Cookie Management Policy

PERSONAL DATA PROCESSING DISCLOSURE TEXT

1. INTRODUCTION
As the data controller, it is of great importance for EDS Enjeksiyon Dokum San. Tic. A.S. (hereinafter referred to as “EDS” or the “COMPANY”) to process and store all personal data belonging to its employees, customers, and other natural and legal persons with whom it is in a relationship in accordance with the Personal Data Protection Law No. 6698 (“KVKK”). Accordingly, and in compliance with Article 10 of the KVKK and the Communique on the Procedures and Principles to be Followed in Fulfilling the Obligation to Inform, published by the Personal Data Protection Board in the Official Gazette dated March 10, 2018 and numbered 30356, our Company provides this information to personal data subjects at the time their personal data is obtained, in order to fulfill its obligation to inform them about the identity of our Company, the purposes for which personal data will be processed, to whom and for what purposes processed personal data may be transferred, the method and legal basis for collecting personal data, and the rights of the personal data subject under Article 11 of the KVKK.

2. PERSONAL DATA
2.1 Definition of Personal Data
Within the framework of Article 3/I(d) of the KVKK, “personal data” means any information relating to an identified or identifiable natural person. In this context, personal data means any information relating to an identified or identifiable natural person.

In this context, anonymous information, information that has been anonymized, and other data that cannot be associated with a specific person are not considered personal data under our Company's policy on this matter.

2.2 Concept of Processing Personal Data
Within the framework of Article 3/I(e) of the KVKK, processing of personal data means any operation performed on data, such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making obtainable, classifying, or preventing the use of personal data, whether fully or partially by automatic means or by non-automatic means provided that it is part of any data recording system.

3. SCOPE OF DISCLOSURE
3.1 Identity of the Data Controller
According to the KVKK, since the “Data Controller” means the natural or legal person who determines the purposes and means of processing personal data and who is responsible for establishing and managing the data recording system, the corporate identity information of EDS Enjeksiyon Dokum San. Tic. A.S., which is the “Data Controller” under the KVKK, is as follows:

Trade Registry No: 11158
MERSIS No: 0324004194600025
Tax Number: 3240041946
Address: Cumhuriyet Mah. Cihan Sok. No:3 41420 Cayirova / KOCAELI
Telephone: (+90) 262 658 08 72
Fax: (+90) 262 658 08 76
Website: www.edsdokum.com.tr
E-mail Address: elifakgun@edsdokum.com.tr
KEP Address: edsdokum@hs01.kep.tr

3.2 Collection, Processing and Purposes of Processing Personal Data
For visitors: Name-surname, visual data (security camera records), license plate and driver information (such as name-surname) of vehicles that will load/unload within workplace boundaries.

For subcontractors: Name-surname, SSI employment entry declaration (for the most recent month), occupational safety training certificate, examination notification form for subcontractor employees, professional competence certificate, criminal record, Turkish ID number, visual data (security camera records).

The specified personal data is/may be collected by automatic or non-automatic methods, verbally, in writing, visually or electronically. Your personal data may be processed by our Company without harming your fundamental rights and freedoms in cases expressly stipulated by law, for the establishment or performance of a contract, fulfillment of our legal obligations, establishment, exercise or protection of a right, and protection of our legitimate interests.

In the cases listed in Articles 5.2 and 6.3 of the Law, your personal data and special categories of personal data may be processed without your explicit consent.

Personal data is obtained, processed and stored for the following reasons and purposes:
- Creating and tracking visitor records,
- Sending electronic communications (SMS, e-mail, etc.) to inform personal data subjects,
- Carrying out commercial and legal activities and executing related business processes and ensuring the security of these relationships,
- Planning and/or executing occupational health and/or safety processes,
- Planning logistics activities,
- Preparing all records and documents that will serve as the basis for processing in electronic or paper environments,
- Complying with information retention, reporting, notification and similar obligations prescribed by legislation and relevant public institutions,
- Planning and carrying out corporate communication and corporate management activities,
- Carrying out information security management services,
- Monitoring and auditing finance and accounting affairs,
- Providing the requested products and services,
- Fulfilling the requirements of the concluded contract and ensuring the monitoring of contractual obligations,
- Carrying out pricing and invoicing activities,
- Ensuring security measures and audits.

