Clarification Text Within the Scope of the Personal Data Protection Law No. 6698
DELFIN ARCHIVE AND SERVICE BUREAU INDUSTRY AND TRADE LIMITED COMPANY (“Delfin” or the “Company”) takes all necessary technical and legal measures in accordance with the Personal Data Protection Law No. 6698 (“KVKK”) in the processing of your personal data due to the activities it carries out. Data subjects may access detailed information regarding the processing of their personal data, transfer of such data to third parties, the legal grounds for personal data collection, and their rights under the KVKK through the clarification text below.
I. Purposes of Processing Personal Data
Your personal data may be processed by the data controller or by natural/legal persons appointed by the data controller under the following circumstances and conditions:
- For the purpose of preparing documents that we are obliged to issue pursuant to the relevant laws,
- For the purpose of improving, developing and diversifying our products and services and offering alternatives to natural/legal persons with whom we have commercial relations,
- For the purpose of raising and improving our service standards, evaluating new technologies and applications, and determining and implementing our commercial and business strategies,
- For the purpose of preparing various reports, research and presentations, planning emergency management processes, following up finance and accounting affairs, and ensuring security within our Company,
- For the purpose of evaluating the recruitment processes of our employee candidates, creating personnel files of our employees, and maintaining our Company’s Human Resources policies,
- Within the scope of our fields of activity in connection with the purpose of establishment of our Company, for the purpose of providing services to all our customers with an understanding of affordable prices and high quality,
- For the purpose of preparing documents that we are obliged to issue pursuant to the relevant laws,
- For the purpose of increasing the performance levels and employee satisfaction of our employees, checking their health status in terms of suitability for work, paying their wages, evaluating their complaints, determining their training and career plans, or ensuring occupational health and safety,
- For the purpose of evaluating candidates applying for employment or internship, evaluating online applications made for recruitment, and carrying out employment commencement procedures for those recruited,
- For the purpose of arranging the statutory leaves of employees, carrying out termination procedures, and determining their attendance at work,
- For the purpose of recording camera footage in our work areas, workplaces and offices, buildings, business sites and vehicles for security and other reasons, and ensuring the security of visitors entering these locations,
- Within the scope of our Company’s obligation to employ ex-convicts, and not limited solely to this scope, for the purpose of evaluating the suitability for work and continuity of employment of our employees and employee candidates,
- In the event that communication is established with our call centers or company telephones, for the purpose of identifying the communication and determining its content through voice and call records,
- Photographs and videos taken of visitors to our business, and during meetings, seminars and other social organizations, award ceremonies and corporate meetings organized by our Company, for the purpose of promoting and announcing our Company and the event and informing the public,
- For the purpose of carrying out necessary quality and standard audits or fulfilling our reporting and other obligations stipulated by laws and regulations,
- For the purpose of ensuring the fulfillment of legal obligations specified under the KVKK, in the manner required or made mandatory by regulatory and supervisory authorities and legal regulations,
- Identity information, contact information and other information submitted to us by adding it to the application document or by hand/orally; for the purpose of identifying the applicant in any oral, written or electronic applications made to contact our Company,
- For the purpose of ensuring the security of our employees, guests and the buildings belonging to our Company through camera recording and other security measures, and controlling entries and exits,
- For the purpose of ensuring that the vehicles and equipment delivered to our employees are used efficiently and effectively,
- For the purpose of using such data in corporate communication and event management activities and processes, and carrying out the necessary work by our Company’s business units to enable personal data subjects to benefit from the services offered by us,
- Photographs and videos taken during meetings, seminars and other social organizations, award ceremonies and corporate meetings organized by our Company, for the purpose of promoting and announcing our Company and the event and informing the public,
- Within the scope of our obligations arising from legislation, for the purpose of taking necessary measures for occupational health and safety, planning and conducting training processes, and enabling early intervention in health-related matters,
- For the purpose of executing and following up financial reporting and risk management operations, creating and monitoring visitor records, and developing and improving public relations and marketing policies,
- For the purpose of fulfilling the requests of judicial authorities, municipalities and other relevant public institutions and organizations,
- For the purpose of preparing and implementing business execution plans and shift schedules,
- For the purpose of planning and executing shuttle services and various logistics activities,
- For the purpose of carrying out our necessary quality and standard audits or fulfilling our other obligations stipulated by laws and regulations,
- For the purpose of notifying changes occurring in legislation or in the policies we have adopted, or making notifications concerning the data subject.
