It is important to process and preserve personal data and/or special personal data in accordance with Law No. 6698 on the Protection of Personal Data (“KVKK” or “Law”). Therefore, as CABİR Holding A.Ş. (“CABİR HOLDİNG”), we act in accordance with KVKK regarding the protection, preservation, and processing of your personal data and/or special personal data.

This information text has been prepared by CABİR HOLDİNG, acting as the data controller, within the scope of Article 10 of the Personal Data Protection Law No. 6698 and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Information Obligation.

LEGAL BASIS

Law No. 6698 on the Protection of Personal Data requires that individuals whose data are being processed be informed before any data processing activity is undertaken. This issue, known as the Obligation to Inform, is stipulated in Article 10 of the Law on the Protection of Personal Data as follows: “When obtaining personal data, the data controller and their authorized person are obliged to inform the relevant persons about the identity of the data controller and their representative, if any, the purpose for which personal data will be processed, to whom and for what purpose the processed personal data may be transferred, the method and legal basis for collecting personal data, and their other rights listed in Article 11.” Article 3 of this Law defines the data controller as “the natural or legal persons who determine the purposes and means of processing personal data and are responsible for the establishment and management of the data recording system.” In this context, the data controller is CABİR Holding, whose website you are visiting. The information about the data controller is as follows.

Data Controller: Cabir Holding A.Ş.

Address: Yenibosna Merkez Mahallesi, Ladin Sokak No: 63, Bahçelievler, Istanbul

Phone: +90 (212) 659 72 95

Email: [email protected]

PURPOSES OF PROCESSING YOUR DATA BY CABİR HOLDİNG

Your personal data is processed within the limits stipulated by Personal Data Protection Law No. 6698 and based on the principles of the law. As CABİR HOLDİNG, our data processing purposes within the framework of the law are;

• To improve the quality of products and services offered to you, to quickly inform you about innovations and products and services offered by CABİR HOLDİNG, to identify personalized needs and intended uses, and to offer tailored goods and services to you, our customers,
• CABİR HOLDİNGto fulfill legal and administrative obligations and resolve legal disputes,
• Carrying out all necessary work to enter into and execute contractual relationships,
• Creating policies, meeting needs, and conducting recruitment processes, particularly regarding human resources, 
• Carrying out CABİR HOLDİNG’s commercial activities and ensuring complete performance for you in this context,
• To inform you about our changing and developing products and services and to provide clarification when necessary,
• To ensure that you benefit most from the products and services offered by our company,
• As CABİR HOLDİNG, to develop, define, and establish a secure foundation for our commercial partnerships and strategies, and to make the right decisions in our commercial policies and administrative operations,
• As CABİR HOLDİNG, to establish a solid foundation for our corporate identity and ensure corporate functioning, to achieve the objectives of our internal policies and thus to increase customer satisfaction,
• Ensuring physical space security, creating and monitoring visitor records,
• Ensuring information security,
• To improve the goods and services offered online by CABİR HOLDİNG,
• To communicate with those who submit requests and complaints to CABİR HOLDİNG, 

PRINCIPLES FOR PROCESSING YOUR DATA

1. To be stored for the period prescribed by the relevant legislation or necessary for the purpose for which they are processed;
2. To process in accordance with the law;
3. To keep the data up-to-date;
4. To act in accordance with the rules of integrity;
5. Not to be used for purposes other than those for which they are processed;
6. To be proportionate and limited to the purposes for which they are processed;
7. To process in accordance with general morality, customs, and traditions;
8. To process in accordance with all relevant legislation, especially the provisions of the Personal Data Protection Law No. 6698. As CABİR HOLDİNG, we have adopted the principle of;.

METHOD OF COLLECTING YOUR DATA AND LEGAL REASON

Your personal data is collected in all forms, verbally, in writing, or electronically, in accordance with the purposes outlined above, to enable CABİR HOLDİNG to provide the products and services we offer within the legal framework and to fully and accurately fulfill our contractual and legal obligations. Your personal data collected for these legal reasons is processed and transferred in accordance with Article 5 of the Personal Data Protection Law (KVKK). CABİR HOLDİNG may process and transfer special categories of data in accordance with Article 6 of the KVKK, provided that it complies with legal requirements.

TRANSFER OF DATA

Your data is transferred to third parties when necessary, in accordance with Personal Data Protection Law No. 6698 and the terms of our confidentiality agreements. However, in all circumstances, CABİR HOLDİNG complies with Articles 8 and 9 of Law No. 6698 when transferring data.

