SITTNAK INTERNATIONAL TRANSPORTATION INC. INFORMATION NOTICE REGARDING YOUR PERSONAL DATA
The protection of personal data is of high importance to SITTNAK INTERNATIONAL TRANSPORTATION INC. (hereinafter referred to as “SITTNAK”) and is among our priorities. This information notice has been prepared to inform data subjects about the protection and processing of personal data, which is handled with great sensitivity by SITTNAK.
DEFINITION OF PERSONAL DATA AND PURPOSE OF PROCESSING PERSONAL DATA
In accordance with the Personal Data Protection Law No. 6698 (“KVK Law”), “personal data” refers to any information relating to an identified or identifiable natural person, while “special category personal data” refers to data such as a person’s race, ethnic origin, political opinion, philosophical belief, religion, sect, or other beliefs, attire, membership in associations, foundations, or unions, health, sex life, criminal convictions, and security measures, as well as biometric and genetic data.
SITTNAK processes personal data in accordance with the provisions and rules set forth in the KVK Law and other relevant legislation. The KVK Law establishes principles for the processing of personal data. SITTNAK acts in accordance with these principles in its data processing activities:
a) Compliance with the law and rules of good faith
b) Accuracy and, where necessary, updating
c) Processing for specified, explicit, and legitimate purposes
ç) Being relevant, limited, and proportionate to the purposes for which they are processed
d) Retention for the period required by the relevant legislation or necessary for the purposes for which they are processed
Pursuant to the KVK Law, the primary condition for the processing of personal data is the explicit consent of the relevant person. In a limited number of cases specified in the KVK Law, it is also possible to process personal data without the explicit consent of the relevant person:
a) If there is an explicit provision in the law regarding the processing of personal data;
b) If the owner of the personal data is unable to express their consent due to actual impossibility, or if it is necessary for the protection of the life or physical integrity of the person whose consent is legally valid or another person;
c) If the processing of personal data belonging to the parties to a contract is necessary for the establishment or performance of the contract;
d) If the processing of personal data is necessary for our Company to fulfill its legal obligations;
e) If the personal data has been made public by the data subject;
f) If the processing of personal data is necessary for the establishment, exercise, or protection of a right;
g) If the processing of personal data is necessary for the legitimate interests of our Company, provided that it does not harm the fundamental rights and freedoms of the data subject.
The primary condition for the processing of special category personal data is also the explicit consent of the relevant person. In a limited number of cases specified in the KVK Law, it is also possible to process special category personal data without the explicit consent of the data subject:
a) Special category personal data other than the data subject’s health and sex life, in cases provided for by law;
b) Special category personal data relating to the data subject’s health and sex life, but only for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment, and care services, and the planning and management of health services and their financing, by persons or authorized institutions and organizations subject to confidentiality obligations.
PARTIES TO WHOM YOUR PERSONAL DATA IS TRANSFERRED AND THE PURPOSE OF TRANSFER
By SITTNAK; your job application, the provision of services to you, the execution/follow-up of SITTNAK’s legal affairs, your visit to our facilities, your visit to our website, or personal data obtained by other means may be transferred to third parties in accordance with the personal data processing conditions and purposes specified in Articles 8 and 9 of the Personal Data Protection Law, in line with the purposes of processing your personal data.
SITTNAK may transfer personal data processed in accordance with Articles 8 and 9 of the KVK Law to the following categories of persons within the scope of the legal relationship between you and SITTNAK:
SITTNAK business partners,
Banks and insurance companies,
Institutions and organizations providing health services to employees,
Training companies,
SITTNAK suppliers,
SITTNAK company officials,
Legally authorized public institutions and organizations,
SITTNAK informs the personal data owner of the groups of persons to whom personal data is transferred in accordance with Article 10 of the KVK Law.