II. Transfer of Personal Data
Your processed personal data may be transferred for the purposes stated above and within the framework of the conditions determined by the KVKK:
- To relevant audit firms, private integrator companies, independent audit firms, customs companies, certified public accountant/accounting firms and law offices for the purpose of fulfilling our obligations pursuant to the relevant legislation provisions and auditing our commercial activities,
- To legally authorized public institutions and organizations in line with the requests of relevant public institutions and organizations and limited to the purposes of such requests,
- To occupational health and safety companies, hospitals and healthcare institutions for the purpose of carrying out emergency medical interventions and fulfilling occupational health and safety obligations,
- To banks and financial institutions for the purpose of carrying out banking and finance transactions,
- To our business partners and suppliers for the purpose of carrying out advertising and promotional processes,
- To solution partner companies, our suppliers and companies operating in this field that carry out repair, maintenance, restoration and service activities,
- To security companies for the purpose of ensuring workplace security,
- To legally authorized public institutions and organizations and judicial authorities in line with the requests of relevant public institutions and organizations and limited to the purposes of such requests.
III. Method and Legal Grounds for Collecting Personal Data
Your personal data are collected by the Company or by natural/legal persons processing data on behalf of the Company through application forms, website, various contracts, all kinds of information forms, surveys, job application forms, employment contracts, social media applications, written, oral and digital notifications received from our customers, suppliers and business partners, call centers, and, without being limited to those listed herein, through oral, written or electronic channels, within the scope of your explicit consent or other data processing conditions stipulated under the KVKK.
Such information is obtained for the purposes of carrying out our commercial and administrative activities within the framework of the law and, within this scope, enabling the Company to provide its services, sustain its commercial life, and fulfill its legal responsibilities completely and accurately.
IV. Storage, Destruction and Anonymization of Personal Data
Our Company stores personal data in accordance with the purpose of processing personal data and in a manner proportionate to the processing purpose. Personal data are retained until the end of the period required by the relevant legislation in cases where the purpose and/or reason for processing no longer exists. When the purpose and reason for processing personal data cease to exist, personal data shall be destroyed or anonymized upon completion of the limitation periods required for the fulfillment of our obligations arising from the laws.
V. Rights of the Data Subject
Natural persons whose personal data are processed within our Company have the following rights pursuant to Article 11 of the KVKK:
- To learn whether their personal data are being processed,
- To request information if their personal data have been processed,
- To learn the purpose of processing personal data and whether they are used in accordance with such purpose,
- To know the third parties to whom personal data are transferred domestically or abroad,
- To request correction of personal data if they have been processed incompletely or inaccurately, and to request that the transaction carried out within this scope be notified to third parties to whom the personal data have been transferred,
- To request deletion or destruction of personal data in the event that the reasons requiring their processing cease to exist, despite having been processed in accordance with the KVKK and other relevant laws, and to request that the transaction carried out within this scope be notified to third parties to whom the personal data have been transferred,
- To object to the occurrence of a result against the person themselves by means of analysis of the processed data exclusively through automated systems,
- To request compensation for damages in the event of suffering damage due to the unlawful processing of personal data.
You may submit your requests regarding the above-mentioned rights listed in Article 11 of the Personal Data Protection Law to our Company in accordance with the Communiqué on the Procedures and Principles of Application to the Data Controller. In order for your requests to be concluded quickly and effectively, we kindly request that you submit your applications by filling out the Personal Data Protection Law Application Form. The requests of the data subject shall be evaluated and resolved free of charge as soon as possible and in any event within thirty (30) days at the latest. If the evaluation and decision-making process requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board shall apply.
