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INFINITUM BİLGİ SİSTEMLERİ SANAYİ TİCARET LİMİTED ŞİRKETİ INFORMATION TEXT ON THE PROTECTION AND PROCESSING OF PERSONAL DATA

 

  1. Entrance

As Infınıtum Information Systems Industry Trade Limited Company (“infinitum”, “Company" or "We"), as the Data Controller, we take the utmost care to ensure the confidentiality of your personal data and to process your data in accordance with the relevant legislation while performing the services we offer.

In this context, in accordance with the Personal Data Protection Law No. 6698 (“Law" or "KVKKInformation Text Regarding the Protection and Processing of Personal Data (hereinafter prepared in accordance with the "Referred to as ")''Clarification Text'') is presented for your information to inform you as the owner of your data and to remind you of your rights.

As explained in this Information Text, your personal data and special personal data may be recorded, archived, updated, transferred, classified, and processed in the ways listed in KVKK and relevant legislation within the scope of the relevant legislation.

  1. Information about the Personal Data Protection Law

We would like to inform you about the protection of fundamental rights and freedoms of individuals in the processing of personal data, especially the privacy of private life, and the Law regulating the obligations of real and legal persons processing personal data and the procedures and principles they will comply with.

  • Some Terms Included in the Law

The concepts of personal data, special personal data, data processing and data controller used in this Information Text are used in accordance with the definitions in the Law, and these definitions are as follows:

  • Personal Data: Any information regarding an identified or identifiable natural person
  • Special Personal Data: Data regarding people's race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and clothing, membership of associations, foundations or unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data
  • Data Controller: Natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system

Title : Infınıtum Information Systems Industry Trade Limited Company

Address: Esentepe Mah.Büyükdere Cad. No:201 D:86 K:4 Loft Residence Şişli/İst.

Trade register number : 108205-5 (Istanbul Trade Registry Office)

Internet address : https://www.infinitumit.com.tr/

E-mail address : [email protected]

  • Data Processor: Natural or legal person who processes personal data on behalf of the data controller, based on the authority given by the data controller
  • Relevant Person/Personal Data Owner: Real person whose personal data is processed
  • Processing of Personal Data: Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or using personal data by fully or partially automatic or non-automatic means provided that it is part of any data recording system. Any action performed on data, such as blocking
  • KVK Board: Personal Data Protection Board
  • Explicit Consent: Consent regarding a specific issue, based on information and expressed with free will
  1. Which Personal Data Are Processed?

Within the scope of the legal relationship we will establish depending on the nature of the products and services you will receive from our company; Personal data that varies depending on the type, nature, history of the relationship between the Company and the Relevant Person, the method of obtaining the data and the following purposes, and is processed in accordance with the principles in the Law and our Company's Personal Data Processing and Protection Policy, including, but not limited to, generally as follows:

      Personal Data Category

Explanation

 

 

 

 

 

 

Identity Information

It is data that clearly belongs to an identified or identifiable natural person, is processed partially or fully automatically or non-automatically as a part of the data recording system, and contains information about the person's identity, such as name-surname, TR ID number, nationality information, mother-in-law. Documents such as driver's license, identity card and passport containing information such as father's name, mother's maiden name, place of birth, date of birth, gender, marital status, as well as tax number, SSI number, signature information, etc. information.

Data Owners to whom the Identity Information is Associated:

– Employee, Employee Candidate, Intern, Visitor, Customer Representative

 

 

 

Communication information

Data that clearly belongs to an identified or identifiable natural person, processed partially or fully automatically or non-automatically as part of the data recording system, including telephone number, contact address, e-mail address, registered e-mail address (KEP), fax number, IP address, etc. such information.

Data Owners to whom Contact Information Relates:

– Employee, Employee Candidate, Intern, Visitor, Supplier Representative, Supplier Employee, Customer Representative 

 

 

 

 

 

 

 

 

Personal Information

It is data that clearly belongs to an identified or identifiable natural person, is processed partially or fully automatically or non-automatically as a part of the data recording system, and is processed to obtain information that will be the basis for the formation of personal rights of natural persons who are in a working relationship with the Company. payroll information, disciplinary investigation, employment document records, property declaration information, resume information, performance evaluation reports, SSI documents, embezzlement documents, passport information, photo, bank information, permission form, travel form, expense form, Occupational Health and Safety Certificates , insurance information, driver information, etc. All kinds of information such as.

