CLARIFICATION TEXT ON THE PROTECTION OF PERSONAL DATA
1. PURPOSE
As SULTAN ET VE GIDA, we respect the privacy of your personal data, attach importance to data security, and consider this issue among our company's priorities. For the purpose of processing and protecting such personal data, we adopt the principles of collecting, processing, and protecting the personal data of our customers, potential customers, website users, employees, employee candidates, former employees of SULTAN ET VE GIDA, interns, company shareholders, company officials, business partners, group company employees, and visitors in accordance with the regulations stipulated in the Law on the Protection of Personal Data No. 6698.
Therefore, we recommend that you carefully read this text, which explains how we process your personal data, with whom we share it, and how you can exercise your rights.
Any personal data belonging to all individuals associated with SULTAN ET VE GIDA, including individuals benefiting from our services, may be recorded, stored, updated, and within the framework permitted by legislation and for as long as your relationship with our company continues processed and shared with 3rd parties, provided that it is in accordance with the Law on the Protection of Personal Data No. 6698, and in compliance with the rules of law and integrity for specific, explicit, and legitimate purposes.
As defined in the Law on the Protection of Personal Data, SULTAN ET VE GIDA determines the information we obtain from you within the scope of our relationship with you, acting as the "Data Controller".
2. DEFINITIONS
In this Clarification Text;
- Personal Data: Refers to any information relating to an identified or identifiable natural person,
- Processing of Personal Data: Refers to any operation performed on personal data, such as collection, recording, storage, preservation, alteration, rearrangement, disclosure, transfer, acquisition, making available, classification, or prevention of use, whether fully or partially automated, or through non-automated means provided that it is part of any data recording system,
- KVKK (Law on the Protection of Personal Data No. 6698): Refers to the Law on the Protection of Personal Data No. 6698, published in the Official Gazette dated April 7, 2016,
- Authority: Refers to the Personal Data Protection Authority,
- Board: Refers to the Personal Data Protection Board,
- Data Processor: Refers to 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: Refers to 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,
- Relevant Person (Data Subject): Refers to the natural person whose personal data is processed,
- Contact Person: Refers to the person who provides liaison with the Authority and the relevant persons. The contact person is not the representative of the Data Controller. The contact person does not have the authority to act on behalf of the Data Controller and is the person to whom requests from the Authority are notified (they do not act as an evaluation authority for questions and requests from Data Subjects, but solely occupy a liaison position).
3. DATA CONTROLLER
- Data Controller: SULTAN ET VE GIDA ÜRT. TİC. VE PAZ. LTD. ŞTİ.
- Address: Macunköy Mah. Gimat Gıda Toptancılar Sitesi 2. Blok No: 56 Yenimahalle / ANKARA
- Telephone: 0 850 346 00 34
- Email: info@sultanet.com
4. APPLICATION
As SULTAN ET VE GIDA; We care about the security, collection, processing, transfer, and destruction of personal data in our possession regarding our customers, potential customers, website users, employees, employee candidates, former employees of SULTAN ET VE GIDA, interns, company shareholders, company officials, business partners, group company employees, visitors, and 3rd parties, within the framework of the Constitution of the Republic of Turkey, international conventions to which our country is a party, and relevant legislation, primarily the Law on the Protection of Personal Data No. 6698.
Within this framework, the personal data you share with us may be processed in compliance with KVKK No. 6698, limited, relevant, and proportionate to our activities and purposes, transferred to third parties domestically and abroad, stored, used for profiling, and classified.
5. PURPOSE OF PROCESSING YOUR PERSONAL DATA
Pursuant to Articles 4, 5, and 6 of KVKK No. 6698, your personal data may be processed with explicit consent in cases where processing conditions do not exist, where expressly stipulated by laws, relating to the establishment or performance of a contract, for the fulfillment of our legal obligations, as mandatory for the establishment, exercise, or protection of a right, for our legitimate interests, or if made public by yourself (the relevant persons). In addition, all your processed personal data will be:
- Processed in accordance with law and the rules of integrity,
- Accurate and up-to-date,
- For specific, explicit, and legitimate purposes,
- Relevant, limited, and proportionate to the purpose for which they are processed,
- Retained for the period stipulated in the relevant legislation or required for the purpose for which they are processed.
Your personal data may be processed by our company for the following purposes without compromising our quality:
- Conducting occupational health and safety activities,
- Planning and monitoring works carried out with business partners, dealers, or suppliers,
- Creating and maintaining customer records,
- Executing customer relations and tracking corporate governance activities,
- Managing and tracking customer requests and complaints,
- Ensuring business continuity,
- Tracking contract processes,
- Tracking and execution of legal processes and communication processes with official institutions,
- Ensuring legal and commercial security,
- Developing and improving the services offered by our company,
- Determining and implementing commercial and business strategies,
- Conducting market research,
- Planning and organizing activities to ensure and/or increase loyalty to products and services,
- Sustaining business and operations,
- Executing sales and purchasing processes,
- Fulfilling warranty obligations,
- Structuring contractual processes such as sales and after-sales support with you as our customers, execution and tracking of all necessary transactions, execution of contract processes and planning and execution of operational processes related to sales,
- Generating and updating efficiency reports by obtaining information on customer-based developments,
- Planning and organizing activities to ensure and/or increase loyalty to products and services,
- Executing company activities and procedures,
- Performing finance and accounting transactions,
- Executing fiscal, accounting, and financial transactions including sales-related invoicing activities, and performing risk management,
- Conducting internal audit processes,
- Fulfilling notification obligations to relevant/authorized public institutions,
- Executing job and internship application and evaluation processes,
- Creating employee personnel files and executing processes related to starting work,
- Executing Human Resources processes,
- Fulfilling obligations arising from employment contracts and legislation for employees,
- Executing educational activities,
- Executing physical security processes,
- Planning information security processes, establishing and managing the information technologies infrastructure,
- Performing risk management,
- For logging activities.
