YILDIRIM YAPI GRUBU
CLARIFICATION NOTICE ON THE PROTECTION OF PERSONAL DATA

This Information and Clarification Form is arranged in relation to the processing and transferring of the “Personal Data” of natural persons regulated by the Turkish Personal Data Protection Law no 6698 (“PDP Law”). Pursuant to the Law no 6698, all kinds of your updated personal information you have shared with our company shall be considered as “Personal Data”. The safety of your personal data is of utmost importance for us and your personal data will be retained in accordance with the conditions provided by the legislation and in the safest manner possible and for a period of time as required by legal obligations.

1) Data Controller and Representative

In accordance with the Turkish Personal Data Protection Law (“PDP Law”) Law No 6698, your personal data may be processed by “YILDIRIM YAPI GRUBU ULUSLARARASI İNŞAAT VE TURİZM TİCARET LİMİTED ŞİRKETİ”. as the “Data Controller” under those explained below.

 

2) The Method and the Legal Reason for Collecting Personal Data

Your personal data may be collected by our Company through various channels (with your participation in training, conferences and similar settings to be held by YILDIRIM YAPI GRUBU through its headquarters, branches, agencies, sales offices or other subcontractors or business partners and the office and other physical settings where you can get in contact with, call centers, websites, mobile applications and similar electronic operation platforms, social media and other public channels, as well as by means of investigation method, through other group companies or other persons and entities with whom they are contracted, in written and oral or audio or video recording or in other physical or electronic settings, etc.). Your personal data may be collected, processed, transferred and retained for the purposes specified in Articles (b) and (c) herein within the data processing conditions and purposes set forth in Articles 5 and 6 of the PDP Law. Your personal data are retained for a period of time as required by legal obligations or as permitted by legislation and under the conditions to the extent permitted by legislation.

3) Categories Of Personal Data Description

• Contact Information : Telephone number, address, e-mail, IP address and similar contact information.
• Internet (eg browsing history, search history and information about your interaction with our Website)
• Occupational details (eg and career education, training and vocational occupations).
• Family and beneficiary information (eg names and birthday) for insurance and planning services.
• Financial information (eg taxes, bank information).
• Business-related data related to details about products and/or services purchased from us.
• Marketing and contact information for your uses of receiving marketing services from us.

 

Private personal data:  We generally do not collect sensitive or special categories of personal data about individuals other than our own employees. In some cases, YILDIRIM YAPI GRUBU is required to process sensitive personal data of our employees and other third parties. Except in cases where such personal data are disclosed by the individual himself or we have the express consent of the individual, such a transaction only requires YILDIRIM YAPI GRUBU to exercise its rights and obligations as an employer (including for occupational health purposes), to protect the vital interests of individuals, to establish legal demands. Examples of sensitive personal data we may obtain or otherwise hold include:

• The racial, religious or ethnic origins of private individuals, corporate property beneficiaries or applicants.
• Negative information about potential or current applicants that could reveal criminal convictions or criminal information.
• Health data for which processing is necessary to monitor entry to the workplace and to provide a safe environment for our staff, customers and suppliers.

Technical and Usage data: Includes Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technologies on the devices you use to access our Website. Usage data includes information about how you use our Website, products and services.

4) What legal grounds do we rely on to process personal data?

When we collect and use personal data to run our business and provide our products and services, we may rely on the following legal grounds:

• Contract: We may process personal data to fulfill our contractual obligations (or to enter into a contract) that we owe to the data subjects.
• Consent: We can rely on your freely given consent at the time you provide your personal data to us.
• Legitimate interests: We may rely on legitimate interests based on our assessment that the processing is fair, reasonable and balanced and that your interests and fundamental rights do not override those interests. These may include:

– Managing and improving our relationship with you and the organization you represent,

– Protecting the security and integrity of our facilities, Website and other information technology systems (including protecting against malicious, deceptive, fraudulent or illegal activity and prosecuting those responsible for such activity),

– To respond to and communicate with you about your requests, questions and comments,

-To run, evaluate and develop our business,

– To comply with our corporate and corporate social responsibility commitments.

• Legal obligations: We may process personal data to fulfill our legal and regulatory obligations or obligations. Also, to protect ourselves, our employees and our business partners against fraud and other criminal activity and to cooperate with law enforcement and other regulatory agencies.
• Public interest: We may process personal data in the performance of a specific task in the public interest or in the exercise of official authority vested in us.
• Vital interests: We may process personal data to protect the vital interests of the individual or another natural person.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal reason allowing us to do so.

Please note that we may process your personal data without your knowledge or consent, where required or permitted by law, in accordance with the above rules.

 

5) The Purposes of Processing your Personal Data

Please be assured that YILDIRIM YAPI GRUBU will act responsibly and with due care in handling any data and information provided to us by you or provided to us through your visit to our Website and collected by us. In addition, you should be informed that any data and information that is connected to and collected by YILDIRIM YAPI GRUBU on the occasion of your visit to the Website may be stored, processed or transferred for the following purposes:

• Protecting the rights, property and safety of YILDIRIM YAPI GRUBU or any third party;
• Compliance with legal or regulatory obligations;
• Collecting and/or providing statistical aggregated data and information about the Website or its visitors or users;

We may use your personal data to send you updates about our products and services, including special offers, promotions, or new products and services (via email, text message, phone or post).

You have the right to opt out of receiving marketing communications at any time. In this regard, please contact us.

YILDIRIM YAPI GRUBU undertakes not to use, sell or rent your personal data for commercial purposes without your express consent.