Data Owners to whom Personnel Information is Related:

– Employee, Intern

 

 

 

 

 

Legal Transaction Information

It is data that clearly belongs to an identified or identifiable natural person, processed partially or fully automatically or non-automatically as a part of the data recording system, within the scope of the Company's legal processes, determination and follow-up of its receivables and rights, and fulfillment of its debts and legal obligations. Processed data includes information such as information in correspondence with judicial authorities, incoming and outgoing documents, and case files.

Data Owners to whom Legal Transaction Information Relates:

– Employee, Intern

 

 

 

 

 

Customer Transaction Information

It is data that clearly belongs to an identified or identifiable natural person, processed partially or fully automatically or non-automatically as a part of the data recording system, and is obtained and generated about the relevant person as a result of the operations carried out by the Company's commercial activities and business units. Information such as central records, invoice, promissory note check information, order information, request information, offer, service number.

Data Owners to whom Customer Transaction Information is Related:

– Potential Product or Service Buyer, Customer Representative

 

 

 

 

Financial Information

It is data that clearly belongs to an identified or identifiable natural person, processed partially or fully automatically or non-automatically as a part of the data recording system, and shows all kinds of financial results created according to the type of legal relationship that the Company has established with the personal data owner. Personal data processed regarding information, documents and records, and data such as bank account number, IBAN number, credit card information, financial profile, asset data, income information.

Data Owners to whom Financial Information Relates:

– Product or Service Receiver, Product or Service Receiver Representative, Potential Product or Service Buyer or Representative, Intern, Employee, Shareholder/Partner

 

 

 

 

 

 

Professional Experience Information

It is data that clearly belongs to an identified or identifiable natural person, partially or fully automatically or non-automatically as a part of the data recording system, and is processed according to the type of legal relationship that the Company has established with the personal data owner, diploma information, courses attended. , in-service training information, certificates, candidate application forms, reference interview information, job interview information, transcript information.

Data Owners to whom Professional Experience Information Relates:

– Intern, Employee Candidate, Employee

 

 

 

 

 

Location Information

 

 

It is data that clearly belongs to an identified or identifiable natural person, processed partially or fully automatically or non-automatically as part of the data recording system, vehicle tracking system etc. used within the scope of the Company's commercial activities and operations carried out by its business units. Information obtained as a result of the systems, such as the location information of the relevant person/company vehicle. 

Data Owners to whom Location Information Relates:

- Worker

 

Physical Space Security Information

It is data that clearly belongs to an identified or identifiable natural person, processed partially or fully automatically or non-automatically as a part of the data recording system, ensuring physical space security and creating visitor records within the scope of the Company's commercial activities and operations carried out by its business units. These are data such as camera recordings, employee and visitor entry and exit information obtained for purposes such as tracking and tracking.

Data Owners to whom Physical Space Security Information is Related:

– Employee, Visitor

 

 

 

 

 

Transaction Security Information

 

It is data that clearly belongs to an identified or identifiable natural person, processed partially or fully automatically or non-automatically as part of the data recording system, within the scope of the Company's commercial activities and operations carried out by its business units and within the scope of the Company's establishment with the personal data owner. processed according to the type of legal relationship; Data such as IP address, password and password information.

Data Owners to whom Transaction Security Information is Related:

– Employee, Intern

 

 

 

 

 

Risk Management Information

 

It is data that clearly belongs to an identified or identifiable natural person, processed partially or fully automatically or non-automatically as part of the data recording system, within the scope of the Company's commercial activities and operations carried out by its business units and within the scope of the Company's establishment with the personal data owner. processed according to the type of legal relationship and to manage commercial, technical and administrative risks; Data such as IP address and signature circular.

Data Owners to whom Risk Management Information Relates:

– Employee, Intern

 

 

 

 

 

 

 

Audiovisual Records

It is data that clearly belongs to an identified or identifiable natural person, processed partially or fully automatically or non-automatically as part of the data recording system, creating and tracking visitor records, customer relations within the scope of the Company's commercial activities and operations carried out by its business units. These are data such as camera images and photographs processed for purposes such as carrying out management processes and ensuring physical space security.

