ALTUN GIDA ANONİM ŞİRKETİ

PERSONAL DATA PROTECTION AND PROCESSING POLICY

DEFINITIONS

Personal Data Any information relating to an identified or identifiable natural person.
Special Categories of Personal Data Data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs,
appearance and dress, association, foundation or trade union membership, health, sexual life, criminal conviction,
security measures, as well as biometric and genetic data are special categories of personal data.
Explicit Consent Consent that is based on information, given freely and relates to a specific subject.
Anonymisation Making personal data impossible to associate with an identified or identifiable natural person in any way, even by
matching it with other data.
Processing of Personal Data Any operation which is performed on personal data, whether or not by automatic means, such as collection, recording,
storage, preservation, alteration, re-organisation, disclosure, transfer, acquisition, making available, classification
or preventing the use of personal data, provided that it is part of a data recording system, in whole or in part.
Board Personal Data Protection Board
Policy Altun Gıda A.Ş. Personal Data Protection Policy
Data Controller The person who determines the purposes and means of processing personal data and manages the place where the data
are kept in a systematic manner.
Data Processor Any natural or legal person who processes personal data on behalf of the data controller, on the basis of the
authority granted by the data controller.
  1. SECTION

1.1. INTRODUCTION

First and foremost, we would like to state that as the Altun Gıda A.Ş. family, we have built our company policy on trust, loyalty and transparency. In this respect, the protection of personal data is considered one of our company’s most important priorities. This Policy has been prepared in order to determine the fundamental principles and implementation rules to be adopted to ensure compliance with the obligations introduced by the Personal Data Protection Law. This Policy explains the principles for the processing of personal data that need to be known by natural persons whose personal data we process. As our esteemed producers/employees/employee candidates, you share your personal data with us through your visits to our website, your submission of CVs and other means.

This Policy provides information regarding the methods of collection of your data, the purposes for which they are used, how long they are retained by us, our obligations, your rights, the transfer processes of your personal data, as well as the anonymisation, deletion and protection of your data. By approving this Policy, your explicit consent is deemed to have been given.

Pursuant to the Constitution of the Republic of Türkiye, everyone who owns personal data has the right to request the protection of such data. With regard to the protection of personal data, which is a constitutional right, Altun Gıda has adopted as a principle that it will exercise due care in protecting the personal data of its producers/employees/employee candidates/visitors through this Policy. Within this principle and in accordance with the relevant legislation, our company takes the necessary administrative and technical measures for the protection of personal data that it processes.

The basic principles adopted by our company in the processing of personal data within the scope of this Policy are as follows:

  • To process your personal data lawfully and in good faith,
  • To keep your personal data accurate and up to date,
  • To process your personal data for specific, explicit and legitimate purposes,
  • To process your personal data in a manner that is relevant, limited and proportionate to the purposes for which they are processed,
  • To retain your personal data for the period stipulated in the relevant legislation or required for the purposes for which they are processed,
  • To inform and enlighten personal data subjects,
  • To establish the necessary system to enable personal data subjects to exercise their rights,
  • To take the necessary measures for the preservation of your personal data,
  • To act in accordance with the relevant legislation and the regulations of the Personal Data Protection Board when transferring your personal data to third parties in line with the requirements of the processing purpose,
  • To show particular sensitivity in the processing and protection of special categories of personal data.

1.2. PURPOSE OF THE POLICY

The main purpose of this Policy is to inform you, as the Altun Gıda A.Ş. family, that the personal information you have shared with us is protected and secured on the basis of confidentiality principles in accordance with the Personal Data Protection Law.

1.3. SCOPE

This Policy covers all personal data of our producers/employees/employee candidates that are processed by automatic means or by non-automatic means provided that they are part of any data recording system.

1.4. APPLICATION OF THE POLICY AND THE RELEVANT LEGISLATION

With regard to the processing/anonymisation of your personal data and similar issues, the relevant legal regulations and legislation shall primarily apply. In the event of any inconsistency between this Policy and the relevant legislation, the provisions of the applicable legal regulations, legislation and decisions of the Personal Data Protection Board shall apply. In the event of changes or amendments to the legal legislation, Altun Gıda A.Ş. will act in accordance with the statutory periods foreseen in the Personal Data Protection Law (KVKK) and carry out the necessary preparations accordingly.

1.5. EFFECTIVENESS OF THE POLICY

This Policy prepared by our Company is dated 11/12/2019. In case the Policy as a whole or certain articles of it are renewed, the effective date of the Policy will also be updated.

