We, SMG, attach utmost importance to promoting safety of your personal data which you may disclose to us by using our website, filling subscription, application, information, request and other similar forms regarding our services or otherwise under the provisions of the Personal Data Protection Law no. 6698 (the “PDPL”) and all other applicable regulations.
1-DEFINITION OF PERSONAL DATA
Personal data refers to all kinds of information related to an identified or identifiable person. In that respect, personal data shall mean all kinds of information which is related to the physical, familial, economic, social and similar attributes of a specific person and has the capacity to render the relevant person identifiable in any manner including but not limited to name, surname, date and place of birth, mailing address, identification, tax, insurance, passport, social security, telephone number, vehicle registration plate, IP address, e-mail address, curriculum vitae, references, photographs, visual and voice records, fingerprints, and genetic information which you may disclose to our company.
3-PRINCIPLES REGARDING PROCESSING OF PERSONAL DATA
Personal data may only be processed in line with the principles and rules provided in the PDPL and other applicable regulations. When processing personal data, the Company acts in line with the principles and requirements of:
-Compliance with the law and principles of integrity,
-Ensuring personal data is accurate and, if necessary, up-to-date,
-Processing personal data for specific, clear and legitimate reasons,
-Ensuring any processing is moderate, connected and limited to the purpose of processing,
-Storing and keeping the data for the period provided in the relevant regulation or required for the purpose of processing.
4- CONDITIONS FOR PROCESSING PERSONAL DATA
Personal data may not be processed without the explicit consent of data subjects.
Nevertheless, personal data may be processed without the explicit consent of data subjects to the extent:
- Such processing is explicitly provided in the law,
- It is essential for safekeeping the life or physical integrity of the data subject or a third person in the event that the data subject is unable to utter explicit consent owing to actual obstacles or else the explicit consent provided by the data subject is not deemed legally valid, -It is necessary to process the personal data of the parties to a contract provided that any such processing shall be directly related to the execution or performance of the contract,
-It is obligatory for fulfilling legal obligations of the data controller,
-The data subject has already made the data available to the public,
-Processing of personal data is required for creation, use or protection of any right, or
-The relevant processing is required for legitimate interests of the data controller provided that the fundamental rights and freedoms of the data subject are not impaired.
5-PURPOSES OF PROCESSING PERSONAL DATA
We will process your personal data in line with the terms and conditions specified in articles 5 and 6 of the PDPL with a view to enabling relevant business units to conduct the necessary activities to use, improve and implement our corporate services, ascertaining and applying corporate strategies, responding to individual or corporate demands, undertaking all kinds of studies and research activities, and performing accounting, marketing, administrative and operational processes. In addition, we may use your e-mail address in order to send information and marketing communications about our products. We may also collect information about your computer and your visit to our website such as your IP address, geographical location, browser type, redirection source, duration of your visit and number of page views etc. The relevant information may be used for administering the website, enhancing the experience of visitors and for marketing purposes.
6- PURPOSES OF TRANSFERRING PERSONAL DATA
We may transfer your personal data to individuals, enterprises and organizations including, without limitation, third party processors, financial institutions, other third party service providers, business partners, dealers, contractors, applicable regulatory authorities, shareholders, branch offices, group companies, domestic and international subsidiaries, external advisors, governmental authorities, advertisers, analytics providers, third parties which may acquire, take over or perform any merger in terms of part of our business or assets in order to attain the purposes arising from the PDPL and other legal regulation as well as making cooperation to the extent required for conducting and improving our commercial and business processes.
7- METHODS FOR COLLECTING AND STORING PERSONAL DATA
Personal data may be collected verbally, in writing or electronically by means of our corporate units, website, social media platforms, mobile applications and similar tools through automated or non-automated methods although the relevant methods and means may vary based on your relationship with our company.
In that respect, our company will collect personal data by means of:
Demo request forms which may be completed in our website based on the explicit consent of data subjects, All kinds of application and information forms sent to our company, Contracts executed with our company, All kinds of information, documents and forms which will be collected for various organizations and events based on the explicit consent of data subjects, and E-mails.
Personal data will be automatically integrated into our corporate system upon collection. Besides, the relevant personal data will be incorporated into our customer pool. In addition, all kinds of physical documents and forms which are used for sending personal data to our company will be filed and kept in the company.
8- STORAGE OF PERSONAL DATA
We will store your personal data only as long as reasonably necessary for fulfilling the collection purposes including the legal, regulatory, taxation, accounting or reporting requirements. Still, we may store your personal data for a longer period in case of any complaint or if we reasonably become convinced that our relationship with you may result in any litigation. While determining the appropriate storage period, we will take into account the volume, quality and sensitivity of personal data, potential risks of losses which may be incurred as a result of unauthorized use or disclosure of personal data, objectives of processing personal data and our likelihood of attaining those objectives as well as all applicable legal, regulatory, taxation, accounting or reporting requirements.
9- RIGHTS OF DATA SUBJECTS
Under the Personal Data Protection Law no. 6698, data subjects who disclose their personal data to SMG may file an application to our company which acts as the data controller in order to;
1. learn whether or not their personal have been processed,
2. request information about the processing, if applicable,
3. request information about the processing purpose and whether or not the use of the data is fit for the purpose,
4. receive information about the recipient domestic or foreign third parties,
5. ask for correction in case of incomplete or incorrect processing,
6. ask for deletion or destruction of the personal data provided that the principles indicated in other laws regarding deletion, destruction or pseudonymization of personal data shall remain reserved,
7. demand notification of the relevant processes to third persons to whom the personal data have been transferred,
8. object to any unfavourable result for the data subject arising from analysis of processed data with automated systems exclusively,
9. make claims for their losses, if any, incurred as a result of processing activities in violation of the law.
10- APPLICATION TO DATA CONTROLLER
Pursuant to article 13.1 of the PDPL, data subjects who intend to exercise their legal rights shall be required to file an application to our company in writing which may be delivered;
- in person to our office in Gayrettepe Mah. Yıldız Posta Cad. D Plaza No: 52 Giriş Katı Beşiktaş/İstanbul with original signature,
- by notification to our office in Gayrettepe Mah. Yıldız Posta Cad. D Plaza No: 52 Giriş Katı Beşiktaş/İstanbul,
- via a notary to our office in Gayrettepe Mah. Yıldız Posta Cad. D Plaza No: 52 Giriş Katı Beşiktaş/İstanbul,
-via an e-mail with secure electronic signature to be sent to firstname.lastname@example.org, or
- other methods specified in the PDPL and to be determined by the Board.
Pursuant to article 13.2 of the PDPL, we will respond to your applications free of charge in writing or electronic media “as soon as possible, not to be more than thirty days” after receiving your request in line with the requirements of article 13 of the PDPL. Nevertheless, we may charge a certain fee in line with the tariff announced by the Personal Data Protection Board if the processes related to your application require us to incur any cost.
SMG uses a number of technologies such as cookies, markers, labels and scripts etc. in order to identify your browser, monitor your activities on the website and sources of traffic, and evaluate the success of a certain marketing campaign. Cookies are known as small data files containing a series of characters which are sent to your browser via our servers when you have access to our website. You may delete the cookies from your browser at any time.
You will have the option to accept or reject the cookies. Most of the web browsers are designed to accept cookies although you may make settings in order to make sure that your browser will alert you about cookies or reject them. Also, you may reject the cookies by disabling them on your browser.
12- RIGHT TO MODIFICATION