Data Owners to whom Visual and Audio Records are Related:

– Employee, Candidate Employee, Intern, Visitor

 

 

 

 

Health Information

It is data that clearly belongs to an identified or identifiable natural person, processed partially or fully automatically or non-automatically as a part of the data recording system, and is health data such as Health Report, Disabled tax exemption certificates, insurance documents, etc. of the personal data owner.

Data Owners to whom Health Information is Related:

– Employee, Intern

 

 

 

 

 

Criminal Conviction

And

 Security Measures Information

It is data that clearly belongs to an identified or identifiable natural person, processed partially or fully automatically or non-automatically as a part of the data recording system, within the scope of operations carried out by the business units of the Company or in the business of real persons who have a working relationship with the Company. Data such as the criminal record of the personal data owner obtained in order to carry out the processes or to protect the legal and other interests of the Company and the personal data owner.

Data Owners to whom Criminal Conviction and Security Measures Information Relates:

– Employee, Intern

  1. For what purpose and on what legal basis is your personal data processed?

Your personal data obtained by our company may be processed within the scope and legal reasons explained below:

 

ID information

 

1)      Personal Data Processing Purposes

  • Creation and Tracking of Visitor Records
  • Conducting Management Activities
  • Providing Information to Authorized Persons, Institutions and Organizations
  • Execution of Wage Policy
  • Ensuring the Security of Movable Goods and Resources
  • Tracking of Requests / Complaints
  • Conducting Strategic Planning Activities
  • Execution of Contract Processes
  • Carrying out Social Responsibility and Civil Society Activities
  • Carrying out Storage and Archive Activities
  • Conducting Risk Management Processes
  • Execution of Advertising / Campaign / Promotion Processes
  • Conducting Performance Evaluation Processes
  • Conducting Marketing Analysis Studies
  • Organization and Event Management
  • Carrying out Activities for Customer Satisfaction
  • Execution of Customer Relationship Management Processes
  • Execution of Goods / Service Production and Operation Processes
  • Execution of Goods / Service Sales Processes
  • Execution of Goods/Service After-Sales Support Services
  • Execution of Goods / Service Purchasing Processes
  • Carrying out Logistics Activities
  • Carrying out Business Continuity Ensuring Activities
  • Receiving and Evaluating Suggestions for Improving Business Processes
  • Carrying out Occupational Health / Safety Activities
  • Execution/Audit of Business Activities
  • Planning Human Resources Processes
  • Carrying out Communication Activities
  • Conducting Internal Audit / Investigation / Intelligence Activities
  • Follow-up and Execution of Legal Affairs
  • Execution of Assignment Processes
  • Ensuring Physical Space Security
  • Carrying out Finance and Accounting Affairs
  • Conducting Activities in Compliance with Legislation
  • Execution of Access Authorizations
  • Conducting Educational Activities
  • Conducting Audit / Ethics Activities
  • Execution of Fringe Benefits and Benefits Processes for Employees
  • Fulfillment of Employment Contract and Legislation Obligations for Employees
  • Conducting Employee Satisfaction and Loyalty Processes
  • Carrying out the application processes of employee candidates
  • Conducting Employee Candidate / Intern / Student Selection and Placement Processes

 

 

 

 

 

 

2)      Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in line with the realization of the above-mentioned purposes, as specified in the relevant legislation and Article 5 of the KVKK;

● It is clearly stipulated in the law,

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

● It is mandatory for the data controller to fulfill its legal obligation,

● Data processing is mandatory for the establishment, exercise or protection of a right and

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

 It is processed based on legal reasons.

 

Contact information

 

