KVKK Information Text

As UpSun Transfer, we show utmost sensitivity regarding the security of personal data. UpSun Transfer takes the highest level of security measures possible within the framework of the relevant legislation in order to ensure that your personal data is collected, stored and shared in accordance with the law and to protect your privacy. With the awareness of this responsibility, 6698 s.k. As data controller, we process your personal data as explained below and within the framework of the legislation.

1) Identity of the Data Controller and Representative. The extent to which your personal data may be processed by UpSun Transfer, as the data controller, in accordance with Article 10 of the Personal Data Protection Law No. 6698 (“KVKK”) is explained below.

2) Purpose of Processing Personal Data

Your collected personal data may be processed by UpSun Transfer for the following purposes in accordance with the basic principles stipulated by the legislation:

Carrying out the necessary work by our Company’s business units in order to carry out the commercial activities carried out by UpSun Transfer in accordance with the legislation and Company policies and carrying out activities in this direction;

Determining UpSun Transfer’s human resources policy and carrying out its activities;

Determining, planning and implementing UpSun Transfer’s commercial policies in the short, medium and long term;

Ensuring the commercial, technical and legal safety of the relevant persons with whom UpSun Transfer has a business relationship and providing contact with these real / legal persons;

Protecting UpSun Transfer’s commercial reputation and the trust it creates;

Complying with the information storage, reporting and information obligations stipulated by official institutions within the scope of the relevant legislation, and fulfilling the legal obligations we are subject to regarding the use of these services;

In order to determine and implement our company’s commercial and business strategies; management of financial operations, communication, market research and social responsibility activities, purchasing operations (request, offer, evaluation, order, budgeting), internal system and application management operations, legal operations;

Examining, evaluating and responding to requests from official authorities or relevant persons;

Ensuring the security and control of the company’s physical locations through camera recording and other systems;

Fulfilling the burden of proof as evidence in legal disputes that may arise in the future;

Personal data is processed within the scope of the processing conditions and purposes specified in Articles 5 and 6 of the KVKK.

Your data is classified within the scope of automatic decision-making in order to process the necessary work and information within the scope of our activities. This situation is mandatory for the reports to be created and the documents to be submitted to the relevant organizations.

Processing your personal data is a legal and contractual obligation, and if your data is not provided, it is impossible for real/legal persons who have a business relationship with the company to carry out commercial activities, fulfill the notifications and obligations required under the legislation, ensure the execution of human resources activities, and ensure legal-technical-commercial safety. it will become.

3) To Whom and For What Purpose Data Can Be Transferred/Transfer Abroad

Personal data is transferred by UpSun Transfer to the following persons within the scope of KVKK Articles 8 and 9, provided that it is limited to the purposes listed above:

UpSun Transfer’s business partners and affiliates,

Persons and institutions permitted by the Turkish Commercial Code, Turkish Code of Obligations, Labor Law and other relevant laws and legislation,

To legally authorized institutions and organizations, to institutions, organizations, individuals and companies ordered by administrative and legal authorities and special legislation;

In case of transfer, it will be transferred to the real and legal persons from whom we receive products and services and with whom we cooperate, by asking whether the domestic institution and/or business to be transferred also has KVKK compliance and data security.

According to Article 9 of the Law, transfer of your personal data abroad;

The existence of the conditions specified in the Law in the transfer of personal data to countries with adequate protection (countries deemed safe by the Board) or the express consent of the person concerned (conditions specified in the 2nd paragraph of Article 5 and the 3rd paragraph of Article 6 of the Law),

Transfer of personal data to countries where there is no adequate protection may be carried out in case of the existence of the conditions specified in the Law (conditions specified in the 2nd paragraph of Article 5 and the 3rd paragraph of Article 6 of the Law), a written commitment to adequate protection and the permission of the Board. . The Personal Data Protection Board will declare the countries considered safe.

4) Gathering Management and Legal Reason of Persons

Your personal data is collected by our Company through different channels (verbal, written, electronic media) in order to carry out our activities, based on legal reasons such as ensuring compliance with the legislation and Company policies, execution of contracts, clearly foreseen by the law, and the legitimate interests of the company. Your personal data may be processed and transferred for the purposes specified in this Information Text within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the KVKK, in accordance with the basic principles stipulated by the KVKK.

5) Duration of Storage of Personal Data

Your personal data is retained for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed. The following criteria are taken into account when determining the maximum period:

The period accepted as a general practice in the sector in which the data controller operates within the scope of the purpose of processing the relevant data category,

The period that requires the processing of personal data in the relevant data category and during which the legal relationship established with the relevant person will continue,

The period during which the legitimate interest to be obtained by the data controller, depending on the purpose of processing the relevant data category, will be valid in accordance with the law and the rules of honesty,

The period during which the risks, costs and responsibilities that will arise from storing the relevant data category depending on the purpose of processing will continue legally,

Whether the maximum period to be determined is suitable for keeping the relevant data category accurate and updated when necessary,

The period during which the data controller is obliged to retain personal data in the relevant data category in accordance with its legal obligation,

The limitation period determined by the data controller for asserting a right based on personal data in the relevant data category.

6) Personal Data Owner’s Rights Listed in Article 11 of Law No. 6698

As personal data owners, if you submit your requests regarding your rights to UpSun Transfer using the methods set out in the UpSun Transfer Personal Data Protection and Processing Policy, which has been shared with the public at www.upsuntransfer.com.tr, our company will respond to your request as soon as possible and at the latest, depending on the nature of the request. It will be concluded within thirty days. However, if the transaction requires an additional cost, UpSun Transfer will charge the fee at the tariff determined by the Personal Data Protection Board. In this context, personal data owners;

– Learning whether personal data is processed or not,

– Requesting information if personal data has been processed,

– Learning the purpose of processing personal data and whether they are used for their intended purpose,

– Knowing the third parties to whom personal data is transferred domestically or abroad,

– Requesting correction of personal data in case of incomplete or incorrect processing and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,

– Requesting the deletion or destruction of personal data in case the reasons requiring processing are eliminated, even though it has been processed in accordance with the provisions of KVKK and other relevant laws, and requesting that the transaction carried out in this context be notified to third parties to whom personal data has been transferred,

– Objecting to the emergence of a result that is unfavorable to the person by analyzing the processed data exclusively through automatic systems,

– They have the right to demand compensation for the damage in case of damage due to illegal processing of personal data. In cases where the application is rejected, the response is found to be insufficient, or the application is not responded to in due time; The relevant person may file a complaint with the Personal Data Protection Board within thirty days from the date of learning the response of the data controller, and in any case within sixty days from the date of application. In accordance with Article 13 of the Law, a complaint cannot be filed without exhausting the remedy.

Apart from the above-mentioned rights of the relevant person within the scope of international legislation; There is also the right to request the restriction of the processing of personal data and to withdraw consent to the processing or transfer of personal data.