Personal Data Protection Law

YÜKSEL TOPRAK GIDA LIVESTOCK TURİZM MAK. SINGING. VE TİC. Inc. PROCESSING AND PROTECTION OF PERSONAL DATA POLICY

INTRODUCTION

In accordance with the Law No. 6698 on the Protection of Personal Data (“Law”); This is YÜKSEL TOPRAK GIDA HAYVANCILIK TURİZM MAK. SINGING. VE TİC. Inc. (will be referred to as the “COMPANY”) Personal Data Processing and Protection Policy (“Policy”) regulates the procedures and principles that must be followed by the (“COMPANY”) in fulfilling its obligations regarding the protection and processing of personal data.

1-PURPOSE and SCOPE

It is aimed to maintain the principle of conducting the “COMPANY” activities in a transparent manner. In this context, the basic principles adopted in terms of compliance of the COMPANY's data processing activities with the regulations in the Personal Data Protection Law No. 6698 ('KVK Law') are determined and the practices implemented by the 'COMPANY' are explained.

The policy determines the processing conditions of personal data and sets out the main principles adopted by the processing of personal data (“COMPANY”). In this framework, the Policy is for real persons whose personal data are processed, where all personal data processing activities within the scope of the Law are carried out automatically or non-automatically provided that they are part of any data recording system of the company.

The "COMPANY" reserves the right to make changes in the "Policy" in parallel with the legal regulations.

Company YÜKSEL TOPRAK GIDA HAYVANCILIK TURİZM MAK. SAN. VE TİC. A.Ş.

Personal Data/Data

Any information relating to an identified or identifiable natural person.

Special Qualified Personal Data

Data on race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, dress, association, foundation or union membership, health, sexual life, criminal conviction and security measures, and biometric and genetic data.

Processing of Personal Data

Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making Personal Data fully or partially automatic or non-automatic, provided that it is a part of any data recording system,It is all kinds of operations performed on data such as classification or prevention of use.

Third Parties and persons whose personal data are processed by the "COMPANY".

The third parties are natural persons who are related to the "COMPANY" with the above-mentioned parties in order to ensure the security of commercial transactions or to protect the rights of the aforementioned persons and to obtain benefits. Joint debtor (Guarantor, Promissory Note Debtor) Companion, Family Members and their relatives can be given as examples to these people.

Personal Data Owner/Relevant Person

“COMPANY” means its Stakeholders and Employees, Business Partners, Authorities, Employee Candidates, Visitors, and Group Customers, Potential Customers, Third Parties and persons whose personal data is processed.

Data Recording System

It refers to the recording system in which personal data is processed and structured according to certain criteria.

Data Controller

It is the natural or legal person who determines the purposes and methods of processing personal data and is responsible for the establishment and management of the data recording system.

Data Processor

It is the natural and legal person who processes personal data on behalf of the data controller based on the authority given by the data controller.

Open Consent

It is the consent of a particular subject, based on information and expressed with free will.

Anonymization

It is to make the data previously associated with a person incapable of being associated with an identified or identifiable natural person under any circumstances, even by matching them with other data.

Law

Refers to the Law on Protection of Personal Data No. 6698.

KVK Board

It is the Personal Data Protection Board.

1.2. Enforcement and Change

The policy was published on the website by the “COMPANY” and presented to the public. In case of conflict with the legislation in force, especially the Law, and the regulations included in this Policy, the provisions of the legislation shall apply.

“COMPANY” reserves the right to make changes in the Policy in line with the legal regulations. The current version of the Policy can be accessed from the "COMPANY" website

2. PERSONAL DATA AND DATA OWNERS, DATA PROCESSING PURPOSE AND DATA CATEGORIES

2.1. What Are Your Personal Data?

Personal data means information that identifies or makes it identifiable. The categories of your personal data that can be processed by the "COMPANY" are listed below.

2.2. Data Subject Categories

Data subjects within the scope of the policy are all natural persons whose personal data are being processed by the COMPANY. In this context, the categories of data subjects are as follows:

DATA OWNER CATEGORIES EXPLANATION

Working

"COMPANY" refers to real persons who perform services with an employment contract.

Intern

“Real persons working as interns in the COMPANY

Employee Candidate

It refers to real persons who apply for a job by sending a CV to the "COMPANY" or by other methods.

