KVKK

INFORMATION TEXT ON PROCESSING AND PROTECTION OF PERSONAL DATA

This Information Text and notification has been prepared by Alencast Alüminyum Enjeksiyon Döküm San. Ltd. Şti. ("Our Company") acting as the data controller, in order to inform you about the methods of collection, use, processing, storage, transfer and, if necessary, deletion of your personal data, to make explanations, to inform you, and to obtain your explicit consent statements in accordance with Law No. 6698 on the Protection of Personal Data ("KVKK") and related legislation.

Alencast Alüminyum (alencast.com) Website pays attention to keeping the information of its customers, visitors, employees and other third parties confidential.

Within the scope of this information text, the data controller, who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system, is Alencast Alüminyum Enjeksiyon Döküm San. Ltd. Şti.

A) Definitions

Explicit consent: Refers to the consent statement declared by data subjects based on information and free will regarding a specific subject.

Anonymization: Refers to making personal data unable to be associated with an identified or identifiable natural person in any way, even by matching with other data.

Data subject: Refers to the natural person whose personal data is processed.

Personal data: Refers to any information relating to an identified or identifiable natural person.

Special categories of personal data: Refers to data that is subject to a stricter protection regime under the Law, which may cause the Data Subject to be victimized or discriminated against in cases such as their disclosure or loss.

Processing of personal data: Refers to any operation performed on data such as obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making obtainable, classifying or preventing the use of personal data, which are processed completely or partially automatically or non-automatically as part of a data recording system.

Data recording system: Refers to the recording system where personal data are processed by being structured according to certain criteria.

Data controller: Refers to the natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

B) What is Personal Data?

Personal data is defined by KVKK as any information relating to an identified or identifiable natural person. Accordingly, your information such as your name, surname, e-mail address and phone number are called personal data.

C) Which Personal Data Do We Process?

The personal data we collect may vary depending on the nature of the legal relationship you have established with us. Your personal data collected through all channels, including digital environments, are categorically as follows.

• Identity information (your personal data such as name, surname, identity and passport number that you provided when creating an account on our website, when you applied, etc.)
• Contact information (your personal data such as e-mail address, phone number, mobile phone number, social media contact information, address when creating an account on the site, etc.)
• Education Information, (your personal data such as school, faculty, department graduated from, etc.)
• Visual and audio data (photographs, camera recordings, voice recordings, etc.)

D) Scope of Personal Data and Personal Data Processing Principles

"Acting in accordance with law and honesty rules", "Accuracy and up-to-dateness", "Processing data for specific, explicit and legitimate purposes", "Being relevant, limited and proportionate to the purposes for which they are processed", "Retaining for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed" are our basic principles regarding your personal data processing activities.

Alencast Alüminyum, as the Data Controller, in accordance with the legal obligations arising from Law No. 5202 on Defense Industry Security, Turkish Commercial Code No. 6102, KVKK, Labor Law No. 4857, Turkish Code of Obligations No. 6098, Turkish Penal Code No. 5237, Law No. 5651 on Regulation of Publications Made on the Internet and Combating Crimes Committed Through These Publications and other related legislation and regulations, in order to benefit from the activities, may obtain, record, store, update, rearrange, transfer to third parties in Turkey or abroad to the extent permitted by the legislation, and process personal data (name-surname, address, profession, education, marital status, date and place of birth, resume, e-mail, phone number, gender, vehicle license plate, location data opened when entering the website, IP address, all camera recordings within the perimeter and boundaries of Alencast Alüminyum's facilities, sharing with Alencast Alüminyum and when entering the website) by automatic or non-automatic methods, based on your explicit consent or in accordance with the relevant legislation mentioned above, including Law No. 5201 on Supervision of Industrial Establishments Producing War Materials and Weapons, Ammunition and Explosives and MSY 317-2 C Ministry of National Defense Defense Industry Security Directive, by taking necessary administrative and technical measures in other ways permitted by law.

