CLARIFICATION TEXT ON PERSONAL DATA

We, ASG GRUP YATIRIM A.Ş. aspect cautious stance on your personal data safety. In this context, we attach great importance to the processing and preservation of all personal data belonging to all persons associated with the Company in accordance with the Law on the Protection of Personal Data No. 6698 (KVKK). As a result of our responsibility described as “KVKK” operate your personal data as “data controller” and according to “KVKK” principles of proportionality, limitation, and connection with the purpose. We would like to inform you as data controller.

1. WHAT IS PERSONAL DATA

Personal data is all information about identified or identifiable person. Any data considered as personal data must be belong to real person and this person must be considered identified or identifiable.

Personal data could be saved and processed data related to identified or identifiable real person (For example: ID Number, IP address, Name, Surname etc.) or reports (For example CVs, payroll, invoices, bank statements, credit card statements, copies of identity cards), writings (For example letters, invitations) considered personal data as well.

2. WHAT IS PERSONAL DATA PROCESSING?

Processing of personal data is any operation performed on data such as obtaining, recording, storing, preserving, modifying, reorganizing, disclosing, transferring, taking over, making available, classifying, or preventing the use of personal data by fully or partially automatic or non-automatic means if it is part of any data recording system.

3. PURPOSE OF PROCCESING PERSONEL DATA AND HOW WE PROCCES PERSONEL DATA?

Personal data can differ services provide by ASG GRUP YATIRIM A.Ş.  and ASG GRUP YATIRIM A.Ş.’s commercial activities; with automatic or non-automatic methods ASG GRUP YATIRIM A.Ş.  departments and offices, business associated companies, suppliers, web site, social media, mobile apps, and familiar tools verbal, written or electronic collect and can be process. ASG GRUP YATIRIM A.Ş.  update and process your personal data for determine your needs, respond your requests faster if our employe partnership continues or use our products and benefit our services.

Moreover, we process your personal data when you enter our website or visit ASG GRUP YATIRIM A.Ş.  to use ASG GRUP YATIRIM A.Ş.  services, organizations, and seminars.

Collected personal data to be used for improving products and services provided by ASG GRUP YATIRIM A.Ş. Personal data to be used for conducting user satisfaction survey, improve and diverse ASG GRUP YATIRIM A.Ş.  services. Along with these personal data process for conduct stipulated laws and regulations and according to KVKK law article 5 and 6 necessary quality and standard controls will be conducted.

Our employee’s data process by legal entity or authorized true person or ASG GRUP YATIRIM A.Ş.  partner s or ASG GRUP YATIRIM A.Ş. This entities process data because of our obligations stipulated by legislations at the same time human resources policy and improve employee satisfaction and work safety and ensuring friendly workplace environment.

4. CONDITIONS OF PROCCESED PERSONEL DATA SHARING POLICY

Your personal data can be shared within ASG GRUP YATIRIM A.Ş.  with our subsidiaries and affiliates, in accordance with the legislation, especially the Turkish Constitution and KVKK, within the above-mentioned purposes and without limitation. Personal data, including but not limited to those listed, may be shared with our business partners, suppliers, Company officials, shareholders, legally authorized public institutions, and private individuals, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVK Law. Within the scope of this sharing, personal data may be transferred to the within country or abroad.

5. PERSONEL DATA HOLDERS RIGHTS ACCORDING TO KVKK ARTICLE 11

Natural persons whose personal data are processed have the following rights within the scope of Article 11 of KVKK.

  • Learning whether personal data is processed or not,
  • Request information if their personal data has been processed,
  • To learn the purpose of processing personal data and whether they are used for their intended purpose,
  • To know the third parties to whom personal data are transferred domestically or abroad,
  • To request correction of personal data in case of incomplete or incorrect processing and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
  • To request the deletion or destruction of personal data if the reasons requiring its processing disappear, although it has been processed in accordance with the provisions of the KVKK and other relevant laws, and to request notification of the transaction made within this scope to third parties to whom personal data is transferred,
  • To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
  • In case of damage due to unlawful processing of personal data, to demand the compensation of the damage.

As personal data owners, if you submit your requests regarding your rights to our ASG GRUP YATIRIM A.Ş.  by the methods specified in this Clarification Text, ASG GRUP YATIRIM A.Ş.  will finalize 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 a fee is stipulated by the Personal Data Protection Board or if the transaction requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board will be charged by us.

Pursuant to paragraph 1 of Article 13 of the KVK Law, you can submit your request to exercise your rights mentioned above to ASG GRUP YATIRIM A.Ş.  in writing or by other methods to be determined by the Personal Data Protection Board. In this context, the channels, and procedures you will submit your written application to ASG GRUP YATIRIM A.Ş. within the scope of Article 11 of the KVKK are explained below.

To exercise your rights mentioned above, you may fill in the Data Owner Application Form at www.asggrup.com and send a signed copy of the form to ASG GRUP YATIRIM A.Ş. with documents identifying your identity with wet signature, by registered letter with return receipt or through a notary public or by other methods specified in the KVKK, or you may send the relevant form to info@asggrup.com with secure electronic signature.

In the application that you have as a personal data owner and that you will make in order to exercise your rights mentioned above and that includes your explanations regarding the right you request to exercise; the matter you request must be clear and understandable, the subject you request must be related to your person or if you are acting on behalf of someone else, you must be specifically authorized in this regard and document your authority, it must also contain identity and address information and documents certifying your identity must be attached to the application.

We kindly request your information.