Third Parties

It refers to real persons excluding the categories mentioned above and the employees of the “COMPANY”.

Business Partners/Shareholders/ Supplier companies and their employees

Parties with which the "COMPANY" has established business partnerships for purposes such as the execution of its commercial activities or, in this context, who provide goods or services to the "COMPANY" in accordance with the instructions of the "COMPANY" and on a contractual basis, and the employees of these parties

Visitor

It refers to the real persons who visit the campus and website of the "COMPANY".

Customer

It refers to the real persons who benefit from the products and services offered by the Company.

Potential Customer

It refers to real persons who show interest in using the products and services offered by the Company and have the potential to become customers.

Data subject categories are specified for general information sharing purposes. The fact that the data owner does not fall under any of these categories does not remove the data owner's qualification as specified in the Law.

2.3. Personal Data Processing Purposes

For Employee Candidates;

With Shareholders/Business Partners/Suppliers

Within the scope of the commercial relationship between you and the "COMPANY", the personal data of your company officials and employees, as specified in Article 5 of the Law; The establishment and performance of our contracts can be processed within the scope of the following purposes, in accordance with the basic principles stipulated in the Law, within the scope of the fulfillment of legal obligations and the legitimate interests of the "COMPANY" and within the scope of personal data processing conditions.

For Customers;

For Visitors;

Within the scope of your visits to the "COMPANY", our website and other workplaces, your identity and visual data are processed in physical environments with security cameras and visitor logbooks, in order to ensure the security of the "COMPANY" and you, as well as to fulfill our legal obligations and to comply with our legitimate interests.

For those who call the Customer Service Line;

Personal data of the name-surname, contact (phone, address) information and voice recording shared by the “COMPANY” by the callers of the Customer service line;

3. PROCEDURES AND PRINCIPLES TO BE FOLLOWED IN THE PROCESSING OF DATA

3.1. Principles Regarding the Processing of Personal Data

Your personal data is processed by the "COMPANY" in accordance with the personal data processing principles set forth in Article 4 of the Law. It attaches importance to processing your personal data in accordance with the law and the rules of honesty, for data processing purposes only.

In order to ensure that the "COMPANY" personal data is correct and up-to-date, Data owners are entitled to request correction or deletion of their correct and outdated data.

The “COMPANY” makes the necessary assessments for the processing of personal data for specific, clear and legitimate purposes for each category of personal data subject.

Personal data is deleted, destroyed or anonymized by the "COMPANY" after the disappearance of the purpose of processing personal data or with the expiration of the period stipulated in the legislation, in order to ensure that personal data is kept for the period required by the legislation or the processing purposes.

3.2. Conditions Regarding the Processing of Personal Data

According to the "COMPANY", Article 5, Paragraph 2 and Article 8, Paragraph 2 of the KVKK, without the express consent of the personal data owner;

3.3. Conditions Regarding the Processing of Special Categories of Personal Data

In Article 6 of the Law, special categories of personal data are specified in a limited number. These; data on race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and clothing, membership in associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data.

The “COMPANY” may process your personal data of special nature in the following cases by taking the necessary precautions:

4. METHOD OF COLLECTING YOUR PERSONAL DATA AND LEGAL REASON

Your personal data; It is collected through all kinds of physical, audio and electronic media such as website visits, the establishment and execution of contracts, recruitment processes, your visits to our workplaces, and depending on the nature of the personal data and the purpose of processing, the 2nd paragraph of Article 5 of the Law and the following reasons for compliance with the law. (explained above), if there is no such reason, it will be collected based on your express consent. Your personal data may be collected, processed and transferred for the purposes specified in this Policy, based on the legal reasons listed below, by fully automatic, partially automatic or non-automatic methods.

5. TRANSFER OF PERSONAL DATA

In accordance with the additional regulations listed in Articles 8 and 9 of the KVK Law and determined by the Personal Data Protection Board; In case of conditions for the transfer of personal data, it can transfer personal data at home or abroad.

