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  • Ak Sigorta
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  • Doğa Sigorta
  • Dubai Sigorta
  • Ergo Sigorta
  • Ethica Sigorta
  • Eureko Sigorta
  • Gig
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ANTAMAGAZINE

ANTAMOTION-PERSONAL DATA PROTECTION LAW POLICY

1) PURPOSE

The main purpose of this Policy is to make statements about personal data processing activities carried out in accordance with the law and the systems adopted for the protection of personal data and to ensure transparency by informing the persons whose data is processed by our personal data company such as supplier employees, supplier authorities, people who buy products or services and visitors.

2)  SCOPE

This policy applies to all activities managed by Antamotion regarding the processing and protection of personal data.

This policy concerns all the personal data of our partners, officials, employees and partners of our customers, officials, employees, officials and stakeholders of institutions with which we cooperate and unrelated persons which is processed.

This policy applies to all activities regarding processing and protection of personal data by Antamotion in addition to relevant detailed data procedures.

3)  IMPLEMENTING THE POLICY

The relevant legislation terms in effect during processing and protection of personal data will be applied first. If there is a conflict between legislation terms and policy terms, Antamotion accepts that up-to-date legislation terms prevail.

The policy is made up of Antamotion practices reviewed in light of the relevant legislation.

(1) Data personnel are obliged to:

  1. a)  ensure personal data isn’t processed illegally,

  2. b)  ensure personal data isn’t accessed illegally,

  3. c)  store personal data,

take all necessary technical and administrative measures to ensure appropriate security levels.

4) DEFINITIONS

For the purposes of this Law the following definitions shall apply:

a) Data subject: the natural person, whose personal data is processed,

b) Personal data: all the information relating to an identified or identifiable natural person,

c) Antamotion : Company is described as “Yeşilipek Özel Sağlık ve Servis Hizmetleri Otomotiv Turizm Ticaret Limited Şirketi” and “Antamotion Otomotiv Servis ve Kiralama Hizmetleri Ticaret Limited Şirketi”.

d) Processing of personal data: any operation performed upon personal data such as collection, recording, storage, retention, alteration, re-organization, disclosure, transferring, taking over, making retrievable, classification or preventing the use thereof, fully or partially through automatic means or provided that the process is a part of any data registry system, through non-automatic means,

e) Board: the Personal Data Protection Board,

f) Authority: the Personal Data Protection Authority,

g) Processor: the natural or legal person who processes personal data on behalf of the controller upon his authorization,

h) Data registry system: the registry system which the personal data is registered into through being structured according to certain criteria,

ı) Controller: the natural or legal person who determines the purpose and means of processing personal data and is responsible for establishing and managing the data registry system.

4) ISSUES CONCERNING PROTECTION OF PERSONAL DATA

Antamotion takes the necessary legal, technical and administrative measures regarding data security on the following issues and shows the highest level of attention and care in this regard. Actions and measures taken by our company to ensure “data security” in accordance with Article 12 of the KVKK Law are as follows.

  • Our company takes technical and administrative measures according to the technological possibilities and implementation cost to ensure that the personal data are processed lawfully. Employees are informed that they cannot disclose the personal data they have learned to anyone else in violation of the provisions of the Law on KVKK, and cannot use it for purposes other than processing, and that this obligation will continue after they leave their jobs and necessary commitments are received in this direction.

  • Our company takes technical and administrative measures according to the nature of the data to be protected, technological possibilities and application cost in order to prevent the unconscious, unauthorized disclosure, access, transfer or any other illegal access of personal data.

  • Our company raises awareness amongst data processing institutions such as business partners and suppliers, where it has transferred personal data to prevent illegal processing of personal data, to prevent illegal access to data, and to ensure that data is protected in a lawful way; takes necessary measures for business partners and suppliers to engage in personal data processing activities in compliance with KVKK law.

  • The obligations that our company has to comply with while processing personal data as a data collector and the obligation to comply with the legal, administrative and technical measures it has developed in this regard.

  • Our company takes necessary technical and administrative measures according to technological possibilities and application cost to prevent personal data to be stored in safe environments and to be destroyed, lost or changed for illegal purposes.

  • Our Company performs the required audits within its own body in accordance with Article 12 of the KVKK Law. The results of these audits are reported to the concerned department in line with the Company's internal operation procedures, and required activities are carried out to improve the measures taken.

  • In case that personal data processed in accordance with Article 12 of the KVKK Law are obtained by others through illegal means, our company operates a system that allows this situation to be notified to the concerned personal data subject and the KVKK Board as soon as possible.

5)  PROCESSING OF PERSONAL DATA POLICY

5.1 Principles for processing personal data

Antamotion processes all personal data in line with KVKK and the relevant legislation. As per KVKK Article 4, Antamotion processes the personal data in line with the law and honesty rules, in pursuit of up-to-date, specific, clear and legitimate purposes and in a fashion that is limited, proportionate and related to the purpose.

