DISCLOSURE TEXT ON PERSONAL DATA PROCESSING

Person Data

Personal data is any information relating to an identified or identifiable natural person. In this context, anonymous information, anonymized information and other data that cannot be associated with a specific person is not considered personal data. (KVKK art.3/I (ç)) Sensitive personal data is data related to race, ethnicity, political opinion, philosophical belief, religion, religious sect or other beliefs, appearance and attire, membership in associations, foundations or trade-unions, data about health, sexual orientation, convictions and security measures, and biometric and genetic data.

GENEL TRANSPORT FORWARDING & TRADE CO. LTD processes personal data with honesty and in compliance with the Law and the applicable legal directives. In so doing GENEL TRANSPORT FORWARDING & TRADE CO. LTD undertakes to maintain data accurately and moderately, update it when necessary, by processing data only for specific, clear and legitimate purposes, if relevant and as limited to the purpose for which data is processed, and store it as long as required by the relevant legislation or for the purpose for which it is processed, while taking all the administrative and technical measures stipulated in the Law, and transferring data only in accordance with the conditions determined by the Law.

DATA PROCESSED BY GENEL TRANSPORT FORWARDING & TRADE CO. LTD

GENEL TRANSPORT FORWARDING & TRADE CO. LTD can process general and sensitive personal data datawith the explicit consent of the data owner and in accordance with the circumstances stipulated in articles 5 and 6 of the KVKK. In accordance with the relevant legislation and principles and disclosure statement herein contained the following data types can be processed by GENEL TRANSPORT FORWARDING & TRADE CO. LTD in compliance with its policy on the Protection, Privacy and Disposal of Personal Data;

• Data for identifying the data owner, such as name, surname, profession, title, information aboutthe institution/organization employing him or her, educational background, employment history, gender, marital status, citizenship, tax liability status and, if applicable, information about parents, guardians and attorneys.
• Data such as date of birth, place of birth, identity number, marital status, gender, blood type, religion and ID picture included in identification documents such as ID, passport, driver’s license, etc.
•  Sensitive personal data, i.e., data related to the ethnicity, political opinion, philosophical belief, religion, religious sect or other beliefs, appearance and attire, membership in associations, foundations or trade-unions, health, sexual orientation, convictions and security measures, including biometric and genetic data (KVKK 6),
• Contact information such as address, e-mail, telephone and fax number, workplace or temporary residence,
• Products, projects and service bids, purchased by and deemed appropriate for the data owner,
• Communications records with GENEL TRANSPORT FORWARDING & TRADE CO. LTD such as emails and other audio and/or video data,
• Information on transactions and actions carried out via e-mail, letter or other means of communication,
• Data obtained through sales, such as order and transaction information through sales channels,
• In case of job application to GENEL TRANSPORT FORWARDING & TRADE CO. LTD data on the resume provided for this purpose and other relevant data,
• In case of employment by GENEL TRANSPORT FORWARDING & TRADE CO. LTD all types of data related to the service contract and the capability to work,
• Video and written records, with a view to ensuring Workplace Security,
• Data on Employees’ Personal and Occupational Health,
• Data required for activities during procurement processes, data required for collection and invoicing: such as Internet protocol (IP) address, device ID, unique identifier information, device type, advertising ID, unique device icon, statistics on website views, inbound and outbound traffic information, redirect URL, internet log information, location information, websites visited and information about the transactions and actions performed through advertisements and e-mail contents on our websites, platforms and internet network.

METHOD AND REASON FOR COLLECTING PERSONAL DATA

Your personal data, whether verbally, in writing or through electronic media, are obtained for the purposes listed below, in order to provide the products and services offered by the company within the identified legal framework, in order to fulfil the contractual and legal obligations of our company completely and accurately, to satisfy the Human Resources procedures and to accomplish our company’s product offer and corporate advertisements.

GENEL TRANSPORT FORWARDING & TRADE CO. LTD has created a policy on the Protection, Privacy and Disposal of Personal Data and announced it both on its website and by other means of communication. Your personal data collected for these legal requirements can also be processed and transferred under the conditions and purposes stipulated in Article 5 and 6 of KVKK.

In addition to obtaining personal data generally from the data owner, GENEL TRANSPORT FORWARDING & TRADE CO. LTD can also obtain the data within the framework of Articles 5 and 6 of KVKK through group companies, business partners and subcontractors, with which GENEL TRANSPORT FORWARDING & TRADE CO. LTD works within its projects, and/or other relevant authorized institutions and organizations, dealers, natural persons, as well as the institutions and organizations that are provided as reference in job applications or included in the applicant’s work and education history, recruitment platforms, and institutions represented by or representing the data owner.