Transfer of personal data to third parties in the country, in the presence of at least one of the data processing conditions described in Articles 5 and 6 of the Law and explained under Title 3 of this Policy, and provided that it complies with the basic principles of data processing conditions, your personal data will be transferred to the "COMPANY". It can be transferred by

The transfer of personal data to third parties abroad, in cases where there is no explicit consent of the person, in the presence of at least one of the data processing conditions stated in Articles 5 and 6 of the Law and explained under Title 3 of this Policy, and in accordance with the basic principles regarding data processing conditions. Personal data can be transferred abroad provided that it is complied with. As of today's conditions, our COMPANY does not transfer abroad.

In accordance with the general principles of the Law and the data processing conditions in Articles 8 and 9, the "COMPANY" can transfer data to the following Real and Legal Persons.

6. DISCLOSURE AND RIGHTS OF DATA OWNERS

As a personal data owner, we declare that you have the following rights in accordance with Article 11 of the Law:

7. ENSURING THE SECURITY AND CONFIDENTIALITY OF PERSONAL DATA

In order to prevent the unlawful disclosure, access, transfer of personal data or security deficiencies that may occur in other ways, the "COMPANY" takes all necessary measures, within the possibilities, according to the nature of the data to be protected. In this context, all necessary administrative and technical measures are taken by the "COMPANY", an audit system is established within the "COMPANY" and in case of unlawful disclosure of personal data, it acts in accordance with the measures stipulated in the Personal Data Protection Law.

8. DISPOSAL OF PERSONAL DATA

A DISPOSAL POLICY, which determines the methods of disposal of personal data, has been prepared and published on the website of the "COMPANY" (www.yukselkiremit.com). All disposal processes are carried out in accordance with this policy. Although it has been processed in accordance with the law in accordance with Article 7 of the Law, in the event that the reasons requiring its processing disappear, the "COMPANY", ex officio or upon the request of the Relevant Person, may comply with the Data protection and destruction policy, legislation and "COMPANY" that it has specially prepared for this business. destroys in accordance with the guide published by ”.

9. ISSUES REGARDING THE PROTECTION OF PERSONAL DATA

"COMPANY"; In accordance with Article 12 of the KVK Law, to prevent the unlawful processing of the personal data it is processing and to prevent the data from being accessed illegally.It takes the necessary technical and administrative measures to ensure the appropriate level of security in order to ensure the protection of data and data, and within this scope, it makes or has the necessary inspections made. The “COMPANY” takes technical and administrative measures according to technological possibilities and implementation costs in order to ensure that personal data is processed in accordance with the law.

9.1.Technical Measures

The administrative measures taken by the COMPANY for the legal processing of personal data are listed below.

9.2. Administrative Measures

The administrative measures taken by the "COMPANY" for the legal processing of personal data are listed below:

10. CONTACT

You can send your applications regarding your rights listed above by filling out the Related Person Application Form, which you can access on our website with the extension (www.yukselkiremit.com) or with another written document with the same content, to the address of our "COMPANY" stated below. For comprehensive information on the principles of protection and processing of your personal data, you can review the Personal Data Processing and Protection Policy at (www.yukselkiremit.com). You can send all your requests in writing to the postal addresses listed below.

In case the data owners (relevant persons) submit their requests regarding their personal data to the "COMPANY" in writing, the "COMPANY" as the data controller, in accordance with Article 13 of the KVK Law, as soon as possible and within thirty (30) days at the latest, depending on the nature of the request. carries out the necessary processes to ensure its conclusion.

Within the scope of ensuring data security, the “COMPANY” may request information in order to determine whether the applicant is the owner of the personal data subject to the application. The “COMPANY” may also ask questions about the application of the Related Person in order to ensure that the application is concluded in accordance with the request.

The application of the person concerned; In cases where there is a possibility of impeding the rights and freedoms of other persons, requiring disproportionate effort, and the information is publicly available, the request may be rejected by the "COMPANY" by explaining the reason.

YÜKSEL TOPRAK GIDA HAYVANCILIK TURİZM MAK. SAN. VE TİC. A.Ş.

Address: Ak Kent Mah. Çevre Yolu Bulvarı No: 192 / MERKEZ ÇORUM

Telephone: +90.364 225 01 38 – 39

Gsm: 0533 772 35 27

E-Mail: yukselkiremit@hotmail.com

Web Address: www.yukselkiremit.com

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