3.3 To Whom and for What Purposes Processed Personal Data May Be Transferred Domestically and/or Abroad
Your collected personal data may be transferred by our Company to enable you to benefit from the products and services provided by our Company, for the necessary work to be carried out by our business units, to administrative and official authorities to which transfer is legally required, to relevant persons and institutions as required by legislation and for the fulfillment of legal obligations, to independent audit companies, tax advisors and other external professional consultants, lawyers, insurance companies, partners, domestic and foreign third parties from whom services are or will be received, legally authorized public institutions and private persons, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK and other applicable legislation.

Your collected personal data may be transferred to foreign countries announced by the Personal Data Protection Board as having adequate protection, under the conditions specified in Articles 5/2 and 6/3 of the Law (“Foreign Country with Adequate Protection”), or, in the absence of adequate protection, to foreign countries where the data controllers in Turkey and in the relevant foreign country undertake in writing to provide adequate protection and where the permission of the Personal Data Protection Board exists (“Foreign Country Where the Data Controller Undertaking Adequate Protection Is Located”).

Our Company acts/will act in compliance with the provisions stipulated in Article 9 of the KVKK and other applicable legislation in this regard.

3.4 Method and Legal Basis of Personal Data Collection
Your personal data is obtained for the purposes stated in Article 2 and within the scope of fulfilling our obligations and protecting our legitimate interests, by automatic or non-automatic methods, through cameras located in our company and through other channels by which our Company contacts or may contact you in the future. The personal data obtained is preserved and stored for legal periods in accordance with the relevant legislation.

3.5 Rights of the Personal Data Subject Under Article 11 of the KVKK
As personal data subjects, if you submit your requests regarding your rights to our Company through the methods set out below in this Disclosure Text, our Company will conclude the request free of charge as soon as possible and no later than thirty days, depending on the nature of the request. However, if a fee is prescribed by the Personal Data Protection Board, the fee in the tariff determined by our Company will be charged.

In this context, personal data subjects have the following rights under Article 11 of the KVKK: to learn whether their personal data is being processed; to request information if it has been processed; to learn the purpose of processing their personal data and whether it is used in accordance with that purpose; to know the third parties to whom their personal data has been transferred domestically or abroad; to request correction if personal data has been processed incompletely or incorrectly; to request deletion or destruction of personal data if the reasons requiring its processing cease to exist, subject to an evaluation under the principles of purpose, duration and legitimacy; to request notification of correction, deletion or destruction operations to third parties to whom personal data has been transferred; to object to a result arising against them through analysis of processed personal data exclusively by automated systems; and to request compensation for damages if they suffer damage due to unlawful processing of personal data.

Pursuant to paragraph 1 of Article 13 of the KVKK, you may submit your request regarding the exercise of the above-mentioned rights to our Company in writing or by other methods determined by the Personal Data Protection Board. The channels and procedures through which you may submit your written application to our Company under Article 11 of the KVKK are explained below:

To exercise the above-mentioned rights, submit your request containing the necessary information to identify you and your explanations regarding the right you request to exercise under Article 11 of the KVKK. After filling out the application form available at www.edsdokum.com.tr, send one wet-signed copy to Cumhuriyet Mah. Cihan Sok. No:3 Cayirova-KOCAELI in person, by post, through a notary, or electronically to elifakgun@edsdokum.com.tr or edsdokum@hs01.kep.tr.

CONTACT INFORMATION
EDS Enjeksiyon Dokum Sanayi ve Ticaret A.S.
Address: Cumhuriyet Mah. Cihan Sok. No:3 Cayirova-KOCAELI
MERSIS No: 0324004194600025