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INFORMATION AND CLARIFICATION TEXT

ON THE PROTECTION OF PERSONAL DATA LAW NO. 6698 (KVKK)

Data Controller:
ONTAD GIDA İNŞ. SAN. VE TİC. LTD. ŞTİ.

Address:
Mehmet Akif Ersoy Mah. 1. Öteyaka Küme Evleri No.66/3 Kemalpaşa / İZMİR

Tax No: 6430380520
Mersis No: 643038052000012

From here on referred to as the “Company”; we show maximum sensitivity towards the processing and protection of your personal data. In accordance with the Law on the Protection of Personal Data and related legislation, as the data controller, we undertake all necessary technical and administrative measures to prevent unlawful processing, unauthorized access, and to ensure the secure retention of your personal data.

This clarification text has been prepared by our Company in compliance with the Communiqué on the Procedures and Principles to be Followed in the Fulfillment of the Obligation to Inform under the Personal Data Protection Law (“Law”).

Within this scope, in our capacity as the “Data Controller” as defined by the Law, we would like to inform you. You may access detailed information regarding the purposes of processing your personal data through our Personal Data Processing and Protection Policy.

In full awareness of this responsibility, we process your personal data within the framework and boundaries prescribed by the legislation as explained below. The personal data you share with us as a business partner, supplier, consumer, subscriber, or customer may be processed in accordance with the KVKK, limited to and proportionate with our purposes of activity and services; it may be transferred to third parties, stored, used for profiling, and classified.

COLLECTION, PROCESSING, AND PURPOSE OF PROCESSING PERSONAL DATA:

Your personal data collected under the relevant legislation shall be processed in accordance with the principles prescribed by the law, either partially or wholly, through automated or non-automated means, provided that it is part of any data recording system; through collection, recording, storage, modification, reorganization.

Your personal data is processed by the Company in accordance with Articles 4, 5, and 6 of the Law and relevant legislation for the following purposes:

  • Management of post-sales support services

  • Tracking of requests / complaints

  • Conducting communication activities

  • Ensuring physical space security

  • Receiving and evaluating suggestions for improving business processes

  • Managing customer relations processes

  • Conducting activities aimed at customer satisfaction

  • Conducting marketing processes for products / services

  • Managing advertisement / campaign / promotion processes

  • Planning and execution of the Company’s commercial and/or business strategies

  • Conducting finance and accounting processes

  • Following up and conducting legal affairs

  • Managing logistics activities

  • Managing procurement processes for goods / services

  • Managing after-sales support services for goods / services

  • Managing sales processes for goods / services

  • Managing production and operation processes for goods / services

  • Managing customer relations processes

  • Managing contract processes

  • Managing strategic planning activities

  • Conducting marketing analysis

  • Conducting activities aimed at customer satisfaction

  • Managing wage policies

  • Ensuring the legal, technical, and commercial-business security of our Company and the persons in business relations with our Company

Your personal data will be processed under the conditions and purposes set forth in Articles 5 and 6 of the KVKK. In cases where explicit consent is required, your explicit consent will be obtained. However, under the conditions specified in Article 5 paragraph 2, personal data may be processed without explicit consent.

In accordance with mandatory provisions of the law, it is essential to keep the information of individuals accurate and up-to-date. Therefore, updates to your personal information may be requested periodically.

Below is a list of personal data categories processed within the framework of our Company’s activities:

  • Identity Information: (ID number, name and surname, place and date of birth, parents’ names, marital status, gender)

  • Contact Information: (Phone numbers, address, email address)

  • Financial Information: (Billing and payment details, bank account number, IBAN number, credit card details, tax ID, tax office, invoices, delivery notes, signature circulars, delivery-receipt documents, information in contract annexes with third parties)

  • Marketing Information: (Shopping history, website visit history)

  • Legal Transaction Information: (Legal communications with individuals, services provided, legal disputes involving courts, prosecutors, mediators, arbitration boards, judiciary correspondences, lawsuit and enforcement files)

  • Visual and Audio Data: (CCTV recordings)

  • Physical Space Security Information: (CCTV recordings)

RETENTION PERIOD

Your personal data will be retained by our Company for no less than the statute of limitations for the relevant legal relationship, and at least 10 (ten) years. Physical space security data will be retained for 1 (one) month. After these periods expire, your personal data will be deleted, destroyed, or anonymized by our Company or upon your request, in accordance with the Law and relevant regulations. You may withdraw your consent for processing data other than those required by law at any time.