Processing in line with the law and honesty rules- Antamotion acts in line with the principles stemming from legal regulations, general trust and honesty rules to process personal data. In this scope, Antamotion considers the proportion of requirements when processing personal data, and does not utilise the data for reasons other than what the purpose requires.

Ensuring the accuracy and up-to-date nature of personal data- Antamotion ensures the accuracy and up-to-date nature of the personal data that it processes, considering the basic rights of the data owners and its own legitimate interests.

Processing for specific, clear and legitimate reasons- Antamotion explicitly and clearly defines its legitimate and legal purpose for processing personal data.

Having boundaries and acting conservatively concerning the purposes for processing- Antamotion processes personal data in a fashion that allows for carrying out the specified objectives, and avoids processing personal data that is unrelated to the objective or unnecessary.

Storing for no longer than is predetermined in the related legislation or is necessary for the purposes of processing- Antamotion stores personal data for as long as defined in the relevant legislation or necessary for its purpose. In this scope, Antamotion determines whether a duration for keeping the personal data is laid out in the relevant legislation. If a duration period is specified, Antamotion abides by this duration. If not, Antamotion keeps the personal data for as long as is necessary for the purpose for which the personal data was collected. When the period permitted for holding the data ends or the reasons for processing the data disappear, Antamotion deletes, disposes of or anonymises the personal data.

5.2 Antamotion’s reasons for processing personal data

As per KVKK Article 10, Antamotion informs the relevant persons when collecting personal data. In this scope, Antamotion sheds light on the identity of Antamotion and its representatives (if applicable), the purpose for processing the personal data, to whom and why the processed personal data might be transferred, the method for collecting personal data and the lawful reason for collection, and the rights of the relevant persons as per Article 11 of KVKK.

Antamotion processes personal data, which are stated in personal data processing terms in KVKK Articles 5 and 6, and in accordance with the purposes below.

5.2.1 Terms

The law may clearly dictate that Antamotion process personal data except for data related to health or sex life.

Antamotion’s processing of personal data may be directly related to and necessary to signing or carrying out a contract. Personal data may be processed to prepare a proposal during the beginning phase of a contract, to prepare a purchasing form or to fulfil relevant persons' requests related to the results of a contract. During contract preparation, relevant persons may be contacted in light of the information they have provided.

Antamotion is allowed to process data if it is required to fulfil a legal obligation or if law requires the personal data or allows these transactions. It is necessary for data transactions to be necessary for the legally-allowed data processing activity and must conform to the relevant legal terms in terms of type and scope.

Antamotion may process personal data provided that the data is made public when:

Antamotion is obliged to process the data to establish, use or protect the rights of Antamotion, the persons whose data is being processed or unrelated persons;

Antamotion is obliged to process the data for its own legitimate interests (provided the basic rights and freedoms of the persons whose data is processed are not violated). Legitimate interests are interests that are in line with the law, morals and customs, as well as material interests.

Antamotion is obliged to process personal data to protect the data owner’s or someone else’s life or bodily integrity when it is impossible or not legally valid for the personal data owner to express consent.

Private personal data except for that related to the health and sex life of the data owner, in circumstances defined in laws.

If the circumstances above do not exist Antamotion asks for explicit consent to process personal data from the personal data owner or through the relevant customers.

6) TRANSFERRING PERSONAL DATA

Antamotion is able to transfer the personal data and sensitive personal data of the data owner to third parties by taking the necessary security measures in accordance with the purpose of processing the personal data which is obtained and processed pursuant the law. In this respect, Antamotion acts in accordance with the provisions of Article 8 of the KVKK Law.

It is also possible to transfer the data without approval in the circumstances explained in Articles 5 and 6 of KVKK. Antamotion may transfer personal data to unrelated persons in Turkey and companies in the Antamotion network under Antamotion on condition that it is transferred in line with the conditions defined in KVKK and other relevant legislation, taking all the safety measures defined in legislation, unless there is a contrary clause in KVKK, other relevant legislation or, if applicable, the contract signed with the data owner.

Antamotion shares the information requested by public legal entities as per KVKK Article

Other persons and institutions to whom the personal data might be transferred for the purposes mentioned above are as follows: subsidiaries and/or direct/indirect domestic/overseas institutions and other unrelated persons, who provide services, cooperate with Antamotion and are program partners responsible, alongside of Antamotion for taking data security measures such as the protection of all kinds of personal data and preventing unauthorised access and illegal processing.

7) THIRD PARTIES THAT PERSONAL DATA IS TRANSFERRED BY ANTAMOTION

In accordance with Article 10 of the KVKK Law, Antamotion informs the personal data subject of the groups to whom personal data are transferred.