1)      Personal Data Processing Purposes

  • Creation and Tracking of Visitor Records
  • Conducting Management Activities
  • Providing Information to Authorized Persons, Institutions and Organizations
  • Conducting Talent / Career Development Activities
  • Execution of Investment Processes
  • Ensuring the Security of Data Controller Operations
  • Execution of Marketing Processes of Products / Services
  • Execution of Wage Policy
  • Execution of Supply Chain Management Processes
  • Ensuring the Security of Movable Goods and Resources
  • Tracking of Requests / Complaints
  • Conducting Strategic Planning Activities
  • Execution of Contract Processes
  • Carrying out Social Responsibility and Civil Society Activities
  • Carrying out Storage and Archive Activities
  • Conducting Risk Management Processes
  • Conducting Performance Evaluation Processes
  • Conducting Marketing Analysis Studies
  • Organization and Event Management
  • Carrying out Activities for Customer Satisfaction
  • Execution of Customer Relationship Management Processes
  • Execution of Goods / Service Production and Operation Processes
  • Execution of Goods / Service Sales Processes
  • Execution of Goods/Service After-Sales Support Services
  • Execution of Goods / Service Purchasing Processes
  • Carrying out Logistics Activities
  • Carrying out Business Continuity Ensuring Activities
  • Receiving and Evaluating Suggestions for Improving Business Processes
  • Carrying out Occupational Health / Safety Activities
  • Execution/Audit of Business Activities
  • Planning Human Resources Processes
  • Carrying out Communication Activities
  • Conducting Internal Audit / Investigation / Intelligence Activities
  • Follow-up and Execution of Legal Affairs
  • Execution of Assignment Processes
  • Ensuring Physical Space Security
  • Execution of Commitment Processes for Company / Product / Services
  • Carrying out Finance and Accounting Affairs
  • Conducting Activities in Compliance with Legislation
  • Execution of Access Authorizations
  • Conducting Educational Activities
  • Conducting Audit / Ethics Activities
  • Execution of Fringe Benefits and Benefits Processes for Employees
  • Fulfillment of Employment Contract and Legislation Obligations for Employees
  • Conducting Employee Satisfaction and Loyalty Processes
  • Carrying out the application processes of employee candidates
  • Conducting Employee Candidate / Intern / Student Selection and Placement Processes
  • Execution of Information Security Processes

2)      Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in line with the realization of the above-mentioned purposes, as specified in the relevant legislation and Article 5 of the KVKK;

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

● It is mandatory for the data controller to fulfill its legal obligation,

 It is processed based on legal reasons.

 

Location Information

 

1)      Personal Data Processing Purposes

  • Fulfillment of Employment Contract and Legislation Obligations for Employees

 

 

 

 

 

 

2)      Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in line with the realization of the above-mentioned purposes, as specified in Article 5 of the KVKK;

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

● It is mandatory for the data controller to fulfill its legal obligation,

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

 It is processed based on legal reasons.

 

Personal Information

 

1)      Personal Data Processing Purposes

  • Conducting Management Activities
  • Follow-up and Execution of Legal Affairs
  • Execution of Assignment Processes
  • Carrying out Finance and Accounting Affairs
  • Conducting Activities in Compliance with Legislation
  • Conducting Educational Activities
  • Execution of Fringe Benefits and Benefits Processes for Employees
  • Fulfillment of Employment Contract and Legislation Obligations for Employees
  • Conducting Employee Satisfaction and Loyalty Processes
  • Carrying out the application processes of employee candidates
  • Conducting Employee Candidate / Intern / Student Selection and Placement Processes

 

 

 

 

 

 

2)      Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in order to achieve the purposes listed above, as specified in the relevant legislation and Article 5 of the KVKK;

● It is clearly stipulated in the law,

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

● It is mandatory for the data controller to fulfill its legal obligation,

● Data processing is mandatory for the establishment, exercise or protection of a right

It is processed based on legal reasons.

 

Legal Transaction Information

 

1)      Personal Data Processing Purposes

  • Execution of Contract Processes
  • Conducting Performance Evaluation Processes
  • Carrying out Occupational Health / Safety Activities
  • Planning Human Resources Processes
  • Carrying out Communication Activities
  • Conducting Internal Audit / Investigation / Intelligence Activities
  • Follow-up and Execution of Legal Affairs
  • Carrying out Finance and Accounting Affairs
  • Conducting Educational Activities
  • Conducting Audit / Ethics Activities
  • Execution of Fringe Benefits and Benefits Processes for Employees
  • Fulfillment of Employment Contract and Legislation Obligations for Employees
  • Conducting Employee Satisfaction and Loyalty Processes
  • Carrying out the application processes of employee candidates
  • Conducting Employee Candidate / Intern / Student Selection and Placement Processes
  • Execution of Information Security Processes

 

 

 

 

 

2)      Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in order to achieve the purposes listed above, as specified in the relevant legislation and Article 5 of the KVKK;

● It is clearly stipulated in the law,

● Data processing is mandatory for the establishment, exercise or protection of a right.

● It is mandatory for the data controller to fulfill its legal obligation

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

It is collected based on legal reasons.