CONDITIONS FOR PROCESSING PERSONAL DATA (ARTICLE 5)

Personal data cannot be processed without the explicit consent of the data subject, except in the following cases:

  1. It is clearly stipulated in laws.

  2. It is necessary for protecting the life or physical integrity of the person or another person where the data subject cannot express consent due to actual impossibility.

  3. It is necessary for the performance of a contract.

  4. It is necessary for the data controller to fulfill its legal obligation.

  5. It has been made public by the data subject.

  6. It is necessary for the establishment, exercise, or protection of a right.

  7. It is necessary for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject.

CONDITIONS FOR PROCESSING SPECIAL CATEGORIES OF PERSONAL DATA (ARTICLE 6)

  1. Personal data regarding race, ethnic origin, political opinion, philosophical beliefs, religion, sect or other beliefs, attire, association, foundation or union membership, health, sexual life, criminal convictions and security measures, and biometric and genetic data are special categories of personal data.

  2. Processing of special categories of personal data without explicit consent is prohibited.

  3. Except for health and sexual life data, special categories of personal data may be processed without explicit consent if stipulated by law. Health and sexual life data may be processed without explicit consent only by persons or authorized bodies under confidentiality obligations for purposes such as public health, preventive medicine, medical diagnosis, treatment and care services, health services management and financing.

  4. Adequate safeguards determined by the Board must be taken for processing special categories of personal data.

TRANSFER OF PERSONAL DATA AND PURPOSE

Your personal data may be transferred under Articles 8 and 9 of KVKK to our business partners, affiliates, subsidiaries, suppliers, technology support providers, and authorized public institutions, provided necessary precautions are taken and within the purposes specified above.

TRANSFER ABROAD:
Your personal data processed based on the legal grounds stated in Article 5(2) of KVKK may be transferred abroad without explicit consent of the data subject under Article 9(2) of KVKK through databases of online software systems located abroad, either:

  • To foreign countries declared by the Board as having adequate protection (“Countries with Adequate Protection”),

  • To foreign countries where data controllers in Turkey and such countries provide written undertakings for adequate protection and where Board permission has been obtained (“Countries with Undertaking for Adequate Protection”).

METHOD AND LEGAL GROUNDS FOR COLLECTING PERSONAL DATA:

Your personal data may be collected through various means (Company headquarters, branches, subcontractors, business partners, physical offices, websites, digital platforms, social media, public sources, events, research, group companies, third parties) through written, oral, visual, or electronic media.

RIGHTS OF DATA SUBJECT (ARTICLE 11)

Pursuant to Article 11 of the Law, everyone has the right to apply to the data controller and:

  • Learn whether personal data is being processed,

  • Request information if their personal data has been processed,

  • Learn the purpose of processing and whether it is used accordingly,

  • Know the third parties to whom data is transferred domestically or abroad,

  • Request correction of incomplete or inaccurate data,

  • Request deletion or destruction of data under Article 7 of the Law,

  • Request notification of such corrections or deletions to third parties,

  • Object to decisions made solely on automated processing,

  • Demand compensation for damages arising from unlawful processing.

HOW TO EXERCISE YOUR RIGHTS:

You may submit your requests as per the “Communiqué on Procedures and Principles of Application to Data Controllers” via the following methods:

  • By sending a signed application to our address: Mehmet Akif Ersoy Mah. 1. Öteyaka Küme Evleri No.66/3 Kemalpaşa / İZMİR

  • Via email to inquiries@ontad.com.tr with the subject “Request under the Law on Protection of Personal Data”

  • Via secure electronic signature, mobile signature, or via the KEP address: ontad@hs01@kep.tr

Your applications will be responded to within 30 days at the latest, depending on the nature of the request, in accordance with the Law. Fees may apply as determined by the Board’s tariff if the process requires additional cost.