
Your personal data may be processed when data processing is mandatory for the establishment, exercise or protection of any right.
3.7 When It Is Mandatory for the Legitimate Interests of the Controller, Provided that this Processing Shall Not Violate the Fundamental Rights and Freedoms of the Data Subject
Your personal data may be processed when it is mandatory for the legitimate interests of the controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject.
3.8 Based on Your Explicit Consent
Your personal data may be processed based on your explicit consent in the absence of the conditions expressed above.
4. CATEGORIZATION OF PERSONAL DATA
5. PURPOSES OF PERSONAL DATA PROCESSING
ODINE processes personal data for the purposes detailed below per Data Subject Group, under the conditions set forth by the articles 5 and 6 of the Law.
5.1 CUSTOMER
Customer personal data are processed within the conditions set forth by the articles 5 and 6 of the Law, for the purposes of carrying out financial and accounting affairs, carrying out contractual processes, fulfilling legal obligations, ensuring physical security, managing internal audit activities, managing communication activities, executing business continuity activities, following up on and auditing of business activities, carrying out customer relations management processed, executing firm, product and service loyalty processes, executing customer satisfaction activities, managing organizations and events and carrying out service processes and support services promised by the Company.
5.2 POTENTIAL CUSTOMER
Potential Customer personal data are processed within the conditions set forth by the articles 5 and 6 of the Law, for the purposes of fulfilling legal obligations, ensuring physical security, carrying out the sales processes related to the services or products, managing advertisement activities and executing customer satisfaction activities.
5.3 THIRD PERSON
Third Person personal data are processed within the conditions set forth by the articles 5 and 6 of the Law, for the purposes of carrying out the business and operation processes which are necessary for the function of the services presented by the Company, carrying out the necessary work for the implementation of the commercial activities of the Company and executing relevant business processes, carrying out the work and business processes which are necessary for the function of the services and products presented by the Company, offering and promotion of the services and products provided by the Company and performance of the contract.
5.4 ONLINE VISITOR
Online Visitor personal data are processed within the conditions set forth by the articles 5 and 6 of the Law, for the purposes of carrying out marketing analysis processes, carrying out advertisement / campaign / promotion processes, managing communication activities, carrying out processed related to the development of the services and products and fulfilling legal obligations.
6. TRANSFER OF PERSONAL DATA
Your personal data may be transferred to our group companies, affiliates, business partners, suppliers and to legally authorized public authorities and natural persons located inland and/or abroad, within the framework provided in the articles 3 and 5 of the Terms and the conditions specified in the articles 8 and 9 of the Law.
7. METHOD AND LEGAL REASON OF COLLECTION OF PERSONAL DATA
Personal data are processed by ODINE based on the legal reasons and via the methods explained below per Data Subject Group.
7.1 CUSTOMER
Customer personal data obtained from himself/herself or from a third person on electronical, physical or verbal media, may be processed partially or completely automatically or non-automatically provided that the process is a part of any data registry system, are processed, as envisioned by the article 5 of the Law; provided that it is clearly provided for by the laws, that the processing of personal data belonging to the parties of a contract, is necessary provided that it is directly related to the conclusion or fulfilment of that contract, that it is obligatory for our legitimate interests given that your fundamental rights and interests are not harmed or that it is mandatory for the controller to be able to perform his legal obligations.
7.2 POTENTIAL CUSTOMER
Potential Customer personal data obtained from himself/herself or from a third person on electronical, physical or verbal media, may be processed partially or completely automatically or non-automatically provided that the process is a part of any data registry system, are processed, as envisioned by the article 5 of the Law; provided that data processing is mandatory for the establishment, exercise or protection of any right, that the processing of personal data belonging to the parties of a contract, is necessary provided that it is directly related to the conclusion or fulfilment of that contract, that it is mandatory for the legitimate interests of the controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject or that it is mandatory for the controller to be able to perform his legal obligations.
7.3 THIRD PERSON
Third Person personal data obtained from himself/herself or from a third person on electronical, physical or verbal media, may be processed partially or completely automatically or non-automatically provided that the process is a part of any data registry system, are processed, as envisioned by the article 5 of the Law; provided that it is explicitly envisioned by laws or that it is mandatory for the legitimate interests of the controller, that this processing shall not violate the fundamental rights and freedoms of the data subject or based on the conditions specified article 6 of the Law.
7.4 ONLINE VISITOR
Online Visitor personal data obtained from himself/herself or from a third person on electronical, physical or verbal media, may be processed completely automatically provided that it is clearly provided for by the laws such as the Law no. 5651 on Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publication, that it is mandatory for the legitimate interests of the controller, that this processing shall not violate the fundamental rights and freedoms of the data subject or that it is mandatory for the controller to be able to perform his legal obligations.
8. PERSONAL DATA SECURITY
ODINE takes reasonable measures preventing data losses by accident, intended erasures and aggrievements of and risks of unauthorized access to personal data in order to ensure personal data security and to avoid unlawful processing of personal data.
All technical and physical measures are taken to prevent access to personal data by unauthorized persons. In this context, the authorization system is designed in such a manner that it doesn’t allow users to access personal data more than it is needed.
ODINE conducts necessary audits and controls or has them conducted with the aim of ensuring proper implementation of the provisions of the Law within its organization.
9. STATEMENT ON THIRD PARTY PERSONAL DATA
Processing of third parties’ personal data obtained from Data Subject Groups is approved and consented to, by the Data Subject Group. Data Subject Group undertakes that she or he has informed the data subject and if necessary, obtained her/his explicit consent pursuant to the Law. Otherwise, all damages arising thereof will be compensated solely by the Data Subject Group.
10. PROCEDURES AND RULES FOR DATA PROTECTION REQUESTS
As a data subject, you can direct your claims relating to your rights listed on the article 11 of the Law, by filling out the Data Protection Request Form, which you can obtain from our website https://www.odinesolutions.com/ and from the Front Office, in accordance with the specified procedures and principles, or with your application which meets the minimum conditions stipulated by the Communiqué on the Procedures and Principles of Application to the Data Controller, to our odine@hs02.kep.tr REM address, kvkk@odinesolutions.com e-mail address, or in writing, through your e-mail address that is registered in our system or via a mobile-signed or e-signed message that you can forward to us, or you can submit your written application with wet signature in person or through a notary public to the address of Veko Giz Plaza, Kat: 11 Maslak / Istanbul / Turkey. We, as the Company, will process your application as soon as possible and within thirty days at the latest, according to the nature of your claim and free of charge. However, if the transaction requires additional costs, a fee in the amount determined by the Turkish Personal Data Protection Board shall be charged by the Company.
Within the article 11 of the Law, you are entitled
- to learn whether his personal data are processed or not,
- to request information if his personal data are processed,
- to learn the purpose of his data processing and whether this data is used for intended purposes,
- to know the third parties to whom his personal data is transferred at home or abroad,
- to request the rectification of the incomplete or inaccurate data, if any,
- to request the erasure or destruction of his personal data under the conditions laid down in Article 7,
- to request notification of the operations carried out in compliance with subparagraphs (4) and (5) to third parties to whom his personal data has been transferred,
- to object to the processing, exclusively by automatic means, of his personal data, which leads to an unfavourable consequence for the data subject and
- to request compensation for the damage arising from the unlawful processing of his personal data.
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