 

Customer Transaction Information

 

1)      Personal Data Processing Purposes

  • Carrying out Storage and Archive Activities
  • Execution of Customer Relationship Management Processes
  • Execution of Goods / Service Production and Operation Processes
  • Execution of Goods / Service Sales Processes
  • Execution of Goods/Service After-Sales Support Services
  • Execution of Goods / Service Purchasing Processes
  • Carrying out Logistics Activities

 

 

 

 

 

2)      Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in order to achieve the purposes listed above, as specified in the relevant legislation and Article 5 of the KVKK;

● It is clearly stipulated in the law,

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

● It is mandatory for the data controller to fulfill its legal obligation

● Data processing is mandatory for the establishment, exercise or protection of a right

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

It is collected based on legal reasons.

 

Physical Space Security Information

 

1)      Personal Data Processing Purposes

  • Carrying out Storage and Archive Activities
  • Carrying out Occupational Health / Safety Activities
  • Ensuring Physical Space Security

 

 

 

2)      Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in order to achieve the purposes listed above, as specified in the relevant legislation and Article 5 of the KVKK;

● It is clearly stipulated in the law,

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

● It is mandatory for the data controller to fulfill its legal obligation,

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

It is processed based on legal reasons.

 

Transaction Security Information

 

1)      Personal Data Processing Purposes

  • Carrying out Storage and Archive Activities
  • Carrying out Occupational Health / Safety Activities
  • Carrying out Communication Activities
  • Conducting Internal Audit / Investigation / Intelligence Activities
  • Follow-up and Execution of Legal Affairs
  • Ensuring Physical Space Security
  • Conducting Audit / Ethics Activities
  • Execution of Information Security Processes
  • Conducting Emergency Management Processes

 

 

 

 

 

2)      Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in line with the realization of the above-mentioned purposes, as specified in the relevant legislation and Article 5 of the KVKK;

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

● It is mandatory for the data controller to fulfill its legal obligation,

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

It is processed based on legal reasons.

 

Risk Management Information

 

1)      Personal Data Processing Purposes

  • Conducting Management Activities
  • Carrying out Storage and Archive Activities
  • Carrying out Occupational Health / Safety Activities
  • Conducting Emergency Management Processes

 

2)      Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in line with the realization of the above-mentioned purposes, as specified in the relevant legislation and Article 5 of the KVKK;

● It is necessary for the protection of the life or physical integrity of the person or someone else who is unable to express his/her consent due to actual impossibility or whose consent is not given legal validity.

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

● It is mandatory for the data controller to fulfill its legal obligation,

● Data processing is mandatory for the establishment, exercise or protection of a right

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

It is processed based on legal grounds.

 

 

Financial Information

 

1)      Personal Data Processing Purposes

  • Carrying out Finance and Accounting Affairs
  • Fulfillment of Employment Contract and Legislation Obligations for Employees

 

2)      Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in line with the realization of the above-mentioned purposes, as specified in the relevant legislation and Article 5 of the KVKK;

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

It is processed based on legal grounds.

 

Professional Experience Information

 

1)      Personal Data Processing Purposes

  • Conducting Talent / Career Development Activities
  • Conducting Educational Activities
  • Execution of Fringe Benefits and Benefits Processes for Employees

 

2)           Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in line with the realization of the above-mentioned purposes, as specified in the relevant legislation and Article 5 of the KVKK;

● It is clearly stipulated in the law,

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,

● It is mandatory for the data controller to fulfill its legal obligation,

● Data processing is mandatory for the establishment, exercise or protection of a right

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

It is processed based on legal grounds.

 

Audiovisual Records

 

1)      Personal Data Processing Purposes

  • Creation and Tracking of Visitor Records
  • Execution of Customer Relationship Management Processes
  • Ensuring Physical Space Security
  • Execution of Information Security Processes

 

2)       Legal Reasons for Processing Personal Data

Your personal data is processed by our Company in line with the realization of the above-mentioned purposes, as specified in the relevant legislation and Article 5 of the KVKK;

● It is mandatory for the data controller to fulfill its legal obligation,

● Data processing is mandatory for the establishment, exercise or protection of a right

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

It is processed based on legal reasons.

