LPDP Clarification Text

TÜMOSAN MOTOR ve TRAKTÖR SANAYİ ANONİM ŞİRKETİ
TÜMOSAN MOTOR ve TRAKTÖR SANAYİ ANONİM ŞİRKETİ WEBSITE CLARIFICATION TEXT UNDER THE LAW ON PERSONAL DATA PROTECTION NO. 6698

TÜMOSAN Motor ve Traktör Sanayi Anonim Şirketi (“TÜMOSAN”) takes all necessary technical and legal measures in accordance with the Law on Personal Data Protection No. 6698 (“LPDP”) in the processing of your personal data due to the activities it carries out.

Your personal data is processed by TÜMOSAN, as data controller, and/or the natural/legal person it appoints:

• In accordance with the law and the rule of honesty,
• Within the framework of our contractual and legal obligations,
• By maintaining up-to-dateness and accuracy,
• In a limited and measured manner appropriate to the purpose of processing,
• To be kept for the period stipulated in the relevant legislation or necessary for the purpose for which it is

processed.

Relevant persons can access detailed information about their personal data processed, the purposes of processing their personal data, their transfer to third parties, the legal reasons for collecting personal data and their rights in the LPDP, from the information text below.

The legal reasons TÜMOSAN relies on during data processing are as follows:

• Existence of explicit consent (“Article 5/1 and Article 6”)
• That it is clearly stipulated in the law (“Article 5/2-a”).
• That processing of personal data belonging to the parties of a contract is necessary, provided that it is directly related to the conclusion or fulfilment of that contract. (“Article 5/2-c”)
• That it is mandatory for the controller to be able to perform his legal obligations. (“Article 5/2-ç”)
• That it is made available to the public by the data subject himself. (“Article 5/2-d”)
• That data processing is mandatory for the establishment, exercise or protection of any right. (“Article 5/2-e”)
• That it is mandatory for the legitimate interests of the controller, provided that this processing shall not violate the fundamental rights and freedoms of the data subject. (“Article 5/2-f”).