These personal data; may be processed by taking all necessary information security measures, provided that they are not used outside the purposes and scope specified in this Alencast Alüminyum Information Text on Protection of Personal Data, based on your explicit consent or if it is expressly provided for in the laws, if it is necessary for the establishment or performance of the contract, if it is mandatory for the fulfillment of legal obligations, or if it is required by legitimate interests; will be stored for the legal retention period or for the period required by the processing purpose, and will continue to be used by our Organization after being anonymized at the end of the period required by the processing purpose, or will be destroyed in accordance with KVKK and related legislation.

Alencast Alüminyum shows maximum sensitivity regarding the security of your personal data and takes all necessary technical, administrative and legal measures to protect your personal data.

E) Data Controller and Representative

Alencast Alüminyum Company shows maximum sensitivity regarding the security of your personal data. With this awareness, it attaches great importance to the processing and storage of all kinds of personal data of all natural persons related to Alencast Alüminyum in accordance with Law No. 6698 on the Protection of Personal Data. Your personal data may be processed by Alencast Alüminyum as the data controller within the scope explained below.

F) Purposes of Processing Personal Data

Our Company may collect personal data in categories such as identity information, contact information, customer information, customer transaction information, transaction security information, legal transaction and compliance information, and marketing sales information from parties such as customers, employees, potential customers, job applicants, business partners and suppliers. Within the scope of the Personal Data transfer conditions specified in Articles 8 and 9 of the Personal Data Protection Law, your data may be processed by our Company for the purposes and legal reasons stated below, but not limited to these.

• To be able to address the Data Subject, to communicate with the Data Subject, to provide evaluation and meetings regarding the proposals and requests transmitted, to provide feedback regarding the proposals and requests transmitted;
• Performance of contracts concluded with the Data Subject, keeping and changing necessary records in this context;
• Performing accounting operations, opening current account records, making payments and tracking incoming payments, issuing & receiving Invoice, E-invoice and E-archive invoice/ Keeping in Accounting Records;
• Communication with the Data Subject and the company where the Data Subject works or represents, sending brochures, booklets, magazines, catalogs, price lists and other promotional and promotional documents and texts for the purpose of promoting our Company, our products, our activities and the sector in which we operate, sending price offers, sending price lists, providing permission processes related to these;
• Ensuring legal and commercial security;
• Use within the scope of profiling/segmentation studies, data enrichment, market research studies for the purpose of making the necessary studies to customize and recommend the products and services offered by our Company to personal data owners according to their preferences, usage habits and needs;
• Maintaining relations with public institutions and organizations and other organizations;
• Making image and sound recordings with security cameras for the purpose of ensuring security within the company;
• Evaluation of job applications submitted to us and providing feedback on them, verification of the accuracy of information submitted to us in job applications;
• Recording of calls made from our company phones for the purposes of examining and listening within the scope of quality standards, customer satisfaction follow-ups or any complaint, legal dispute or criminal proceedings;
• Processing of employee or candidate data within the scope of relevant legislation and contracts and conducting internship/vocational training/scholarship/training program activities,
• Fulfillment of storage, information, reporting and other obligations defined by legislation arising from relevant legislation,
• Processing of personal data within the scope of making necessary studies for relevant persons who will benefit from the products, services and support to be provided by Alencast Alüminyum and conducting relevant business processes,
• Your Personal Data and photographs will be processed and stored by Alencast Alüminyum in accordance with Law No. 6698 on the Protection of Personal Data. Your personal data and photographs may be used by Alencast Alüminyum in all corporate belonging studies, including advertising and promotion.
• Processing of personal data within the scope of planning or execution of activities necessary for customizing and recommending to relevant persons the products, services and support to be provided by Alencast Alüminyum according to the preferences, usage habits and needs of relevant persons who will benefit from them; may be processed within the scope of the personal data processing conditions specified in Articles 5 and 6 of Law No. 6698 on the Protection of Personal Data.

Within the scope above, your personal data will be retained for the maximum period specified in the relevant legislation or required for the purpose for which they are processed, and in any case for the legal statute of limitations periods.