 

Your special personal data obtained by our company may be processed within the scope explained below:

Special Personal Data

 

Health Information

 

1)        Processed Personal Data

2)    Personal Data Processing Purposes

Health report

  • Carrying out Occupational Health / Safety Activities
  • Execution of Fringe Benefits and Benefits Processes for Employees
  • Fulfillment of Employment Contract and Legislation Obligations for Employees

 

 

3)      Legal Reasons for Processing Personal Data

The processing of your health data, other than the limitations specified in Article 6 of the KVKK, will only be processed with your explicit consent.

4)   Personal Data Collection Methods

The above-mentioned personal data is collected through health reports that are requested to be submitted by Employees and Interns upon entry to employment.

 

Criminal Conviction and Security Measures

 

1)      Processed Personal Data

2)  Personal Data Processing Purposes

Criminal Record

  • Follow-up and Execution of Legal Affairs
  • Execution of Fringe Benefits and Benefits Processes for Employees
  • Fulfillment of Employment Contract and Legislation Obligations for Employees

 

3)      Legal Reasons for Processing Personal Data

Your Criminal Conviction and Security Measures data will only be processed based on your explicit consent, apart from the limitations set out in Article 6 of the KVKK.

4)      Personal Data Collection Methods

The above-mentioned personal data is collected through the criminal record document declared by Employees during the employment process.

The categories mentioned above are for informational purposes only, and we may add other categories so that our Company can carry out its future commercial and operational activities. In such cases, our Company will continue to update the specified categories in the relevant texts for you in order to continue to inform you as quickly as possible.

  1. Collection Method and Legal Reason for Your Personal Data

For the purpose of checking the compliance with Article 1, which regulates the purpose of the Law, and Article 2, which regulates the scope of the Law, personal data may be collected through all kinds of verbal, written, electronic media, technical and other methods, through various means such as call center, Company website, and the scope of this Clarification. In order to achieve the purposes stated in the text, it is collected in order to fully and accurately fulfill the responsibilities arising from the law within the framework of legislation, contract, demand and voluntary legal reasons, and is processed by our Company or data processors assigned by the Company.

  1. To whom and for what purpose do we transfer your personal data?

 

Our company carefully complies with the conditions set out in the KVKK regarding the sharing of personal data with third parties, without prejudice to the provisions of other laws. In this context, personal data is not transferred to third parties by our Company without the explicit consent of the data owner. However, in case of one of the following conditions regulated by the KVKK, personal data may be transferred by our Company, based on one or more of the conditions listed below and limited, without obtaining the explicit consent of the data owner:

  • If there is a clear regulation in the law regarding the transfer of personal data,
  • If it is necessary to protect the life or physical integrity of the personal data owner or someone else,
  • If the personal data owner is unable to express his/her consent due to actual impossibility or if his/her consent is not given legal validity,
  • If it is necessary to transfer personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,
  • If personal data transfer is mandatory for our company to fulfill its legal obligations,
  • If personal data has been made public by the personal data owner,
  • If personal data transfer is mandatory for the establishment, exercise or protection of a right,
  • If personal data transfer is necessary for the legitimate interests of our Company, provided that it does not harm the fundamental rights and freedoms of the personal data owner.

Your personal data, in accordance with the law and the purpose of the Law, our Company;

  • Planning and implementing Company Policies in the best possible way,
  • Correct planning, execution and management of commercial partnerships and strategies,
  • Ensuring the legal, commercial and physical security of himself and his business partners,
  • Ensuring corporate functioning, planning and execution of management and communication activities,
  • Ensuring data security at the highest level,
  • Creation of databases,
  • Communicating with personal data owners who submit their requests and complaints to it and ensuring request and complaint management,
  • event management,
  • Management of relationships with business partners or suppliers,
  • Carrying out personnel recruitment processes,
  • Execution/monitoring of financial reporting and risk management transactions,
  • Execution/follow-up of company legal affairs,
  • Carrying out work to protect its reputation,
  • Managing investor relations,
  • Providing information regarding legislation to authorized institutions,

It is transferred only if the personal data processing conditions specified in Articles 5 and 6 of the Law are met, limited to its purposes. Transfer of personal data abroad is carried out with the permission of the KVK Board, in addition to the existence of processing conditions, to countries with adequate protection or to countries that undertake adequate protection. If the processing activity carried out for the aforementioned purposes does not meet any of the conditions stipulated under the Law, the Company obtains the express consent of the relevant person regarding the relevant processing process.

