Kvkk Policy

ICC Grup İnşaat, Personal Data Protection Clarification Text, This clarification text has been prepared by ICC Grup İnşaat, 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 Fulfillment of the Disclosure Obligation.

  1. Data Controller

It processes personal data in the categories of Employee, Employee Candidate, Owner, Trainee, Supplier Employee, Supplier Official, Product or Service Recipient and Visitors notified to the verbis system, taking into account the issues regarding the privacy of private life. Pursuant to the Law, the extent to which personal data may be processed by ICC Grup İnşaat, as the data controller, is explained in this clarification text ("Clarification Text").


  1. What is the Collection Method and Legal Reason of Personal Data?

Personal data, including sensitive personal data, including health information, are obtained from the person concerned, from systems that can detect location, and from the authority of the company where the supplier employees work, by fully or partially automated or non-automated means, provided that they are part of any data recording system. Personal data may be processed and transferred domestically and abroad in accordance with the basic principles stipulated by the Law, within the scope of the personal data processing conditions and purposes specified in Articles 5 and 6 of the Law, with the real and legal persons specified in this Clarification Text and for the following purposes.

  1. What are the Cases where the Data Controller can Process Personal Data without Explicit Consent?

Pursuant to Article 5 of the Law, in the following cases, ICC Grup İnşaat may process personal data obtained in accordance with the law without seeking explicit consent:
In cases expressly stipulated by law,

  • If the Personal Data Owner is unable to disclose his/her consent due to actual impossibility or if it is mandatory to process personal data for the protection of the life or physical integrity of the Personal Data Owner or someone else in cases where consent is not legally valid,
  • Provided that it is directly related to the establishment or performance of a contract concluded between ICC Group Construction and the Personal Data Owner,
  • it is necessary to process the personal data of the parties to the contract,
  • it is mandatory for ICC Group Construction to be able to fulfill a legal obligation with,
  • Personal data has been made public by the Personal Data Owner,
  • Data processing is mandatory for the establishment, exercise or protection of a right,
  • Provided that fundamental rights and freedoms are not harmed, data processing is mandatory for the legitimate interests of ICC Grup İnşaat.

In addition, pursuant to Article 6 of the Law, in the following cases, ICC Grup İnşaat may process special categories of personal data obtained in accordance with the law without seeking explicit consent:

  • Personal data relating to race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, membership to associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data are sensitive personal data.
  • Sensitive personal data other than the health and sexual life of the personal data subject, if stipulated by law,
  • Sensitive personal data relating to the health and sexual life of the personal data owner can only be held by persons or authorized institutions and organizations under the obligation of confidentiality for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing.

  1. What are the Purposes of Processing Personal Data?


Personal data;

  • Execution of Employee Candidates and Internship Application Processes
  • Fulfillment of Employment Contract and Regulatory Obligations for Employees
  • Execution of Employee Benefits and Benefits Processes
  • Conducting Training Activities
  • Execution of Access Authorizations
  • Execution of Activities in Compliance with the Legislation
  • Execution of Finance and Accounting Affairs
  • Ensuring Physical Space Security
  • Execution of Assignment Processes
  • Monitoring and Execution of Legal Affairs
  • Execution of Communication Activities
  • Planning Human Resources Processes
  • Execution / Supervision of 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

may be processed by ICC Grup İnşaat and other natural and/or legal persons specified in article V.

  1. To Whom Personal Data Is Transferred For What Purpose?

The collected personal data may be transferred to legally authorized public institutions and organizations, natural persons or private legal entities, companies/organizations that will establish a business contract with ICC Grup İnşaat, and their business partners, suppliers, service providers, in accordance with the basic principles stipulated by the Law and the personal data transfer conditions specified in Articles 8 and 9 of the Law and for the following purposes.

  • Monitoring and Execution of Legal Affairs
  • Obtaining permits for personnel to work in the field and Execution of Assignment 
  • Processes
  • Notification of Subscription Initiation and Payment of Invoices
  • Ensuring Physical Space Security,
  • Providing Information to Authorized Persons, Institutions and Organizations
  • Telephone Line Supply
  • Obtaining Access Authorizations to Business Partners' Software
  • Fulfillment of Tender Entry Requests,
  • Fulfillment of Legal Obligation
  • Realization of SSI Notifications
  • Realization of Card Printing
  • Opening Corporate User Accounts
  • Making Personnel Salary Payments
  • Execution of Contract Processes
  • Keeping the intern attendance record
  • Creating an E-Prescription after diagnosis.

ICC Grup İnşaat may transfer personal data to foreign countries declared to have adequate protection by the PDP Board ("Foreign Country with Adequate Protection") or, in the absence of adequate protection, to foreign countries where the data controllers in Turkey and in the relevant foreign country undertake adequate protection in writing and where the PDP Board has permission ("Foreign Country Where the Data Controller Undertakes Adequate Protection").

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

Within the framework of Article 11 of the Law, the Personal Data Owner may at any time apply to the data controller to

  • To learn whether his/her personal data is being processed or not,
  • Request information if their personal data has been processed,
  • To learn the purpose of processing personal data and whether they are used in accordance with their purpose,
  • To know the third parties to whom personal data is transferred domestically or abroad,
  • To request correction of personal data in case of incomplete or incorrect processing,
  • To request the deletion or destruction of personal data in the event that the reasons requiring the processing of personal data disappear, to be evaluated within the principles of purpose, duration and legitimacy, To request the deletion or destruction of personal data,
  • Although it has been processed in accordance with the Law No. 6698 on the Protection of Personal Data and other relevant provisions of the law, to request the deletion, destruction or anonymization of personal data in the event that the reasons requiring its processing disappear
  • To request notification of the correction, deletion or destruction of personal data to third parties to whom personal data are transferred,
  • To object to the emergence of a result to the detriment of the person himself/herself by analyzing the processed data exclusively through automated systems,
  • In case of damage due to unlawful processing of personal data, to demand compensation for the damage
    rights.

  1. How Does the Personal Data Owner Exercise His/her Rights

In accordance with Article 11 of the Law, in order for the Personal Data Owner to exercise the above-mentioned rights, he/she must fill out the application form completely and submit it to ICC Grup İnşaat through the channels specified in the form. ICC Grup İnşaat will finalize the request free of charge as soon as possible and within thirty (30) days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, ICC Grup İnşaat reserves the right to charge the fee in the tariff determined by the Personal Data Protection Board.

  1. How Long Will Personal Data Be Processed?

In accordance with the Law, personal data processed for the purposes specified in this Clarification Text will be deleted, destroyed or anonymized by ICC Grup İnşaat, when the purpose requiring its processing according to Article 7 of the Law disappears and / or the statute of limitations required for the processing of data as ICC Grup İnşaat in accordance with the legislation expires.