REFSAN ENDÜSTRİYEL FIRIN VE MAKİNA SANAYİ TİCARET A.Ş.
GENERAL PRIVACY NOTICE ON THE PROTECTION OF PERSONAL DATA

Last Updated: February 01, 2024

REFSAN ENDÜSTRİYEL FIRIN VE MAKİNA SANAYİ TİCARET ANONİM ŞİRKETİ extends its sector-specific sensitivity to the security of personal data. With this awareness, we attach great importance to the processing, preservation, and deletion of both private and general personal data belonging to our visitors across all platforms in strict compliance with the Turkish Personal Data Protection Law No. 6698 (KVKK), the secondary regulations (regulations, communiqués, circulars) enacted under this Law, and the binding decisions of the Personal Data Protection Board. Acting as the "Data Controller" as defined by the Law, we process your personal data in the manner explained below and strictly within the boundaries mandated by Turkish legislation.

INFORMATION ABOUT THE DATA CONTROLLER

Pursuant to the Law, REFSAN ENDÜSTRİYEL FIRIN VE MAKİNA SANAYİ TİCARET ANONİM ŞİRKETİ, registered with tax number 734 271 75 35 and residing at 1.OSB 1.Cd. No:2 Merkez-Kütahya, Turkey, serves as the “Data Controller”.

PURPOSES OF PROCESSING PERSONAL DATA

REFSAN ENDÜSTRİYEL FIRIN VE MAKİNA SANAYİ TİCARET ANONİM ŞİRKETİ needs to process personal data while directly fulfilling its legal obligations and in situations indirectly required by these obligations and the services provided. In this context, your personal data is processed by our company to:

Comply with the Law on the Protection of the Consumer No. 6502
Comply with the Law of Fees No. 492
Comply with the Press Law No. 5187
Comply with the Turkish Penal Code No. 5237
Comply with the Code of Criminal Procedure No. 5271
Comply with the Corporate Tax Law No. 5520
Comply with the Law on the Regulation of Publications on the Internet and Combating Crimes Committed by Means of Such Publications No. 5651
Comply with the Electronic Communications Law No. 5809
Comply with the Turkish Code of Obligations No. 6098
Comply with the Turkish Commercial Code No. 6102
Comply with the Tax Exemption Status Letter No. 48107
Fulfill our obligations specified in the Personal Data Protection Law No. 6698 and secondary regulations issued accordingly,
Provide necessary information to relevant public institutions and organizations, judicial or administrative authorities, and law enforcement agencies when required,

Your data is processed within the limits defined by the Law, in accordance with the law and good faith, and is always relevant, limited, and proportionate to these specific purposes.

TRANSFER OF PERSONAL DATA

Within the scope of the purposes listed above and in accordance with the conditions specified in Articles 8 and 9 of the Law, your personal data may be transferred to REFSAN human resources department personnel and supervisors, REFSAN executives, real and legal persons permitted by relevant legislation (including affiliated institutions), primarily TAX OFFICES and other authorized public bodies when necessary, judicial and administrative authorities, law enforcement agencies, occupational health and safety specialists and workplace physicians under confidentiality obligations, relevant financial institutions to pay your wages and other entitlements, institutions we collaborate with for payroll and human resources management systems, insurance companies we work with for private health insurance, humanitarian aid authorities and the relevant ministry, and consulting, technology, and training companies from which we outsource services. Furthermore, due to REFSAN's overseas activities and/or the execution of services received from abroad, relevant employee data may be transferred abroad (in situations where sharing with foreign institutions is inevitable).

REFSAN requests personal information such as your name, age, interests, and e-mail address to provide better service to its customers. This information is used for periodic campaigns, special promotional activities tailored to customer profiles, and data classification to prevent unsolicited e-mails. Additionally, REFSAN may send automated reminders and promotional messages via WhatsApp. Aside from this, our customers' personal information is never shared with third parties without the customer's knowledge or instruction and is strictly not used for commercial purposes. Customer security regarding privacy is maintained at the highest level, with all necessary precautions taken to protect personal data.