6. METHOD OF COLLECTION AND LEGAL REASON OF YOUR PERSONAL DATA
Your personal data may be collected verbally, in writing, or electronically, whether fully or partially automated, or through non-automated means provided that it is part of any data recording system, for the purposes and scope specified above.
Within the framework of commercial process execution activities; it is collected through various methods verbally, in writing, or electronically, in such a way that it can be obtained from outside our company, including contact forms, fair organizations, business cards, supplier information request forms, other commercial documents, payment information and documents, valuable papers, employee and intern candidate application forms, resumes, e-mail, website, various contracts, mobile applications, consumer complaint forms, our customers, suppliers, and other 3rd parties.
We process your collected personal data within the scope of the purposes specified above, based on the legal grounds under KVKK Art. 5/2-c – for the establishment and performance of a contract, KVKK Art. 5/2-ç – for the fulfillment of our legal obligation, KVKK Art. 5/2-f – within the framework of the legitimate interests of our company, or with your explicit consent.
7. TRANSFER OF YOUR PERSONAL DATA
Your personal data may be transferred, taking data security measures such as data preservation, prevention of unauthorized access, and prevention of unlawful processing, within the scope of the purposes listed above, in accordance with KVKK and current legislation, jointly responsible with SULTAN ET VE GIDA, to: Authorized public institutions and organizations as required by legal legislation obligations and needs, intermediary financial institutions for the purpose of evaluating financial risks, independent audit firms for the purpose of conducting audit processes, institutions providing intermediary/agency services during business trips, organizations, and fair processes, our business partners, suppliers, shareholders, local/international organizations from which we receive support in our business processes, domestic/international organizations cooperating with us and from whom services are received under relevant contracts to carry out activities as SULTAN ET VE GIDA subsidiaries and/or direct/indirect domestic/foreign entities, and other 3rd parties.
8. STORAGE AND DELETION OF DATA
Relevant personal data must be stored for certain periods as required by legislation. Therefore, it is our company's responsibility to store personal data in accordance with the legislation and for the required period. These storage periods are defined in detail on a data basis in the prepared personal data inventory. Personal data is retained for the period foreseen in the legislation or required by its purpose. Data is stored in physical or electronic environments. Necessary security measures for the storage and preservation of data have been taken and a secure environment has been provided by our company. Personal data whose storage period has expired is destroyed in 6-month periods (deletion / destruction / anonymization).
9. YOUR RIGHTS AS A RELEVANT PERSON
Within the framework of Article 11 of KVKK No. 6698, you have the rights to:
- Learn whether your personal data is processed or not,
- Request information if your personal data has been processed,
- Learn the purpose of processing personal data and whether they are used in accordance with their purpose,
- Know the third parties to whom personal data is transferred at home or abroad,
- Request correction of personal data in case of incomplete or incorrect processing,
- Request the deletion or destruction of your personal data within the framework of the conditions foreseen in the KVKK legislation,
- Request notification of the third parties to whom your personal data has been transferred regarding the correction of incomplete or incorrect data and the deletion or destruction of your personal data,
- Object to the occurrence of a result against you by analyzing the processed data exclusively through automated systems,
- Request compensation for the damage in case you suffer damage due to unlawful processing of personal data.
To exercise these rights, by filling out the petition containing your request or the Information Request Form at
www.sultanet.com;
- Including the applicant's identity and address information (documents proving identity must be attached),
- The subject you request being related to you,
- If you are acting on behalf of someone else, being specifically authorized in this regard and documenting your authority,
- The subject you request being clear and understandable;
You can submit it in writing to our company's address at
"Macunköy Mah. Gimat Gıda Toptancılar Sitesi 2. Blok No: 56 Yenimahalle / ANKARA" or via email sent from the email address defined in our system. Within the scope of the above article, depending on the nature of your request, it will be concluded free of charge as soon as possible (within 30 days at the latest) or according to the conditions in the fee tariff determined by the KVKK Board.
As a relevant person, pursuant to Article 14 of the Law on the Protection of Personal Data No. 6698, in cases where the application is rejected, the response is found insufficient, or the application is not answered within due time; you can lodge a complaint with the Board within thirty days from the date you learn the response and in any case within sixty days from the application date with the consent of the person.
Pursuant to Article 28/2 of KVKK No. 6698; personal data owners cannot assert their other rights specified above, except for the right to demand compensation for damages, in the following cases:
- Processing of personal data is necessary for the prevention of crime or criminal investigation.
- Processing of personal data made public by the personal data owner himself/herself.
- Processing of personal data is necessary for the performance of supervisory or regulatory duties and disciplinary investigation or prosecution by authorized and görevli public institutions and organizations and professional organizations having the characteristics of a public institution, based on the authority given by the law.
- Processing of personal data is necessary for the protection of the economic and financial interests of the State regarding budget, tax, and financial issues.
10. OTHER MATTERS
Relevant legal regulations in force regarding the processing and protection of personal data in the processes within the scope of this Clarification Text on the Protection and Processing of Personal Data shall apply primarily.
The Clarification Text is published on the website
"www.sultanet.com" and made available to the relevant persons. Changes and updates can be made in the Clarification Text in order to comply with changing conditions and legislation, and can be presented to the relevant persons via the website written above.