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ICC Group Construction, Personal Data Protection Information Text, This information text has been prepared by ICC Group Construction, acting as the data controller, within the scope of Article 10 of the Personal Data Protection Law No. 6698 (“Law”) and the Communiqué on the Procedures and Principles to be Followed in Fulfilling the Information Obligation.

 

1. Data Controller

We process personal data of employees, prospective employees, owners, interns, supplier employees, supplier representatives, product or service recipients, and visitors, in categories reported to the Verbis system, taking into account privacy concerns. The scope of processing by ICC Group Construction, acting as the data controller, is explained in this information document ("Information Document").

 

2. What is the Collection Method and Legal Basis for Personal Data?

Personal data, including sensitive personal data, including health information, is collected through fully or partially automated or, provided that it is part of a data recording system, non-automated means, from the data subject, from geolocation systems, and from the authorized personnel of the company where the supplier's employees work. Personal data may be processed and transferred domestically and internationally, in accordance with the basic principles stipulated by the Law, and within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law, to the real and legal persons specified in this Information Notice, and for the purposes listed below.

 

3. In what cases can the Data Controller process personal data without explicit consent in accordance with the law?

Pursuant to Article 5 of the Law, ICC Group Construction may process personal data it has received in accordance with the law without explicit consent in the following cases:

  • In cases where it is clearly provided for by law,

  • In cases where the Personal Data Owner is unable to give his consent due to a de facto impossibility or where the consent is not legally valid, the processing of personal data is necessary to protect the life or physical integrity of the Personal Data Owner or another person,

  • It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or execution of a contract concluded between ICC Group Construction and the Personal Data Owner,

  • It is necessary for ICC Group Construction to fulfill a legal obligation,

  • Personal data has been made public by the Personal Data Owner,

  • Data processing is necessary for the establishment, exercise or protection of a right,

  • Data processing is necessary for ICC Group Construction's legitimate interests, provided that it does not harm fundamental rights and freedoms. Furthermore, pursuant to Article 6 of the Law, ICC Group Construction may process special personal data it has lawfully obtained without explicit consent in the following cases:

  • Data regarding a person's race, ethnic origin, political opinion, philosophical belief, religion, sect or other belief, appearance and dress, membership of associations, foundations or unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data are special personal data.

  • Special personal data, other than the health and sexual life of the personal data owner, are stipulated by law,

  • Sensitive personal data regarding the health and sexual life of the personal data owner may only be obtained by persons or authorized institutions and organizations under a confidentiality obligation for the purposes of protecting public health, conducting preventive medicine, medical diagnosis, treatment and care services, and planning and managing health services and their financing.

 

 

4. What are the Purposes of Processing Personal Data?

Personal data;

  • Managing Candidate and Internship Application Processes

  • Fulfilling Employment Contract and Legislative Obligations for Employees

  • Managing Employee Benefits and Fringe Benefits Processes

  • Conducting Training Activities

  • Managing Access Authorizations

  • Conducting Activities in Accordance with Legislation

  • Conducting Finance and Accounting

  • Ensuring Physical Space Security

  • Conducting Appointment Processes

  • Following and Conducting Legal Affairs

  • Conducting Communication Activities

  • Planning Human Resources Processes

  • Conducting/Auditing Business Activities

  • Execution of Occupational Health/Safety Activities

  • Execution of Service Procurement Processes

  • Execution of After-Sales Support Services

  • Execution of Service Sales Processes

  • Execution of Performance Evaluation Processes

  • Execution of Contract Processes

  • Execution of Wage Policy

  • Providing Information to Authorized Persons, Institutions, and Organizations

  • Creating and Tracking Visitor Records

 

It may be processed by ICC Grup İnşaat and other real and/or legal persons specified in Article V for this purpose.

 

 

5. To Whom and for What Purposes is Personal Data Transferred?

Collected personal data may be transferred to legally authorized public institutions and organizations, natural persons or private law legal entities, companies/organizations that will establish business contracts with ICC Group Construction, and their business partners, suppliers, and service providers, in accordance with the basic principles stipulated by the Law, the personal data transfer conditions specified in Articles 8 and 9 of the Law, and for the purposes listed below.

 

 

  • Monitoring and Conducting Legal Affairs

  • Obtaining Permits and Executing Assignment Processes for Field Staff

  • Notifying Subscription Initiation and Invoice Payment

  • Ensuring Physical Security of the Site

  • Providing Information to Authorized Persons, Institutions, and Organizations

  • Providing Telephone Lines

  • Providing Access Authorization to Business Partners' Software

  • Meeting Tender Entry Requests

  • Fulfilling Legal Obligations

  • Performing Social Security Institution (SGK) Notifications

  • Printing Cards

  • Opening Corporate User Accounts

  • Paying Personnel Salaries

  • Conducting Contract Processes

  • Keeping Intern Attendance Records

  • Creating E-Prescriptions After Diagnosis

 

Personal data may be transferred by ICC Group Construction to foreign countries that have been declared to have adequate protection by the Personal Data Protection Board (“Foreign Country with Adequate Protection”) or, in the absence of adequate protection, to foreign countries where the data controllers in Turkey and the relevant foreign country have undertaken in writing to provide adequate protection and where the Personal Data Protection Board has granted its permission (“Foreign Country Where the Data Controller Who Has Undertaken Adequate Protection Is Located”).

 

6. What are the Rights of the Personal Data Owner?

  • Within the framework of Article 11 of the Law, the Personal Data Owner has the right to contact the data controller at any time to:

  • Learn whether their personal data has been processed,

  • Request information about their personal data if it has been processed,

  • To learn the purpose of processing personal data and whether it is being used in accordance with its intended purpose.

  • To know the third parties to whom personal data is transferred, both domestically and internationally.

  • To request correction of personal data if it is processed incompletely or incorrectly.

  • Requesting the deletion or destruction of personal data in case the reasons requiring the processing of personal data are eliminated, to be evaluated within the scope of the principles of purpose, duration and legitimacy, Requesting the deletion or destruction of personal data,

  • Requesting the deletion, destruction or anonymization of personal data in case the reasons requiring processing are eliminated, even though they have been processed in accordance with the Personal Data Protection Law No. 6698 and other relevant legal provisions.

  • Request notification of the correction, deletion, or destruction of personal data to third parties to whom personal data has been transferred.

  • Object to the analysis of processed data exclusively through automated systems, leading to a detrimental outcome.

  • Request compensation for damages suffered due to unlawful processing of personal data.

 

has the rights.

 

 

7. How Can Personal Data Owners Exercise Their Rights?

Pursuant to Article 11 of the Law, to exercise their aforementioned rights, Personal Data Owners must fully complete the application form and submit it to ICC Group Construction through the channels specified in the form. Depending on the nature of the request, ICC Group Construction will process the request free of charge as soon as possible and within thirty (30) days at the latest. However, if the process requires additional costs, ICC Group Construction reserves the right to charge the fee set by the Personal Data Protection Board.

 

 

8. For How Long Will Personal Data Be Processed?

Personal data processed for the purposes specified in this Disclosure Statement, in accordance with the Law, will be deleted, destroyed, or anonymized and will continue to be used by ICC Group Construction when the purpose requiring processing ceases pursuant to Article 7 of the Law and/or when the statutes of limitations imposed by law on ICC Group Construction for data processing expire.