A. Processed Personal Data, Legal Reason for Personal Data Processing, and Collection Methods

Purpose of Data Processing	Processed Personal Data	Data Processing Terms	Data Collection Methods
In order to ensure security by recording our company's businesses, facilities and work areas	Camera recording	Article 5/2-f	Through camera systems (Automatic means).
For the purpose of audio recording phone calls.	Voice recording.	Article 5/2-f.	Through the call center (Automatic means).
In order to ensure security checks at the entrances.	Name and surname	Article 5/2-f.	From the person concerned (by non-automatic means).
For the purpose of processing incoming documents and trademark registrations.	Name, surname, title, signature.	Article 5/2-f.	By physical means or by e-mail (Non-automatic or partially automated means).
In order to ensure company security.	Name and surname, license plate information.	Article 5/2-f.	Via e-mail (Partially by  automated means).
Recording of required data within the scope of law no. 5651	Mac Address, IP Address, User ID Information Received When Registering to the Hotspot Guest Network	Article 5/2-a, Article 5/2-d, Article5/2-f	By digital means (Automatic means)
Product testing and assembly stages, use in corporate promotions and project presentations and social media activities	Video Recording, Photo	Article 5/1 and Article 6	With cameras (non-automatic means).
For request and complaint management purposes	Name and surname, e-mail, telephone number, request and complaint form, signature.	Article 5/2-e, Article 5/2-f.	Elektronik yollarla (Kısmen otomatik yollarla).
For invoicing purposes.	Name and surname, TIN, TR ID number, e-mail, telephone, address.	Article 5/2-a, Article 5/2-c, Article 5/2-ç, Article 5/2-e.	By physical or digital means (non-automatic or partially automated means).
For the purpose of creating current account records, making payments or collections and legal obligations	Name and surname, TR ID number, ID serial number, mother's name, father's name, place and date of birth, marital status, religion, blood group, signature, photograph registered province, district, quarter, village, volume number, family serial number, gender, enforcement proceedings documents, legal documents transmitted by the court, tax numbers, tax offices, bank details / account IBAN number, if any	Article 5/2-a, Article 5/2-c, Article 5/2-ç, Article 5/2-e, Article 5/1 and Article 6	By physical or digital means (non-automatic or partially automated means).
For the purpose of carrying out e-notifications and official correspondence.	Name and surname, TR ID number, tax number, signature, address.	Article 5/2-a, Article 5/2-ç, Article5/2-f	By physical or digital means (non-automatic or partially automated means).
For the purpose of making court case file payments.	Name and surname, TR ID number, IBAN information, Court/Execution file number.	Article 5/2-ç, Article 5/2-f.	By physical means or by e-mail (Non-automatic or partially automated means).
For the purpose of preparing the list of authorized signatories.	TR ID number, identity card serial number, name and surname, photograph, place of birth, date of birth, marital status, registered province, district, parents' names, family number, volume number, registration number, signature.	m.5/2-a, m.5/2-c.	Fiziki yollarla veya e-posta yoluyla (Otomatik olmayan veya kısmen otomatik yollarla).
Preparation of Audit Reports	Name and surname, ID number, signature, e-signature.	Article 5/2-c, Article 5/2-f.	Through the relevant documents (by non-automatic means).
Preparation of Training Certificate	Name and surname, TR ID Number	Article 5/2-c.	By physical means or by e- mail (Non-automatic or partially automated means).
For the purpose of preparing laws, circulars, instructions, regulations, decrees, statutes, orders and letters and sending them to the relevant places.	Name and surname of the notifier, TR ID number, signature.	Article 5/2-c, Article 5/2-ç, Article 5/2-e, Article 5/2-f.	By physical means or by e-mail (Non-automatic or partially automated means).
For the purpose of following up litigation, mediation and enforcement processes.	Personal data subject to or contained in the file	Article 5/1, Article 6, Article 5/2-a, Article 5/2-d, Article 5/2-e, Article 5/2-f.	By physical means or by e-mail (Non-automatic or partially automated means).
For the purpose of preparing the emergency registration form.	Name and surname, title, address, telephone, injury status.	Article 5/2-b, Article 5/2-f	Via phone (Partially by automated means).
For the purpose of transmitting incoming and outgoing call records to relevant places.	Name and surname, telephone, e-mail, institution he/she works for	Article 5/2-f.	Via phone (Partially by automated means).
For the purpose of transmitting guest appointment information to the relevant places.	Name and surname, phone, e-mail.	Article 5/2-f.	Via phone (Partially by automated means).
For the purpose of forwarding incoming faxes and e-mails to the relevant locations.	Name, surname, title, e-mail, telephone, address.	Article 5/2-f.	By physical means, fax and by e-mail (Non-automatic or partially automated means).
Listing phone numbers so that communication can be maintained.	Name, surname, title, phone, e-mail.	Article 5/2-f.	Via e-mail (Partially by automated means).
For the purpose of carrying out correspondence with public institutions and organizations	Name and surname, address, TR ID number, ID serial number, date of birth, mother and father's name, title, photo, video, telephone, e-mail, signature.	Article 5/2-a, Article 5/2-c, Article 5/2-ç	By physical means or by e-mail (Non-automatic or partially automated means).
In order to confirm the rules to be followed during the field visit	Name and surname, signature,	Article 5/1, Article 5/2-a, Article 5/2-ç, Article 5/2-f.	Record (by non-automatic means).
In legal processes, the personal data of opposing party attorneys are seen because they are included in the file	Personal data contained in files or documents	5/2-d	Through file (Automatic and non-automatic means).
For the purpose of carrying out travel processes such as accommodation, transportation, ticketing, etc.	Identity information, e-mail address, phone number, title deed information, license information, institution information	Article 5/2-c, Article 5/2-ç, Article 5/2-e	Physically and via e-mail (by automatic and non-automatic means).