The Policy is published on our Company’s website at
http://www.altungida.com/tr/kurumsal/58/kisisel-verilerin-korunmasi-kanunu.
It is made available to relevant persons upon request of personal data subjects.

 

  1. SECTION

2 – MATTERS RELATING TO THE PROTECTION OF PERSONAL DATA

Altun Gıda, in accordance with the Personal Data Protection Law, processes personal data and takes all necessary administrative and technical measures and carries out or has carried out the necessary audits in order to prevent unlawful processing, prevent unlawful access and ensure the preservation of the data.

2.1. ENSURING THE SECURITY OF PERSONAL DATA

Altun Gıda takes the necessary legal, technical and administrative measures regarding data security in the issues specified below. Since this matter is among the priorities of our company, the highest level of care and diligence is exercised. The measures taken by our Company as the data controller to ensure “data security” pursuant to the Personal Data Protection Law are as follows:

  • Our Company takes technological, technical and administrative measures in order to ensure that personal data are processed lawfully. Employees have been informed that they may not process the personal data they have learned contrary to the provisions of the Personal Data Protection Law, that they may not disclose, transfer or use such data for purposes other than processing, and that this obligation will continue even after they leave their position. In this respect, undertakings are obtained from them.
  • Our Company takes technological, technical and administrative measures within its technological means to prevent the negligent or unauthorised disclosure, access, processing, transfer or any other unlawful processing of personal data.
  • As the data controller, our Company contractually imposes on the institutions acting as data processors, with which it has various relationships such as producer, the obligation to comply with the legal, administrative and technical measures developed regarding the obligations to be observed when processing personal data, in accordance with the nature of the data-processing activity they perform.
  • Our Company takes technological, technical and administrative measures to ensure that personal data are stored in secure environments and to prevent their unlawful destruction, loss, classification or alteration.
  • Our Company carries out or has carried out the necessary audits within its body in accordance with the Personal Data Protection Law. Activities are conducted to improve the measures taken.
  • In the event that the processed personal data are obtained by others by unlawful means, this situation will be reported to the relevant personal data subject and the Personal Data Protection Board as soon as possible in accordance with Article 12 of the Personal Data Protection Law.
  • How data security is ensured by us with respect to the personal data of employees and persons applying by CV.

2.2. RESPECTING THE RIGHTS OF THE DATA SUBJECT

Our Company establishes and maintains the necessary mechanisms, internal functioning and administrative and technical arrangements in accordance with the Personal Data Protection Law in order to evaluate the rights of personal data subjects and to provide them with the necessary information.

Where personal data subjects submit their requests relating to their rights listed below to our Company in writing, our Company finalises the request free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the operation requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board may be charged by our Company. Personal data subjects have the right to:

  • Learn whether personal data are processed,
  • Request information if personal data have been processed,
  • Learn the purpose of the processing of personal data and whether they are used in accordance with that purpose,
  • Know the third parties to whom personal data are transferred at home or abroad,
  • Request the rectification of personal data if they are incomplete or incorrectly processed and request that third parties to whom the personal data have been transferred be informed of the correction,
  • Request the deletion or destruction of personal data in the event that, although they have been processed in accordance with the provisions of the Personal Data Protection Law and other relevant laws, the reasons requiring their processing no longer exist, and request that third parties to whom the personal data have been transferred be informed of the deletion or destruction,
  • Object to a result arising to their detriment as a result of analysis of the processed data exclusively through automated systems,
  • Request compensation for any damage incurred due to unlawful processing of personal data.

Pursuant to the Personal Data Protection Law, you must submit your request to exercise your rights specified above “in writing” or by using other methods determined by the Personal Data Protection Board to our Company. Since the Personal Data Protection Board has not yet determined any method at this stage, you must submit your application to our Company in writing.

You can submit your request containing your explanation regarding the right you wish to exercise under the Personal Data Protection Law by filling in the form available at
http://www.altungida.com/tr/insan-kaynaklari,
and delivering a signed copy of the form together with documents identifying your identity by hand to the address
“E-5 Karayolu (Çay Cad.) Yeşilköy Mah. No:30/A Dörtyol/Hatay”.
If you wish, you may also send it via a notary public or by other methods specified in the Personal Data Protection Law, or you may send the relevant form signed with a secure electronic signature to
altun.gida@hs02.kep.tr.

2.3. PROTECTION OF SPECIAL CATEGORIES OF PERSONAL DATA

The Personal Data Protection Law attaches special importance to certain personal data because, if processed unlawfully, there is a risk that people may suffer victimisation, discrimination or be subjected tLS����