Conditions for Transfer of Special Personal Data

 

Our company takes the necessary care, takes the necessary security measures and takes the adequate precautions prescribed by the KVK Board; In line with legitimate and lawful personal data processing purposes, the special personal data of the personal data owner may be transferred to third parties within the country in the following cases;

If there is explicit consent of the personal data owner,

Without the express consent of the personal data owner; Special personal data other than the health and sexual life of the personal data owner (data regarding race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, appearance and dress, association, foundation or union membership, criminal conviction and security measures and biometric and genetic data) in cases stipulated by law.

In terms of special personal data regarding health and sexual life, provided that adequate precautions are taken;

  • Protection of public health,
  • Preventive medicine,
  • medical diagnosis,
  • Carrying out treatment and care services,
  • Your personal data may be transferred without explicit consent for purposes such as planning and management of health services and financing.

When transferring special personal data, the conditions specified in the processing conditions of this data are complied with.

We present to your information the persons to whom your personal data may be transferred, the purpose of the transfer activity and the reason for legal compliance, through the table below.

 

 

Persons to whom data can be transferred

 

 

 

Data Transfer

 Purpose

 

 

Data Category

 

 

Reason for Compliance with Law

 

 

 

 

 

 

 

 

 

 

 

 

Suppliers

In order to ensure that the services that are outsourced by our Company from the supplier and necessary to carry out our Company's commercial activities are provided to our Company, or to ensure that the establishment purposes of the business partnership established for purposes such as carrying out various projects and receiving services, either personally or with Group Companies, while carrying out the Company's commercial activities are fulfilled. It can be transferred on a limited basis.

· ID information

· Contact information

· Customer Transaction Information

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract.

● It is mandatory for the data controller to fulfill its legal obligation

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

 

 

 

 

 

 

 

 

 

 

Affiliates and Subsidiaries

It can be transferred to companies that are subsidiaries or affiliates of the company, within the scope of the powers and responsibilities brought by its title, in accordance with the provisions of the legislation.

· ID information

· Contact information

· Legal Transaction Information

· Customer Transaction Information

· Financial Information

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract.

● It is mandatory for the data controller to fulfill its legal obligation

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

● Data processing is mandatory for the establishment, exercise or protection of a right

 

 

 

 

 

 

 

Community Companies

It can be transferred to the company(ies) affiliated to the group to which the Company is affiliated, in accordance with the provisions of the legislation.

· ID information

· Contact information

· Location Information

· Personal Information

· Legal Transaction Information

· Transaction Security Information

· Risk Management Information

· Financial Information

· Professional Experience Information

● Explicit Consent of the Personal Data Owner 

 

 

 

 

 

 

Authorized Public Institutions and

 Organizations

It can be transferred to a limited extent for the purpose requested by the relevant public institutions and organizations within their legal authority.

· ID information

· Contact information

· Personal Information

· Legal Transaction Information

· Customer Transaction Information

· Physical Space Security Information

● It is clearly stipulated in the law

● It is necessary for the protection of the life or physical integrity of the person or someone else who is unable to express his/her consent due to actual impossibility or whose consent is not given legal validity.

● It is mandatory for the data controller to fulfill its legal obligation

 

 

 

 

 

 

 

 

 

 

 

Work partners

It can be transferred to persons with whom the Company has a business partnership relationship in order to carry out its commercial activities, in accordance with the provisions of the legislation.

· ID information

· Contact information

· Legal Transaction Information

· Customer Transaction Information

· Financial Information

● It is necessary to process personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract.

● It is mandatory to process data for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the person concerned.

● Data processing is mandatory for the establishment, exercise or protection of a right

 

 

 

 

 

 

 

 

Work health

And

Security Expert

It can be transferred to the Company's Occupational Health and Safety expert on a limited basis for the purpose requested within his legal authority in accordance with the provisions of the legislation.

· Health Information

● It is clearly stipulated in the law

● It is necessary for the protection of the life or physical integrity of the person or someone else who is unable to express his/her consent due to actual impossibility or whose consent is not given legal validity.

● It is mandatory for the data controller to fulfill its legal obligation

 

 

 

 

 

 

Independent Audit Firm

In accordance with the Company's legal obligations, it can be transferred to independent auditing firms that have independent audit authority within the scope of its audit obligation, and for the limited purpose requested within its legal authority in accordance with the provisions of the legislation.