B. Transfer of Personal Data to Third Parties

Purpose of Data Transfer	Recipient Groups to Which Data is Transferred
Data processed during the preparation of audit documents, if requested	is transferred to relevant and authorized public institutions and organizations.
Data processed during invoicing to the customer, for the purpose of legal liability and ensuring the continuation of the process	is transferred to relevant and authorized public institutions and organizations and Albayrak Holding.
Data processed during audit activities by taking phone and video records, in accordance with legal obligation	is transferred to relevant and authorized public institutions and organizations.
Data processed during the execution of e-notifications and official correspondence, due to legal obligations	is transferred to relevant and authorized public institutions and organizations.
For the purpose of making payments, data processed during payments related to court case files	is transferred to the relevant banks.
Data processed during the preparation of the signature circular, in order to carry out the process	is transferred to the relevant banks.
Data processed during the conclusion of a contract with the customer, for informational purposes,	is transferred to the relevant company or individual.
Visitor identification information for the purpose of recording R&D Center activities	is transferred to the Ministry of National Defense, Presidency of Defense Industry, TÜBİTAK, and foreign suppliers.
For the purpose of carrying out social media and promotional activities, visual and audio data	is published publicly on social media platforms. It is specifically transferred to domestic and international customers.
For the purpose of preparing an incident report, data regarding those  who violate occupational safety during facility visits	is transferred to OSGB companies.
For the purpose of preparing an incident report, data regarding those who violate occupational safety during facility visits	is transferred to OSGB companies.
Contact information, for the purpose of carrying out communication activities,	is transferred to domestic and foreign customers, domestic suppliers, customs consultancies and public institutions, Albayrak Holding and Group Companies.
Data transmitted during the notification of documents such as laws and circulars, upon request,	is transferred to relevant and authorized public institutions and organizations.
Data processed for the purpose of following up litigation, mediation and enforcement proceedings, for the purpose of carrying out the process,	is transferred to foreign offices, courts, enforcement offices, tax offices, relevant banks, Albayrak Holding, relevant public institutions and organizations, and independent audit firms.
In order to transmit incoming and outgoing call records and guest appointment information to the relevant authorities,	is transferred to Albayrak Group Companies.
Data processed during correspondence with public institutions and organizations, in accordance with legal obligations and for the purpose of advancing the processes,	is transferred to relevant and authorized public institutions and organizations, Albayrak Holding and, depending on the nature of the correspondence, to the relevant Albayrak Group Company.
For the purpose of carrying out travel processes, such as accommodation, transportation, ticketing, etc., personal data processed for the same purpose	is transferred to the supplier companies that carry out the process, to the consulates if necessary and to the relevant public institutions and organizations upon request.

C. Rights of the Relevant Person

Herkes, şirketimizin aşağıda belirtilen adresine Veri Sorumlusuna Başvuru Usul ve Esasları Hakkında Tebliğ’e uygun bir şekilde başvuruda bulunarak kendisiyle ilgili;

●    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 at home or abroad;
●    Requesting correction of personal data in case personal data has been processed incompletely or incorrectly and requesting that the action taken accordingly 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 no longer exist, even though it has been processed in accordance with the law and other relevant legal provisions, and requesting that the action taken accordingly be notified to third parties to whom personal data has been transferred;
●    Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems;
●    Requesting compensation for damage in case of damage due to illegal processing of personal data. 

Applications submitted to us are responded to within 30 (thirty) days at the latest from the date the request reaches our Company, depending on the nature of the request. If the evaluation and decision-making process requires an additional cost, the fee in the tariff determined by the Personal Data Protection Board will be taken as basis. Kindly submitted for your information.

D. Identity of the Data Controller

 Mersis (Central Registration System) Number: 0050 0361 6010 0013
 Website: www.tumosan.com
 Phone: +90 212 467 67 00 +90 212 468 19 00
 E-mail Address: kvkk@tumosan.com.tr
 Address: Maltepe Mah. Londra Asfaltı Cad. No: 28/1 Zeytinburnu/Istanbul
 Registered E-mail Address: tumosan@hs01.kep.tr