KVKK Disclosure Notice

This English text is a translation provided for convenience. Law No. 6698 on the Protection of Personal Data is Turkish legislation and the Turkish original of this notice prevails in the event of any discrepancy.

At SDF Endüstri we know the value of your data and run all our processes to high security standards.

SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ (hereinafter referred to as the “Company”) values the protection of your personal data and private information. For this reason we take all due care to ensure that the personal data of persons connected with SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ is processed and retained in accordance with Law No. 6698 on the Protection of Personal Data (“KVKK”). In its capacity as Data Controller, SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ takes the necessary administrative and technical measures to protect your data in all operations involving your personal data and, in line with the KVKK, processes your personal data under the conditions described below and within the limits laid down by legislation.

Personal information recorded while our website is visited is processed in accordance with the legislation on the protection of personal data. Please also review our Privacy Policy, which you can find on our site. Please note, however, that no guarantee can be given regarding data security on other websites reached through links on the SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ website. The data security policy of the relevant page should be reviewed carefully.

Legal Nature and Scope

Article 10 of Law No. 6698 on the Protection of Personal Data (“KVKK”) requires that data subjects be informed when their consent is obtained. The article is headed Obligation of the Data Controller to Provide Information.

Under the provisions of the KVKK, SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ is the Data Controller. Within this framework, the obligation to inform requires data subjects to be told about the identity of the data controller, the purposes of processing personal data, the persons to whom personal data is transferred and the purposes of transfer, the legal grounds for collecting personal data, to whom and by what methods it may be transferred, and the rights listed in Article 11 of the KVKK — such as requesting the data controller to update, delete or anonymise data.

In its capacity as Data Controller, and pursuant to Article 10 of the KVKK, SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ informs data subjects through this Disclosure Notice on the Processing of Personal Data that it processes their personal data within the limits and conditions laid down by legislation.

Identity of the Data Controller

Article 3(1)(ı) of the KVKK defines the data controller as “the natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system”. In this framework the data controller is SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ, whose website you are visiting.

Data Processor

The natural or legal person who processes personal data on behalf of the data controller, on the authority given by the controller, is defined as the “Data Processor” in Article 3 of the KVKK.

Purposes for Which Your Personal Data Is Processed

In line with the principles of the KVKK, your personal data is processed within the scope of the processing conditions set out in Articles 5 and 6 of the KVKK for the following purposes:

• informing our customers of the services offered by SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ and providing opportunities to benefit from them more fully;
• improving the quality of the services offered and, in line with our customer satisfaction priorities, customising their presentation and making recommendations according to our customers' needs, preferences and usage habits;
• planning and implementing our corporate human resources policies in the best possible way;
• correctly planning and conducting our commercial partnerships and strategies;
• ensuring the legal, commercial and physical security of our Company and our business partners;
• ensuring the highest level of personal and commercial data security, establishing an appropriate information infrastructure and databases, and taking administrative and technical measures;
• developing the services offered on our Company website, responding to future requests and complaints, remedying errors arising on this channel and ensuring compliance with the Privacy Policy published on our website;
• carrying out the work required by our relevant business units in order to perform the commercial activities conducted by the Company and running the related business processes;
• determining the Company's strategies and ensuring the corporate functioning of the Company in line with our strategic plans and objectives.

Our Principles for Processing Personal Data

As SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ, we have adopted the following principles:

• a) processing in compliance with the law and the rules of good faith;
• b) endeavouring to ensure that data is accurate and up to date;
• c) processing for specified, explicit and legitimate purposes;
• ç) being relevant, limited and proportionate to the purposes for which data is processed;
• d) retaining data only for the period laid down in the relevant legislation or required for the purpose of processing.

How Personal Data Is Processed

Your data is held and processed at SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ only with your consent or where one of the grounds of lawfulness set out in the Law exists.

To Whom and For What Purpose Processed Personal Data May Be Transferred

Personal data collected and processed by our Company in accordance with the KVKK may be transferred by SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ to its solution partners and to companies acting as performance assistants, solely for the purpose of carrying out the work and subject to confidentiality agreements.

Method of Collecting Your Personal Data and the Legal Grounds

Your personal data may vary depending on the service or commercial activity provided by our Company. In accordance with Articles 4, 5 and 6 of the KVKK, it may be collected verbally, in writing or electronically by automated or non-automated means through offices, the call centre, the website, social media channels, mobile applications and similar means, and may be processed and updated.

Your personal data is obtained in any verbal, written or electronic environment, for the purposes set out above, so that the services we offer can be provided within the defined legal framework and so that our Company can fully and correctly fulfil its contractual and statutory obligations. Personal data collected on this legal basis may also be processed and transferred for the purposes stated in this Disclosure Notice, within the scope of the processing conditions and purposes set out in Articles 5 and 6 of the KVKK.

All necessary technical and administrative measures are taken to protect the personal data collected by SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ, to prevent it falling into the hands of unauthorised persons and to ensure that our customers and prospective customers suffer no harm. In this framework we ensure that software complies with standards, that third parties are selected with care and that our Privacy Policy is observed within the Company.

Rights of the Data Subject and Applications

If, as a data subject, you submit requests concerning your rights listed in Article 11 of the KVKK to our Company by the methods set out in this Disclosure Notice, our Company will conclude the request free of charge within thirty days at the latest, according to its nature. However, if a fee is prescribed by the Personal Data Protection Board, the fee in the tariff determined by our Company will be charged. Furthermore, since under the legislation in force applications concerning personal data must be made by the data subject in person, only the part of your application relating to you will be answered; an application made on behalf of your spouse, a relative or a friend will not be accepted.

In this context, by applying to the contact announced on our website by SDF ENDÜSTRİ DIŞ TİCARET VE LOJİSTİK LİMİTED ŞİRKETİ, you have the right to:

• learn whether your personal data is being processed;
• request information if your personal data has been processed;
• learn the purpose of processing your personal data and whether it is used in accordance with that purpose;
• know the third parties in Türkiye or abroad to whom your personal data is transferred;
• request correction of your personal data if it has been processed incompletely or incorrectly, and request that the action taken be notified to the third parties to whom the data has been transferred;
• request the erasure or destruction of your personal data where the grounds requiring its processing have ceased to exist, even though it was processed in accordance with the KVKK and other applicable legislation, and request that the action taken be notified to the third parties to whom the data has been transferred;
• object to a result arising against you as a consequence of analysis of the processed data exclusively by automated systems;
• claim compensation for damage suffered as a result of the unlawful processing of your personal data.

Making an Application

You may submit your requests concerning the rights listed above to our Company in writing, using the contact details published on our website. Please include in your application your name and surname and a signature if the application is in writing, your Turkish Republic identity number (or nationality and passport number for foreign nationals), your address for notification, your e-mail address, telephone or fax number if any, and the subject of your request. Information and documents relating to the subject should be attached to the application.