1. Purpose

Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi Data Retention and KVKK compliance procedures; It defines the rules and processes that must be followed in order to protect the confidentiality of the information of our employees, customers, suppliers and all real persons in communication and cooperation with Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi and its subsidiaries, to ensure their accuracy and to ensure access to the information by authorized persons when needed. .

Liteks Plastik In İmperteks Textile Industry and Trade Limited Company; All personal data processed by Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi, including our employees, suppliers, visitors, business contacts, business partners, and third parties, are within the scope of this Policy.

It is our priority to ensure the effective use of the rights of the persons whose data is processed in accordance with the relevant legislation, especially the Law on the Protection of Personal Data No. 6698 (“KVKK”) at Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi. Therefore, but not limited to those listed; Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi We operate the Company in accordance with the Personal Data Protection and Processing Policy (“Policy”).

Protection of personal data and observance of the fundamental rights and freedoms of natural persons whose personal data are collected are the basic principles of our policy regarding the processing of personal data. For this reason, we carry out all our activities in which personal data are processed, taking into account the protection of privacy, the confidentiality of personal information, the confidentiality of communication, freedom of thought and belief, and the right to use effective legal remedies. For the purpose of protecting personal data, we take all administrative and technical protection measures required by the nature of the data in accordance with the legislation and up-to-date technology.

This Policy explains the methods we follow for the processing, storage, transfer, deletion or anonymization of personal data shared during our commercial, promotion-marketing or social responsibility and similar activities within the framework of the principles mentioned in the KVKK.

2. Scope

This procedure covers Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi.

All personal data processed by the Company, including our employees, suppliers, visitors, business contacts, business partners, third parties, are within the scope of this Policy.

Our policy is implemented in all activities related to the processing of personal data owned or managed by the Company, and has been handled and prepared by considering the KVKK and other relevant legislation regarding personal data and international standards in this field.

3. Responsibles

The Board of Directors is responsible for the oversight of the determination and operation of notification, review and sanction mechanisms in case of non-compliance with the Policy, rules and regulations. The Personal Data Protection and Processing Policy has been approved by the Board of Directors. It is the authorized approval mechanism to ensure that the policy is created, implemented and updated when necessary.

Organization Data Controllers; Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi is responsible for the preparation and maintenance of the Personal Data Protection and Processing Policy, ensuring that the policies and procedures are followed. Organization data controllers also have an obligation to inform the Relevant Person about the purpose for which your personal data will be processed and the rights arising from the Law.

KVK YK is responsible for determining the general policies and standards for Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi, supporting and guiding the persons assigned as data controllers to take the administrative and technical measures stipulated in the legislation.

4. Enforcement and Change

This procedure has entered into force as of 31.12.2019.

5. Definitions

Explicit Consent: Consent to a particular subject, based on information and free will, with a clear and unambiguous, limited only to that transaction.

Anonymization: It is the rendering of personal data in no way associated with an identified or identifiable natural person, even by matching with other data.

Employee: Company Personnel.

Personal Data Owner (Relevant Person): The natural person whose personal data is processed.

Personal Data: Any information relating to an identified or identifiable natural person.

Sensitive Personal Data: People’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, health information, fingerprints, clothing, association, foundation or union membership, health, sexual life, punishment his convictions, and data on security measures, as well as biometric and genetic data.

Processing of Personal Data: Obtaining, recording, storing, storing, changing, rearranging, disclosing, transferring, taking over, making available, classifying personal data by fully or partially automatic or non-automatic means provided that it is a part of any data recording system. or any kind of operation performed on the data, such as preventing its use.

Data recording system: It refers to the recording system in which personal data is processed and structured according to certain criteria.

Data Processor: The natural or legal person who processes personal data on behalf of the data controller, based on the authority given by the data controller.

Data Controller: The natural or legal person who determines the purposes and means of processing personal data and is responsible for the establishment and management of the data recording system.

KVK Board: Personal Data Protection Board.

KVK Authority: Personal Data Protection Authority.

KVKK: Law on Protection of Personal Data published in the Official Gazette dated 7 April 2016 and numbered 29677

6. Classification of Personal Data

Special categories of personal data: Data about people’s race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, their clothing, membership to associations, foundations or trade unions, health, sexual life, criminal convictions, and security measures. and biometric and genetic data are personal data of special nature.

Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi receives sensitive personal data of all real persons, including our employees, suppliers, visitors, business contacts, business partners, third parties, with express consent or on the condition that it is in accordance with the law.

Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi acts sensitively in the protection of special quality personal data determined as “special quality” by the KVK Law and processed in accordance with the law. Technical and administrative measures taken for the protection of personal data are carefully implemented in terms of special quality personal data and necessary controls are provided.

7. Processing of Personal Data

As Liteks Plastik İmperteks Textile Industry and Trade Limited Company; It is essential to process the personal data of our employees, suppliers, visitors, business contacts, business partners, and third parties in accordance with the law no. 6698 and the procedures and principles stipulated in other laws. It is obligatory to comply with the following principles in the processing of personal data:

a) Compliance with the law and honesty rules.

b) Being accurate and up-to-date when necessary.

c) Processing for specific, explicit and legitimate purposes.

ç) Being connected, limited and restrained with the purpose for which they are processed.

d) To be kept for the period required by the relevant legislation or for the purpose for which they are processed.

In the processing of personal data, since the consents obtained in accordance with the law within the framework of the legislation in force before the publication date of the Law are considered to be in accordance with the Law in accordance with the above-mentioned provision, unless otherwise stated by the data subjects, the data controllers need to update the existing consents obtained under these conditions or give express consent from the relevant persons again. no need to be taken.

If the personal data collected before the publication of the Law is processed within the scope of the conditions in Articles 5 and 6 of the Law other than express consent, there is no need to obtain explicit consent for these processing activities, and these activities do not need to be carried out based on explicit consent.

8. Our Purposes of Processing Personal Data

Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi processes the personal data of our employees, suppliers, visitors, business contacts, business partners and third parties for the following purposes:

Helping ensure the safety of our employees and customers

Conducting our commercial activities

To provide support services within the scope of the contract and within the framework of service standards

To determine the preferences and needs of our visitors and to shape and update the services we provide within this scope.

To ensure that our legal obligations are fulfilled as required or required by legal regulations.

Evaluating job applications

Liaising with people who have a business relationship with the company

Marketing

Supporting the training, development and career processes of our employees

Compliance management

Vendor / supplier management

make legal reporting

Waybill cutting

Billing

Providing corporate communication

Sending newsletters by SMS, e-mail, doing marketing activities or making notifications.

9. Transfer of Personal Data

Personal data cannot be transferred without the explicit consent of the person concerned.

However: Personal data; It can be transferred without seeking the explicit consent of the person concerned, provided that adequate measures are taken in the second paragraph of Article 5 of the Personal Data Protection Law No. 6698, provided that one of the conditions specified in the third paragraph of Article 6 is met.

Provisions in other laws regarding the transfer of personal data are reserved. In the transfer of personal data abroad, it is essential that the person concerned has express consent.

With this; In the transfer of personal data abroad, it can be transferred abroad without the explicit consent of the person concerned, provided that there is adequate protection in the country and systems in which the data is transferred, and in case of lack of sufficient protection, the data controllers in Turkey and the relevant foreign country undertake in writing to provide adequate protection and the Board has the permission.

Adequate protection information is obtained from the list determined by the Board.

10. Rights of Personal Data Owner

By applying to the data controller of the relevant persons; To learn whether the personal data concerning them are processed, to request them if they are processed, to know the third parties to whom the personal data is transferred in the country or abroad, to correct the data if the content of the data is incomplete or incorrect, to delete or destroy the data if it is unlawful, and to take the actions to be taken accordingly. have the right to be notified to the third parties that they have been disclosed and to demand that the damages be remedied due to the illegal processing of the data.

In this context, it is obligatory for the persons concerned to first submit their requests regarding the implementation of the Law to the data controller.

Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi can apply to data controllers as follows:

Written application: Written application means an application made with a document containing a wet signature in accordance with the general provisions.

Secure electronic signature: Documents signed with a secure electronic signature will also meet the written form requirement.

11. Deletion, destruction or anonymization of personal data

Liteks Plastik In İmperteks Textile Industry and Trade Limited Company; Despite the fact that it has been processed in accordance with the provisions of the KVKK and other relevant laws, in the event that the reasons requiring its processing are eliminated, personal data is deleted, destroyed or anonymized by the data controller ex officio or upon the request of the person concerned.

Liteks Plastik İmperteks Tekstil Sanayi ve Ticaret Limited Şirketi is obliged to take actions regarding the deletion, destruction or anonymization of personal data within 5 years from the date of activation of the law, unless the reasons for processing the data disappear, unless otherwise stated in the law.