METHODS AND LEGAL GROUNDS FOR COLLECTING PERSONAL DATA

Your personal data is collected verbally, in writing, or electronically, through automatic and non-automatic methods by real or legal person data processors authorized by REFSAN ENDÜSTRİYEL FIRIN VE MAKİNA SANAYİ TİCARET ANONİM ŞİRKETİ, via channels such as e-mail, phone, website, various contracts, paper forms, and official records.

In this context, your name-surname, previous surname, Turkish ID number (or Passport/Foreigner ID Number for non-citizens), nationality, parents' names, place of birth, date of birth, gender, marital status, residential address, signature, driver's license, passport photograph, bank account details, phone number, e-mail address, fax number, computer IP address, log records, and general personal data are processed in accordance with paragraphs 2/a-c-ç-e-f of Article 5 and paragraph 3 of Article 6 of the Law, based on the legal ground of REFSAN's legitimate interests, provided that it does not harm your fundamental rights and freedoms.

RIGHTS OF DATA SUBJECTS UNDER THE LAW

By applying to REFSAN at any time, you have the right to:

Learn whether your personal data is being processed, the purpose of processing, and whether it is being used appropriately, and request information if it has been processed,
Know the third parties to whom your data is transferred domestically or abroad in accordance with the Law,
Request correction if you believe your data is processed incompletely or inaccurately,
Request the deletion or destruction of your data within the framework of the conditions stipulated in Article 7 of the Law,
Request that the third parties to whom your data has been transferred be notified of your requests under paragraphs (c) and (d) and perform the same actions,
Object to any negative outcome arising solely from the analysis of your data by automated systems, or demand compensation for any damages you suffer due to unlawful recording or use of your data.

If your application for these purposes requires an additional cost, you will be required to pay the fee determined by the Personal Data Protection Board's Communiqué on the Procedures and Principles of Application to the Data Controller. If your application is answered in writing, no fee will be charged for up to the first 10 (ten) pages, and a processing fee of 1 TL will be charged for each subsequent page. If the response is provided on a recording medium such as a CD or flash drive, a fee equal to the cost of the recording medium will be requested.

Your requests will be finalized as soon as possible and within 30 (thirty) days at the latest, depending on the nature of the request.

To exercise your rights under the Law, you can submit your applications in writing (must be in Turkish as per local regulations) to REFSAN.COM.TR. For more detailed information, you can visit the official website of the Turkish Personal Data Protection Authority (KVKK).

Application Methods:

Filling out the form available at www.refsan.com.tr and delivering a wet-signed copy in person or via a notary public to the address "1.OSB 1.Cd. No:2 Merkez-Kütahya, Turkey",
Filling out the form at www.refsan.com.tr, signing it with your "secure electronic signature" under the Electronic Signature Law No. 5070, and sending the electronically signed form to [email protected] via a registered electronic mail address.

In the application you make to exercise your rights mentioned above; the matter you are requesting must be clear and understandable, the subject you are requesting must be related to you personally, or if you are acting on behalf of someone else, you must present a specific power of attorney certified by a notary public.

According to the “Communiqué on the Procedures and Principles of Application to the Data Controller”, your application must include your name-surname, signature, Turkish ID number (or Passport/Foreigner ID Number), residential or workplace address, e-mail address, phone and fax number, and the subject of the request. Applications lacking these mandatory elements will be rejected by REFSAN ENDÜSTRİYEL FIRIN VE MAKİNA SANAYİ TİCARET ANONİM ŞİRKETİ.

REFSAN ENDÜSTRİYEL FIRIN VE MAKİNA SANAYİ TİCARET ANONİM ŞİRKETİ reserves the right to make changes to this privacy notice at any time due to reasons arising from the Law, secondary regulations, and Board decisions. Changes made to the privacy notice and the updated text will become immediately valid as of the date they are notified to you.