· ID information

· Contact information

· Customer Transaction Information

· Legal Transaction Information

· Financial Information 

● It is clearly stipulated in the law

● It is mandatory for the data controller to fulfill its legal obligation

 

  1. How Do We Protect Your Personal Data and How Long Do We Keep It?

 

In accordance with Article 12 of the Law, our company takes the necessary administrative and technical measures in order to prevent the unlawful processing, disclosure, access, transfer of personal data or any security deficiencies that may occur, and in this context, it also carries out the necessary inspections or has them carried out.

In addition, our Company organizes training for our personnel to ensure awareness about not processing personal data unlawfully, preventing unlawful access to data, and ensuring proper preservation of data.

Our company stores personal data in accordance with the periods required for the purpose for which they are processed and stipulated in the relevant legal legislation. For this reason, our Company first determines whether a period of time is stipulated in the relevant legal regulations for the storage of personal data, and if a period is determined, it acts in accordance with this period. If a period of time is not stipulated in the relevant legal legislation regarding the storage of personal data, personal data are stored for the period necessary depending on the purpose for which they are processed and the activity carried out while processing the data. Accordingly, personal data is processed for a period of time that requires processing in accordance with our Company's practices and the customs of commercial life, and is then deleted, destroyed or anonymized.

By our company, personal data is destroyed by the specified destruction methods (deletion/destruction/anonymization) in accordance with the periodic destruction periods or the application of the data owner, in cases where the periods stipulated in the relevant legal legislation expire and the purpose of processing ends.

You can find detailed regulations regarding the Company's techniques / administrative and technical measures taken regarding the storage, deletion, destruction and anonymization of personal data in our Company's "Personal Data Storage, Destruction and Security Policy". 

 

  1. What are your rights under the law as the "Relevant Person" whose Personal Data is Processed?

 

As Personal Data Owner / Relevant Person;

  • To learn whether personal data is processed in accordance with the relevant legislation,
  • Requesting information about personal data if they have been processed, accessing and requesting personal health data,
  • Learning the purpose of processing personal data and whether they are used for their intended purpose,
  • Knowing the third parties to whom personal data is transferred at home or abroad,
  • Requesting correction of personal data if they are incomplete or incorrectly processed,
  • Request deletion or destruction of personal data; In case personal data has been processed incompletely or incorrectly, to request the correction of personal data and/or the deletion or destruction of personal data to be notified to third parties to whom personal data has been transferred,
  • We hereby inform you that you have the right to object to the emergence of a result against the person by analyzing the processed data exclusively through automatic systems, and to request compensation for the damage in case of damage due to the unlawful processing of personal data.

To exercise your rights to learn whether personal data is being processed, to request information if your personal data is processed, to access and request your personal data, to learn the purpose of processing of personal data and whether they are used for their intended purpose, to know the third parties to whom your personal data is transferred domestically or abroad. If so, the information you request will be notified to you in writing, electronically or via the contact information provided by you.

 

  1. By what methods can you exercise your right to apply under the law?

 

Personal Data Owners / Relevant Persons may exercise their rights listed above (Article 8) in Annex 1(one) of this Information Text (Annex 1: Data Subject Application Form) as well as https://www.infinitumit.com.tr/ By filling out the data subject application form available at;  

 

– A signed copy of our Company's Esentepe Mah.Büyükdere Cad. No:201 D:86 K:4 Loft Residence Şişli/İst.You can deliver it personally to '' address, send it through the Notary Public or by registered letter via PTT, 

 

[email protected] or [email protected] You can send it to with secure electronic signature or mobile signature via your registered e-mail address or e-mail address registered in our system.

We would like to emphasize that in order for third parties to request an application on behalf of Personal Data Owners, they must have a special power of attorney issued through a notary.

 

Our company finalizes the requests in the application free of charge as soon as possible, within thirty days at the latest, depending on the nature of the request. However, if the transaction in question requires an additional cost, the fee in the tariff determined by the KVK Board may be charged. The company may accept the request or reject it by explaining the reason. The company will notify you of the response in writing or electronically. If the request in the application is accepted, the Company fulfills the requirements of the request.

 

In cases where the application is rejected, the response is found to be insufficient, or the application is not responded to in due time; The data owner has the right to file a complaint with the KVK Board within thirty days from the date of learning the answer and, in any case, within sixty days from the date of application.

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