In accordance with Article 8 and 9 of the KVKK Law, Antamotion may transfer the personal data of the data subjects managed by the Policy to the following categories:

  • Real persons or private legal entities

  • Shareholders

  • Business Partners

  • Financial Associates and Subsidiaries

  • Suppliers

  • Community Companies

  • Authorized Public Institutions and Organizations

8)  PERSONAL DATA PROTECTION ACTIVITIES WITHIN THE BUILDING FOR ENTRANCES AND WEBSITE VISITORS

Antamotion, processes personal data in building corridors and inside offices in line with the Constitution, KVKK and other relevant legislation. To ensure security, Antamotion monitors corridors and offices with security cameras for entrances and exits. Guests are also documented upon entry.

Antamotion processes personal data using security cameras and by recording guests to increase service quality, ensure service reliability, ensure the safety of lives, and ensure the safety of the property of the company, data owners and other persons, and to protect their legitimate interests.

Antamotion’s monitoring activities via video cameras are limited to the purposes laid out in this policy. To this end, the monitored areas, number of cameras, and the monitoring times are only sufficient to fulfil security needs and are limited to this purpose only. Fields which pose the risk of interfering in a person’s privacy in any way that goes beyond security purposes are not monitored.

Antamotion takes the necessary technical and administrative measures as per Article 12 of KVKK.

Records recorded and stored digitally can be accessed by a limited number of Antamotion’s employees and subcontractor security employees. Those persons with access to the records are obliged to protect the privacy of the data in the framework of non-disclosure agreements.

On the websites owned by Antamotion; ensuring that visitors of these sites conduct their visits on the sites in a manner suitable for the purpose of their visit; In order to be able to show them customized content and to carry out online advertising activities, internet movements within the site are recorded by technical means (For instance, cookies). Approval information about the use of Cookies at the entrance of our Company's website is obtained from all users.

9)  THE RIGHTS OF PERSONS WHOSE PERSONAL DATA IS BEING PROCESSED BY ANTAMOTİON;

Natural persons whose personal data is processed by Antamotion can apply to antalya@autoking.com.tr

    1. to be informed whether your data is being processed,

    2. to request information if it is processed,

    3. to learn the purpose of any processing of your personal data and whether it is being used in compliance with that purpose,

    4. to be informed of any unrelated persons residing within the country or overseas to whom the data is transferred,

    5. to request adjustment if the personal data is processed incorrectly or in an incomplete manner,

    6. to request deletion or disposal of personal data (even when the data is processed in line with the terms of relevant laws) after the reasons for processing the personal data disappear,

    7. to request that the unrelated persons to whom the data is transferred are informed of the transactions carried out

    8. to object to a finding against you as a result of analysing and processing your personal data exclusively through automated systems,

10)  DELETION, DISPOSAL AND ANONYMISATION OF PERSONAL DATA BY ANTAMOTİON

As per Article 138 of the Turkish Penal Code and Article 7 of KVKK, even if personal data is processed as per the terms of the relevant law, if the reason for processing the data no longer exists, the personal data is deleted, disposed of or anonymised upon a decision by Antamotion or the request of the personal data owner.

Antamotion reserves the right to reject the data owner’s request in cases where Antamotion has the right/is obliged to keep the data as per the terms of relevant legislation.
If personal data is processed via an unautomated method, provided it is part of a data recording system, Antamotion physically disposes of the personal data during deletion/disposal in such a way that the data is not reusable. When Antamotion makes a deal with a person or an institution to have personal data processed, the personal data is deleted in such a fashion that it cannot be recovered by this person or institution.

Antamotion may anonymise the personal data when the reasons for processing personal data which is processed legally no longer exist.

11) CONDITIONS UNDER WHICH THE PERSONAL DATA OWNER MAY NOT USE THEIR RIGHTS

As per KVKK Article 28, personal data owners may not use their rights mentioned above under the following conditions since these following conditions are excluded from the KVKK:

the personal data is anonymised through official statistics and processed for research, planning and statistics;

the personal data is processed for art, history, literature or scientific reasons or in the scope of freedom of expression, provided this does not constitute a crime, violate the national defence, national security, public safety, public order, economic security, privacy of personal life or personal rights;

the personal data is processed within the scope of preventive, protective or intelligence activities performed by public bodies and institutions given the task and authority by law to ensure national defence, national security, public safety, public order or economic security;

the personal data is processed by judicial or executive authorities in relation to investigations, prosecutions, adjudications or enforcement. as per Article 28/2 of KVKK, the personal data owners may not claim their rights mentioned in 9, except the right to demand compensation for damages, in the cases listed below:

when the processing of personal data is required to prevent crime or for criminal investigation;

when the data processed is expressed publicly by the data owner;

when the personal data processing is necessary to carry out inspection or regulation, or disciplinary investigation or prosecution by official and authorized institutions and entities and occupational organisations which have the nature of public institutions, as per the authorisation granted by law;

when processing is necessary to protect the economic and financial interests of the state concerning budget, tax and financial issues.

12) OTHER ISSUES

If there is a conflict between this policy and KVKK and the terms of other relevant legislation, KVKK and other relevant legislation terms prevail.