Personnel Clarification Text Under Law on Protection of Personal Data No. 6698

The Purpose and Scope of the Clarification Text

As AGRİTRADE TARIM ÜRÜNLERİ TİCARET LOJİSTİK VE DEPOCULUK LİMİTED ŞİRKETİ, we take measures for protection of your personal data under Law on Protection of Personal Data No. 6698 (hereafter referred to as “LPPD” or “Law”.). We process your personal data under LPPD or the relevant legal legislation as “data controller” due to following reasons and by following methods.

As per the 10th Article titled “Clarification Obligation of Data Controller” of LPPD, the Clarification Text about Processing Personal Data at AGRİTRADE TARIM ÜRÜNLERİ TİCARET LOJİSTİK VE DEPOCULUK LİMİTED ŞİRKETİ: was prepared to inform you as transparently as possible about the identity of the data controller, the method and legal reasons to collect your personal data, the purpose of processing these data, to whom and why there personal data are transferred, the period of time to process personal data and to inform you about your rights, stipulated in the 11th article of LPPD. The explanations made for you “Personal Data” in the clarification text also include your “Sensitive Personal Data”.

Data Controller

Company Title: AGRİTRADE TARIM ÜRÜNLERİ TİCARET LOJİSTİK VE DEPOCULUK LİMİTED ŞİRKETİ.

Address: AKDENİZ MAHALLESİ ATATÜRK CAD. NO: 152/78 KONAK/İZMİR

(The Data Controller shall be referred to as “the Company” or “Agritrade” within the scope of this clarification text.)

The Method and Legal Reason for Collecting Your Personal Data

Your personal data may be collected orally, in writing or electronically by automatic or non-automatic methods through camera recordings, software used to carry out the activities in the company, social media channels, the affiliated units of the Company. Your personal data may be processed by creating and updating it as long as your relationship with the Company continues and it can be stored both digitally and physically.

Your personal data are processed and transferred under the conditions to process personal data, for the purposes stated under the title “Your Processed Personal Data and the Purposes for Processing”, provided the explicit consent within the scope of the 1st paragraph of the 5th article of the Law No. 6698 is given and the following conditions stipulated in the 2nd paragraph of the 5th article are met;

a) If it is clearly stipulated in the laws,

c) If it is necessary to process personal data of the contracting parties, provided a contract is concluded or is directly related to the execution of the contract,

ç) If it is mandatory for the data controller to fulfill its legal obligation,

e) If data processing is mandatory to establish, exercise or protect a right,

f) If data processing is mandatory for the legitimate interests of the data controller, provided it does not damage the fundamental rights and freedoms of the person concerned,

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Your sensitive personal data, other than those related to health and sexual life, shall be processed for the purposes stated under the title “Your Processed Personal Data and the Purposes for Processing” provided the explicit consent within the scope of the 2nd paragraph of the 6th article of the Law No. 6698 is given and in cases stipulated in the 3rd paragraph of the 6th article. 

Your sensitive personal data related to your health information shall be collected for the purposes stated under the title “Your Processed Personal Data and the Purposes for Processing” provided the explicit consent within the scope of the 2nd paragraph of the 6th article of the Law No. 6698 is given and in order to enable the persons that are obligated o protect public health and to keep such information confidential as per the 3rd paragraph, as well as in order to ensure that protective medicine, medical diagnosis, treatment and care services are carried out and healthcare services and financing can be planned and managed.

Your Processed Personal Data and the Purposes for Processing

Your personal data are safely processed in accordance with Law on the Protection of Personal Data, due to legal obligations or to provide better services during transactions and procedures at the company.

In this context, the data stated in the table as personal data, are collected;

Identity: Set of data containing the information about a person’s identity.

(First Name, Last Name, Date of Birth/ Place of Birth, Social Identity/ Turkish ID Number, Mother’s Name, Father’s Name, Gender, Photo, Place of Birth, Age, Driver’s License, Social Security Institution Registration No, Nationality, Photo, Signature)

Contact: Set of data that can be used contact a person.

(Phone number, mail address, Resident Address)

Personal: This data category refers to the data types contained in the personnel personal data file.

(Social Security Institution Insured Employment Stated, Certificate of Professional Competence, Payroll Information, Resumé)

Physical Space Security: This data category refers to data types such as Employee entry and exit information, camera recordings.

(Image recording, Security Camera Image and Audio Recording)

Transaction Security: This data category refers to data types such as IP address information, Website login and logout information, and passwords.

(Security keys, Password, Usernames, Log records , IP Addresses)

Finance:  Set of data containing the financial information of a person.

(Bank Account Number, IBAN Information)

Professional Experience: Set of data containing information about a person’s profession (Information on the institution, where s/he works, work experience, course- certification information, vocational education information, diploma information, foreign language information,)

Audio-visual recordings: Set of data containing audio-visual data of a person.