Personal data may be obtained by CABİR HOLDİNG directly from conversations; through written, verbal, and electronic means such as call centers, websites, social media platforms, mobile applications, and similar means; and may also be obtained verbally, in writing, or electronically from institutions and legal entities with which CABİR HOLDİNG has business relationships (including, but not limited to, business partners, suppliers, agencies, agents, subcontractors, contractors, consultants). This information may also be obtained during training, seminars, or events organized by CABİR HOLDİNG or organized by third parties outside of CABİR HOLDİNG at its workplaces and projects. Personal data may be retained for the period accepted in CABİR HOLDİNG’s relevant policies or stipulated in the legislation.

Collected personal data may be shared with CABİR HOLDİNG’s affiliates and subsidiaries, business partners, suppliers, authorized public institutions and organizations pursuant to Article 8 of the Personal Data Protection Law (KVKK) for the purposes of achieving the aforementioned processing purposes, enabling users to benefit from the products and services offered by CABİR HOLDİNG, customizing and offering services tailored to preferences, usage habits, and needs, ensuring legal, physical, and commercial security, improving and monitoring the quality of services, evaluating services, developing business strategies and policies, and complying with legal regulations.

Your personal data may be shared with affiliates and subsidiaries, business partners, suppliers, authorized public institutions and organizations with headquarters, branches, workplaces, operations, or data storage units abroad, pursuant to Article 9 of the KVKK, for the purposes listed in the previous paragraph.

At CABİR HOLDİNG, we take the necessary technical and administrative measures to prevent the transfer of data to unauthorized third parties, primarily in accordance with relevant legal provisions. In this context, we specifically align our internal company policies with the Personal Data Protection Law and maintain all technical software and hardware necessary to protect personal data. To ensure this, we strive to prevent both our employees and the third parties we work with from violating our Privacy Policy.

YOUR RIGHTS REGARDING THE PROTECTION OF PERSONAL DATA

Article 11 of Law No. 6698 on the Protection of Personal Data regulates the rights of data subjects. The law defines the data subject as the “relevant person” and provides for the right to make certain requests regarding the processing of their data.

In accordance with Article 11 of the Law, you may contact Cabir Holding using the methods listed in the “Contact” section of this Information Text.

• Learn whether your personal data is being processed,
• Request information about it if it has been processed,
• Learn the purpose of processing your personal data and whether it is being used for its intended purpose,
• To know the third parties to whom your personal data has been transferred, whether domestically or abroad,
• To request correction of personal data if it has been processed incompletely or incorrectly,
• To request the deletion or destruction of your personal data if the reasons requiring processing no longer exist, despite the data having been processed in accordance with the Law and other relevant legal provisions, and to request notification of the action taken within this scope to third parties to whom your personal data has been transferred,
• To object to the analysis of your processed personal data exclusively by automated systems, leading to a result detrimental to you,
• To request compensation for your damages if you suffer damages due to the unlawful processing of your personal data.e

You may submit your requests regarding your rights arising from the Personal Data Protection Law, as described above, to our company in accordance with the procedure specified in this Information Notice. CABİR HOLDİNG will respond to your requests as soon as possible, or within thirty days at the latest. Applications must be submitted by the data subject personally. CABİR HOLDİNG will only consider applications submitted by the data subject and share information about the applicant.

APPLICATION PROCEDURE

Requests regarding your rights specified above must be submitted in writing to CABİR HOLDİNG, acting as the data controller, via a notary public at Yenibosna Merkez Mah., Ladin Sk. No:63 Bahçelievler/İstanbul.

Requests sent to the email address must be submitted to [email protected] or [email protected] using the registered electronic mail (KEP) address, secure electronic signature, mobile signature, or the requestor’s registered electronic mail address with CABİR HOLDİNG.

Applications submitted under this scope will be processed as quickly as possible and within a maximum of 30 (thirty) days. If the information and documents submitted are incomplete, this period begins upon the complete submission of the information and documents. Applications in question are currently free of charge. However, if the process requires additional costs, a fee as determined by the Personal Data Protection Board may be charged.

Applications must be submitted in Turkish using the form provided in the annex of this Information Text, and the request must be written clearly enough to be understood without hesitation, and identification information and relevant documents and information must be attached to the application.