SECURITY CAMERA RECORDING SYSTEMS CLARIFICATION TEXT

This Clarification Text applies to the processing of personal data collected through security camera closed circuit recording systems used in the locations of Trakya Grup Plastik Alüminyum ve Cam Sanayi Ticaret Limited Şirketi (“Trakya Group” or “Company”), in accordance with the Personal Data Protection Law No. 6698 (“Law”). It was written with the aim of enlightening data owners regarding the relevant procedures and principles.

1. IDENTITY OF THE DATA CONTROLLER

Trakya Group has the title of “Data Controller” in accordance with KVKK and relevant regulations in terms of personal data obtained from you, and you can reach us through the contact information given below.

Address : Bahçeşehir 2. Kısım Mh. Posta Cd. No: 6/108 Başakşehir/İstanbul

Phone: +90 212 690 61 95

E-mail : info@trakyagrup.com.tr

2. YOUR PROCESSED PERSONAL DATA

Visual data is recorded with the security cameras located in our company’s locations, but audio data (Sound) is not recorded.

3. PURPOSES OF PROCESSING YOUR PERSONAL DATA

Your personal data collected through security cameras may be processed for the following purposes (“Purposes”) within the framework of the personal data processing conditions specified in the fifth and sixth articles of the Law:

  • Ensuring the legal, technical and commercial-occupational security of relevant persons who have a business relationship with our company,
  • Within the scope of ensuring the security of our company’s buildings, to help ensure and protect the safety of our company’s employees, customers and fixtures, and to detect and obtain evidence of possible illegalities,
  • Execution/supervision of business activities,
  • Carrying out goods production and operation processes,
  • Conducting internal audit/investigation activities,
  • Follow-up of requests/complaints,
  • Execution of customer relationship management processes,

4. TO WHOM AND FOR WHAT PURPOSE PROCESSED PERSONAL DATA CAN BE TRANSFERRED

Your collected personal data may be transferred to judicial authorities or relevant law enforcement forces upon request, in order to resolve legal disputes or in accordance with the relevant legislation, within the framework of the personal data processing conditions and purposes specified in the eighth and ninth articles of the Law.

5. METHOD AND LEGAL REASON FOR COLLECTING YOUR PERSONAL DATA

Your personal data collected through security cameras will be processed automatically based on the legal reasons stated in the fifth article of the Law: “it is mandatory for the data controller to fulfill its legal obligations”and““data processing is mandatory for the legitimate interests of the data controller, provided that it does not harm the fundamental rights and freedoms of the relevant person”.It is processed in this way.

6. STORAGE PERIOD OF YOUR PERSONAL DATA

Your personal data is collected electronically through closed circuit camera systems located in our company’s locations, and is stored digitally for a period of 3 (three) months, in line with the purposes specified in the third article of this Information Text.

7. ACCESS AUTHORITY AND DATA SECURITY MEASURES

Only a limited number of Trakya Grup employees have access to the records recorded and maintained digitally. All personnel authorized to access our company’s security camera records and live camera images; It declares that it will protect the confidentiality of the data accessed with a confidentiality commitment.

There is no violation of privacy, and security purposes (such as toilets) are not exceeded. In this data processing, the relevant parties are informed by the data controller or the person authorized by him in accordance with the tenth article of the Law. (Notification letter stating that monitoring and recording will be made is posted at the entrances of the areas where monitoring is carried out)

In accordance with the twelfth article of the Law, all necessary technical and administrative measures are taken to ensure the security of personal data obtained as a result of camera monitoring activities. Access/monitoring of these records is made only by a limited number of company employees or contracted companies who are committed to confidentiality, and the relevant data is recorded digitally in the data recording system. In accordance with the twelfth article of the Law, all necessary technical and administrative measures are taken to ensure the security of personal data obtained as a result of camera monitoring activities.

8. RIGHTS OF THE PERSONAL DATA OWNER AS MENTIONED IN ARTICLE 11 OF LAW NUMBER 6698

We hereby inform you that, as a personal data owner, you have the following rights in accordance with the eleventh article of the Law:

  • Learning whether personal data is processed or not,
  • Requesting information if personal data has been processed,
  • 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,
  • In case personal data has been processed incompletely or incorrectly, to request their correction and to request that the action taken in this context be notified to third parties to whom personal data has been transferred,
  • Requesting the deletion or destruction of personal data in the event that the reasons requiring processing no longer exist, even though it has been processed in accordance with the provisions of Law No. 6698 and other relevant laws, and requesting that the action taken in this context be notified to third parties to whom personal data has been transferred,
  • Objecting to the emergence of a result that is unfavorable to the individual by analyzing the processed data exclusively through automatic systems,
  • In case of damage due to unlawful processing of personal data, they have the right to request compensation for the damage.

In accordance with your legal rights listed above and stipulated in the relevant law and other legislation, you can personally submit your requests via petition to our address above, or have it delivered through a notary public. In addition, in accordance with the fifth article of the “Communiqué on the Procedures and Principles of Application to the Data Controller”, you can contact info@trakyagrup.com.tr by using the registered e-mail (KEP) address, secure electronic signature, mobile signature or the e-mail address you have previously notified our Company and registered in our systems. You can send it to com.tr.

As personal data owners, if you submit your requests regarding your rights to our company through the methods set out in the Personal Data Protection and Processing Policy, our Company will finalize the request free of charge within thirty (30) days at the latest, depending on the nature of the request. However, if a fee is stipulated by the Personal Data Protection Board, our company will charge the fee in the tariff determined by the Personal Data Protection Board.

Regards,

Trakya Grup Plastic Aluminum and Glass Industry Trade Limited Company