(Photo and Camera Recording)

Health information: Set of data containing the health information of a person.

(Blood type, medical history, consultation report, method of administered treatment, type of disease, information on medications, medical values, test-anaylsis results)

Criminal Conviction and Security Measures: This data category refers to data types such as information on criminal convictions, information on security measures, et cetera.

(Data on criminal convictions and security measures, criminal record)

Training Data: Set of data containing personal education data.

(Diploma Grade, Diploma Information, Educational Institution Information)

Visa/Passport Data: Set of data containing visa and passport data of a person.

Your collected personal data shall be processed for following purposes;

• The necessary studies are conducted by our relevant business units, so that third party real and/or legal entities, institutions and organizations (employees, visitors, suppliers, business partners) that have a relationship with the company, can benefit from products and services of our company and of headquarters and units affiliated to our company,
• In order to ensure the life and property safety as well as legal, commercial and occupational safety of third party real and/or legal entities, institutions and organizations,
• In order to ensure discipline, safety and audits if you are physically present at the company headquarters or units where the company work is carried out, we store the camera recordings.
• In order to fulfill legal and regulatory requirements that arise/might arise from including but not limited to Labor Law No. 4857, Turkish Code of Obligations No. 6098, Vocational Training Law No. 3308, Occupational Health and Safety Law No. 6331, Law on Protection of Personal Data No. 6698, Tax Procedure Law No. 213, Social Insurance and General Health Insurance Law No. 5510, Law on Regulation of Publishing on Internet and Combating Crime Committed Through This Publishing No. 5651, Law on Private Healthcare Services No. 5188, Regulation on Processing Personal Health Data and Protection of Personal Privacy, Regulation on Archive Services and all the relevant laws and secondary regulations, and to take necessary measures within this scope,
• In order to carry out auditing and regulatory duties in authorized and commissioned public institutions and organizations, as well as professional organizations that are public institutions,
• In order to ensure the security of company operations,
• In order to conduct civil society and social activities for employees,
• In order to fulfill the requests for information and documents requested by judicial bodies and/or administrative authorities,
• In order to execute of all human resources processes and policies of our company,
• In order to plan, manage and invoice off all services offered,
• In order to train all the employees and for purposes of career development,
• In order to ensure the organizational work of employees that will be carried out between the company and its foreign partners,
• In order to fulfill the requests to participate in organizations, such as trainings, seminars, etc.
• In order to fulfill offer, promotion, exemption, rights and obligations offered by contracted private insurance companies and other institutions within the scope of agreements,
• In order to take all the technical and administrative measures that are necessary for system and applications within the scope of data security,

Your personal data shall be processed for conditions and purposes stated in the 5th and the 6th articles of Law No. 6698.

To Whom and For What Purpose Your Personal Data May Be Transferred

According to LPPD and the legislation, by ensured that all the necessary technical and administrative measures are taken to ensure the appropriate level of security, your personal data shall be transferred to the following for the purposes stated above;

· Persons/institutions and/or organizations permitted by the provisions of the other relevant legislation

· Private insurance companies, banks

· Lawyers or law partnerships for monitoring legal affairs

· Our direct/indirect domestic/international shareholders

· Our subsidiaries and/or affiliates

· Auditors

· Consultants

· Business partners

besides, in order to carry out our business activities, your personal data may be transferred to domestic/foreign institutions, to or from which we provide or buy services, with which we cooperate, within the framework of personal data processing conditions and purposes specified in the 8th and 9th articles of LPPD.

Data Processing Time and Retention Time

Your personal data shall be processed for purposes specified in this Clarification Text and they shall be processed by observing data processing and limitation periods stipulated in all the relevant laws and other legislations, to which our company and headquarters and units affiliated to our company are subject. In case of amendments to the data processing periods in the laws, the new periods determined shall be taken as a basis.

As a requirement of the principle of limitation to the purpose, your personal data are processed to fulfill the purposes described in this Clarification Text and in any case, it is only limited to the time required to process such data as per Company’s practices and business practices, upon expiration of this period of time, the data are deleted, destroyed or anonymized. In this context, the retention period of process-based personal data is as follows;

The Rights of the Person Concerned and Exercising These Rights

As the person concerned, you may send your requests within the scope of the 11th article of the Law regulating the rights of the person concerned, according to the “Communiqué on the Procedures and Principles of Applying to the Data Controller” to the address “AKDENİZ MAHALLESİ ATATÜRK CAD. NO: 152/78 KONAK/İZMİR”  in writing or electronically to the e-mail address  genel@agrilink.com.tr, provided that the e-mail address of the person concerned is registered, in order to exercise your rights. The comprehensive regulation in this context was issued in Agritrade Personal Data Application and Response Procedure You may request Agritrade Personal Data Application and Response Procedure via the e-mail address genel@agrilink.com.tr or you may obtain Agritrade Personal Data Application and Response Procedure at the address www.agritrade.com.tr.