PURPOSES OF PROCESSING PERSONAL DATA
SITTNAK processes personal data within the scope of the purposes and conditions specified in Article 5, paragraph 2, and Article 6, paragraph 3, of the Personal Data Protection Law. The purposes for which your personal data is processed may be listed as follows, without limitation: ensuring the legal and commercial security of SITTNAK or its business partners, continuing SITTNAK’s commercial activities, and managing SITTNAK’s human resources and employment policies. These activities may be detailed as follows, without limitation:
Performing after-sales services,
Performing collection transactions, including mail order and transfer instructions,
Providing customers with product/service promotions, information, personalized advertising, campaigns, and other benefits; sending commercial electronic communications within the framework of loyalty programs; conducting surveys and telemarketing; providing various benefits through statistical analysis,
Performing services such as damage management and conducting assessments for the purpose of tracking damages,
Conducting work to improve service quality and provide better service,
Issuing invoices for our services,
Purchasing services from external sources,
Providing customers with the benefits of specialized organizations for services outside our area of expertise and for the purpose of obtaining technology services,
Identity verification,
Responding to questions and complaints,
Taking the necessary technical and administrative measures within the scope of data security,
Ensuring financial reconciliation with relevant business partners and other third parties regarding the products and services provided,
Providing necessary information in line with the requests and audits of regulatory and supervisory authorities and official bodies,
Retaining information related to data that must be stored in accordance with relevant legislation,
Ensuring the consistency of information,
Measuring customer satisfaction,
For employees: creating personnel files, determining whether they are capable of continuously fulfilling the requirements of the job, providing private health insurance, creating health files, taking occupational safety measures
Fulfilling legal obligations
Receiving and evaluating job applications in the personnel recruitment process
Execution/monitoring of financial reporting and risk management processes
Execution/monitoring of legal affairs
Creating and tracking visitor records at company facilities
You can access our “Cookie Policy and Website Privacy Policy” regarding the personal data processed during your visits to our company website.
RETENTION PERIODS FOR PERSONAL DATA
SITTNAK retains personal data for the periods specified in the relevant laws and regulations, where such periods are stipulated.
If the legislation does not specify a period for how long personal data should be stored, personal data is stored for as long as required by SITTNAK’s practices and industry customs in relation to the activity carried out by SITTNAK while processing that data, and then deleted, destroyed, or anonymized in accordance with the relevant policy established by SITTNAK in accordance with the nature of the data. destroyed, or anonymized.
If the purpose of processing personal data has ended and the retention periods specified by the relevant legislation and SITTNAK have expired, personal data may only be retained for the purpose of serving as evidence in possible legal disputes or asserting or defending rights related to personal data. The periods referred to herein are determined based on the statute of limitations periods for asserting the aforementioned right and, even after the statute of limitations periods have expired, based on examples from previous requests made to SITTNAK on the same subjects. In this case, the stored personal data is not accessed for any other purpose and access to the relevant personal data is only provided when it is necessary for use in the relevant legal dispute. Here too, after the aforementioned period has expired, personal data is deleted, destroyed, or anonymized.
For example, the personal data in our employees’ personnel files is stored for the periods specified by the Social Security Institution (SGK) legislation, health and safety records are stored for the periods specified by the Occupational Health and Safety legislation, and visitor records at our bonded warehouse facilities are stored for the periods specified by customs legislation.
RIGHTS OF DATA SUBJECTS
As a data subject, we hereby inform you that you have the following rights under Article 11 of the Law:
To learn whether your personal data is being processed,
To request information about the processing of your personal data,
To learn the purpose of the processing of your personal data and whether it is being used for its intended purpose,
To know the third parties to whom your personal data has been transferred within or outside the country,
To request the deletion or destruction of your personal data when the reasons for processing it no longer exist, even if it has been processed in accordance with the Law and other relevant legal provisions, and to request that this action be communicated to third parties to whom your personal data has been transferred,
Objecting to a result that is detrimental to you arising from the analysis of processed data exclusively through automated systems,
Requesting compensation for damages incurred due to the unlawful processing of your personal data.
You can submit your requests regarding the above-listed rights to our Company by filling out the SITTNAK International Transportation Inc. Data Subject Request Form, which can be accessed from the Personal Data Subject Request Form. Depending on the nature of your request, your applications will be processed free of charge as soon as possible and within a maximum of thirty days; however, if the process incurs additional costs, you may be charged a fee according to the tariff determined by the Personal Data Protection Board.