6) Do we share personal data with third parties?

We store personal data on servers located in Istanbul, Turkey.

We will not share your information with third parties for direct marketing purposes. YILDIRIM YAPI GRUBU organizations may share your personal information among themselves and disclose your personal information to technology and other service providers, including professional consultants who hold and process the information on their behalf. Every organization is required to protect personal data in accordance with our contractual obligations and data protection legislation.

YILDIRIM YAPI GRUBU may also disclose your personal information if it believes in good faith that it is necessary for the above-mentioned legal and compliance purposes. For these purposes, we may disclose information about you, for example, to courts and litigation parties, insurers, the police and other competent government authorities.

In any scenario, we will be confident that we have a legal basis to share information and document our decision-making, and that we have a legal basis to share information.

We may need to share personal data with external auditors to ensure compliance with legal and regulatory requirements, law enforcement and regulatory agencies to comply with our legal and regulatory obligations, and potential buyers of some or all of our business or during restructuring.

7) Do we use cookies?

Our Website may use cookies. A cookie is a small file that asks permission to be placed on your computer’s hard drive. When you accept, the file is added and the cookie helps analyze web traffic or notifies you when you visit a particular site. You can choose to accept or reject cookies. Most web browsers automatically accept cookies, but you can usually change your browser settings to reject cookies as per your preference. This may prevent you from taking full advantage of the Website.

We cannot place cookies on your computer without your permission, unless it is strictly necessary for the operation of the service we offer on the Website by law.

We use Google Analytics to track how our Website is used so we can make improvements. Our use of Google Analytics requires us to transmit your IP address to Google (but does not provide any other information) – Google uses this information to compile site usage reports for us, but Google may also share this information with other Google services. In particular, Google may use the collected data to contextualize and personalize its own ad network’s ads. For related information:

• Google’s privacy policy
• How Google uses this information

If you have any questions about the cookies we use or would like more information, please contact info@yyg.com.tr

8) Your Rights as Personal Data Subject

As personal data subject, if you send your claims for your rights to our Company pursuant to the below described method, our Company shall bring your claim to a conclusion at no charge as soon as possible depending on the nature of your claim but not later than thirty days. However, if any fee is stipulated by the Personal Data Protection Council, a fee in the tariff determined by our Company shall be charged. In this context, personal data subjects have the right to;

• Find out whether the personal data has been processed,
• Request information if the personal data has been processed,
• Find out the purpose of processing the personal data and whether the data has been used for the intended purpose,
• Find out about the third persons within or out of the country to whom the personal data has been transferred,
• Request the correction any data if they are incompletely or incorrectly processed and request that the third parties to whom the data has been transferred be informed of such correction,
• Even though the personal data have been processed in accordance with the provisions of PDP Law and other relevant law, in the event that the reasons that require processing have ceased, herewith request erasure and destruction of personal data and request that the third parties to whom the personal data transferred be informed of the transaction carried out in this context,
• Even though the personal data have been processed in accordance with the provisions of PDP Law and other relevant law, in the event that the reasons that require processing have ceased, herewith request deletion and destruction of personal data and request that the third parties to whom the personal data transferred be informed of the transaction carried out in this context,
• Object any result arisen from the analysis of the data being processed exclusively through automated systems,
• Request to indemnify that damage if any damage incurred from illegal processing of the personal data.

In accordance with Paragraph 1 of Article 13 of the PDP Law, you may convey your written request to our company to exercise your rights listed above. You may submit your request including a description of the rights you wish to exercise, as mentioned in Article 11 of the PDP Law, by filing the form and along with the documents to prove your identity, in person or send it through notary to Paşa Mah. Hasret Cad. Bomonti Apt. 65/A Şişli İstanbul/Türkiye addressed to YILDIRIM YAPI GRUBU.

Our Company reserves its right to make changes in this clarification notice in case of any possible amendments to the PDP Law and based on the methods to be defined by the Personal Data Protection Council.

9)What we are doing about personal data security?

We have implemented appropriate technical and organizational security policies and procedures to protect personal data from loss, misuse, alteration or destruction. We aim to ensure that access to your personal data is limited to only those who need access to it. Persons with access to data are obliged to maintain the confidentiality of such information. To further protect personal data, we may apply pseudonymization, anonymization and anonymization techniques.

If you have access to parts of our website or use our services, you remain responsible for keeping your user ID and password confidential. Please note that data transmission over the Internet is not completely secure. While we do our best to try to protect the security of your personal data, we cannot ensure or guarantee the security of your data transmitted to our site; Any transmission is at your own risk.

10)How long do we keep personal data?

We retain personal data to provide our services, to stay in touch with you, and to comply with applicable laws, regulations and professional obligations to which we are subject.

We will retain your personal data in our systems for the longest period of time specified: (i) as long as it is necessary for the relevant activity or services; (ii) for any retention period required by law; (iii) until the end of the period during which litigation or investigations relating to the Services may arise.

We retain such personal data for ten (10) years, unless a different time frame applies as a result of business need or certain legal, regulatory or contractual requirements where we retain personal data for those purposes.

11)Who can you contact for privacy questions or concerns?

If you have questions or comments about this Privacy Statement or how we process personal data, please direct your correspondence to: Paşa Mah. Hasret Cad. Bomonti Apt. Send it via e-mail to 65/A Şişli Istanbul/Turkey or info@yyg.com.tr. We aim to respond to you within 30 days of receiving your privacy notices.