According to the Law, personal data can only be processed if at least one of the conditions specified in Articles 5 and 6 of the Law and/or at least one of the conditions required by international legislation provisions exists. In this context, as Alencast Alüminyum, we process our customers' personal data within the scope of our legitimate interests, especially to provide the services we offer to them, to fulfill the obligations we are subject to under the current national and international legislation, and provided that it does not create a negative result on the fundamental rights and freedoms of our customers.

In addition to personal data processing conditions, we may request your explicit consent to process your personal data in some cases. In such cases, your personal data is processed limited to the scope of the explicit consent you have provided with your free will. You have the right to withdraw your explicit consent at any time.

Your personal data may be used in the evaluation of your requests, in establishing communication and managing relations with our business partners, in personalizing and improving your experiences, in providing information about products and services, in managing and concluding requests and complaints, in fulfilling obligations arising from the legislation we are subject to and providing information to authorized institutions and organizations arising from the legislation, in preventing fraud and fraud, in establishing and managing information technology infrastructure, in conducting and auditing processes and operations related to information security.

G) Storage of Personal Data

When determining the storage periods of personal data, we determine by taking into account the current legislation and the processing purposes of the data subject to the process. In this context, if there are statute of limitations periods related to legal obligations regarding personal data processing activities, they are definitely taken into account. If the purpose of processing personal data disappears, the data is deleted, destroyed or anonymized unless there is another legal reason or basis that allows the retention of personal data.

Personal data you have shared with Alencast Alüminyum through the channels mentioned in this Information Text will be stored in accordance with the periods specified in Law No. 6698 on the Protection of Personal Data and related legislation, if a period is specified. If a period is specified in the Law and related legislation, your data will be stored for 2 years after the end of the said period, or if no period is specified.

H) To Which Third Parties Personal Data May Be Transferred and Purposes

Your personal data may be shared with public institutions or organizations, persons with whom we are in commercial cooperation, and our company's subcontractors, to the extent permitted and required by the provisions of the Turkish Commercial Code, Turkish Code of Obligations, Law on the Protection of Personal Data and other legislation.

Alencast Alüminyum may transfer your personal data only; based on the explicit consent of persons or if it is expressly provided for in the laws, especially the legislation we are subject to, if it is necessary for the establishment or performance of the contract, if it is mandatory for the fulfillment of legal obligations, or if it is required by legitimate interests, provided that sufficient measures are taken within the framework of the security and confidentiality principles specified in KVKK, and for the purpose of conducting its activities, to its direct/indirect/domestic/foreign subsidiaries, legal and natural persons with whom it has agreements due to its activities, suppliers, subcontractors, business partners, shareholders, legal, financial and tax advisors, auditors, audit companies or public institutions or organizations authorized to request this data due to a legal obligation, and to other relevant persons or institutions within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of KVKK.

Your personal data may also be shared with legally authorized public institutions and private persons within the scope of their authority.

Your personal data;

• If you have explicit consent, or
• If explicit consent is not obtained but one or more of the other data processing conditions specified in the Law are met:
  • If there is adequate protection in the country to which the data is transferred, in accordance with the decision of the Personal Data Protection Board; or
  • If there is no adequate protection in the country to which the data is transferred, if our company and the Data Controller in the relevant foreign country commit in writing to provide adequate protection and the permission of the Personal Data Protection Board is obtained, it can be carried out.

In these cases where your personal data is shared, we take necessary measures to ensure that the party with whom the data is shared carries out processing and transfer activities in accordance with the rules in the Notification and the provisions in the legislation.

I) Method and Legal Reason for Collecting Personal Data

Your personal data may be collected through physical or electronic means, in accordance with the legal reasons and methods specified in Article 5 of the Law on the Protection of Personal Data. In this sense, your personal data can be obtained by automatic or non-automatic methods.

Your personal data may be collected verbally, in writing or electronically through Alencast Alüminyum's online channels, paper forms, call center, survey and evaluation studies, program partner companies within the scope of services provided by Alencast Alüminyum, with the explicit consent of the person, through cookies (cookies) used by our system to recognize you during website visits, etc. According to the Law, your personal data can only be processed if at least one of the conditions seen in the Law exists. As Alencast Alüminyum, we process data based on the personal data processing conditions listed below, in accordance with the provisions of national and international legislation, especially the basic principles in Article 4 of the Law, regardless of the purpose for which we process your personal data.