PURPOSE OF COLLECTING PERSONAL DATA AND DESTINATION OF TRANSFERRED DATA

Your collected personal data may be transferred to our business partners, suppliers, Group Companies, Company officials, shareholders, legally authorized public institutions and private persons, within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the KVKK Law for the purpose of ensuring the legal and commercial security of the people who have a business relationship with our company, i.e. administrative operations for communications made by our company, ensuring the security and control of the company’s premises, evaluation process of business partner/customer/supplier, incl. authorized persons or employees thereof, reputation research processes, legal compliance process, audit, financial affairs, etc. in determining and implementing our company’s commercial and business strategies and ensuring the execution of our company’s human resources policies, as well as for the purpose of executing the tasks required by our business units, in order to inform you about and help you benefit from products and services offered by our Company and Group Companies, recommending such products and services, as personalized according to your likes, usage habits and needs.

Third parties, domestic and abroad, to whom the transfer can be made are generally as follows:

• Business partners with the purpose of delivering the purchased and selected products and services,
• Infrastructure service providers and other business partners, suppliers and subcontractors, with the purpose of maintaining them both in physical and digital environments by transferring them into physical archives and/or information systems maintained domestically or abroad,
• Authorized attorneys or representatives,
• Third parties whose consultancy services are used, including lawyers, tax consultants and auditors,
• Legally authorized regulatory and supervisory institutions, public authorities and natural persons.

RIGHTS OF THE DATA OWNER:

Data owners, in accordance with Article 11 of the KVKK have the right to:

• Learn whether personal data is processed or not and, if personal data is processed, request information about it,
• Learn the purpose of the data processing and whether this data is used for the intended purposes,
• Receive information about the domestic or foreign third parties to whom personal data is transferred,
• Request rectification, in case of incomplete or inaccurate processing of data,
• Request the erasure or disposal of personal data, in case the reasons for processing personal data no longer exist,
• Request notification to third parties to whom personal data has been transferred regarding the above-mentioned correction and erasure operations,
• Object to the processing of personal data exclusively by automatic means, in case it leads to unfavourable consequences for the data owner,
• Request compensation, in case of damage resulting from the unlawful processing of personal data.

APPLICATION METHOD REGARDING THE RIGHTS OF THE PERSONAL DATA OWNER

In accordance with paragraph 1 of Article 13 of the KVKK, you can submit your application to exercise the above-mentioned rights, containing the required information, with the following methods, in accordance with the “Notice on the Procedures and Principles of Application to the Data Controller” published in the Official Gazette dated March 10, 2018 at number 30356:

A) Information required in the application:

1. 1. Name and Surname of the applicant.
   2. Turkish ID number, if the applicant is a citizen of the Republic of Turkey, if not, passport number with nationality or identification number, if applicable.
   3. Applicant’s residence or workplace address for service.
   4. Applicant’s e-mail address, telephone, and/or fax number.
   5. The subject of the applicant’s request.
   6. Information and documents regarding the applicant’s request.

B) Application methods that can be used by the applicant;

1. 1. The applicant can personally fill in the application request with the above details in accordance with KVKK 13 and deliver it in person to the company’s address at Cumhuriyet Caddesi No: 123/6 TR 34373 Harbiye Istanbul-Turkey in a sealed envelope bearing the note “Request in accordance with the Law on the Protection of Personal Data” and deliver it in exchange of receipt.
   2. The applicant can send a notification to the Company Address through a Notary Public, adding the note “Request in accordance with the Law on the Protection of Personal Data” on the notification envelope.
   3. The applicant can apply by sending an email to our Company’s Registered Electronic Mail address generaltransport@hs01.kep.tr adding the subject line ” Request in accordance with the Law on the Protection of Personal Data”, with a “Secure Electronic Signature” as defined in the Electronic Signature Law No. 5070.

AMENDMENTS

We reserve the right to make amendments to this Personal Data Protection Information and Disclosure Text from time to time. Updated versions of the text can be accessed from GENEL TRANSPORT FORWARDING & TRADE CO. LTD website. Amendments that are made on the text can be tracked on GENEL TRANSPORT FORWARDING & TRADE CO. LTD website. In principle, such amendments will be uploaded GENEL TRANSPORT FORWARDING & TRADE CO. LTD website and will become effective as of the publishing date, however GENEL TRANSPORT FORWARDING & TRADE CO. LTD may also inform you about the amendments in other ways, as it deems appropriate.