Your personal data is collected and stored by Alencast Alüminyum through different communication channels, based on different legal or commercial reasons, in physical or electronic environments, for the purpose of providing benefits to you, fulfilling Alencast Alüminyum's internal requirements/continuing and developing activities, or fulfilling obligations arising from legislation.

J) Data Security

We take reasonable technical and administrative measures to prevent unauthorized access risks, accidental data loss, intentional deletion or damage to data in order to ensure the security of your personal data.

• We ensure data security by using software and hardware including virus and similar malicious software protection systems, firewalls and attack prevention systems.
• We carry out access to personal data within the partnership in a controlled process within the framework of unit/role/application-based authorizations and in accordance with the nature of the data.
• We ensure that necessary audits are carried out in accordance with Article 12 of the Law to ensure the implementation of the provisions of the Law.
• We ensure compliance of data processing activities with the Law through internal company policies and procedures.
• We subject access to special categories of personal data to stricter measures.
• If there is access to personal data from outside the company for reasons such as outsourcing, we obtain commitments from the external service provider to ensure compliance with the Law.
• We take necessary actions to inform all our employees, especially those with access to personal data, about their duties and responsibilities within the scope of the Law.

K) Use of Digital Environments

Your personal data obtained during your use of digital environments may be processed for the purposes of operating and managing the site, conducting studies to improve and develop the user experience related to the site and application, and tracking how the site is used.

If you wish to benefit from the products or services offered within the scope of the application, your personal data will be processed limitedly only for the purpose of enabling you to benefit from the said products or services.

L) Rights of Personal Data Subject Under the Law

Within the scope of Article 11 of Law No. 6698 on the Protection of Personal Data, personal data subjects have the following rights:

1. To learn whether your personal data is being processed,
2. To request information if your personal data has been processed,
3. To learn the purpose of processing your personal data and whether they are used in accordance with their purpose,
4. To know the third parties to whom your personal data has been transferred in the country or abroad,
5. To request correction of your personal data if it has been processed incompletely or incorrectly,
6. To request deletion or destruction of personal data in accordance with Article 7 of Law No. 6698 KVKK,
7. To request notification of the third parties to whom personal data has been transferred regarding the correction of personal data if they have been processed incompletely or incorrectly in accordance with Article 11/1-d of Law No. 6698 KVKK, and regarding the deletion or destruction of personal data in accordance with Article 11/1-e,
8. To object to the emergence of a result against the person by analyzing the processed data exclusively through automated systems,
9. To request compensation for the damage suffered due to the processing of personal data in violation of the law.

You can submit your applications to our company in writing or by using your secure electronic signature, mobile signature or registered e-mail address.

It is important for you to be able to exercise your rights that the information/data you share with Alencast Alüminyum is correct and has been transferred to Alencast Alüminyum correctly. The responsibility arising from providing incorrect or erroneous information belongs to the party who transmitted the information/data to Alencast Alüminyum.

We respond to data subjects who wish to exercise the said rights within the limits foreseen in the Law, in the manner foreseen in the Law, within a maximum of thirty days. For third parties to be able to make an application request on your behalf, there must be a special power of attorney with special authority issued through a notary on behalf of the person who will make the application on your behalf.

Although your applications are processed free of charge as a rule, if a fee tariff is foreseen by the Personal Data Protection Board, charging may be made according to this tariff. We may request information from the relevant person to determine whether the person making the application is the Data Subject, and we may ask questions to the Data Subject regarding their application in order to clarify the issues stated in the application.

You can contact us through the contact information below to exercise the rights mentioned above.

CONTACT INFORMATION

Title: Alencast Alüminyum Enjeksiyon Döküm San. Ltd. Şti.
E-Mail Address: bilgi@alencast.com
Phone: +90 535 324 55 85
Address: Çalı Mah. Sarıyerler Cad. No:24 Nilüfer/Bursa

We respectfully inform you.

Alencast Alüminyum Enjeksiyon Döküm San. Ltd. Şti.