BİRİKİM PİLLERİ BATTERY INDUSTRY AND TRADE LTD.STI. POLICY ON THE PROTECTION AND PROCESSING OF PERSONAL DATA
1. PURPOSE OF THE POLICY
BİRİKİM PİLLERİ BATTERY INDUSTRY AND TRADE LTD.STI. (BİRİKİM PİLLERİ) PERSONAL DATA PROTECTION AND PROCESSING POLICY (“Policy”) has been prepared in order to determine the procedures and principles regarding the processing activities carried out by Birikim PİLLERİ and the protection of the personal data being processed.
With the paragraph added to Article 20 of the Constitution as a result of the amendment made in 2010, the protection of personal data was guaranteed by the Constitution and it was decreed that the procedures and principles regarding the protection of personal data would be regulated by law. In this context, Law No. 6698 on the Protection of Personal Data entered into force on 07.04.2016. First of all, on the protection of personal data, which is a constitutional right, BIRIKIM PILLERI makes this a company policy by arranging the necessary works to raise awareness within the company and by harmonizing the internal operation with the legislation on the protection of personal data.
This Policy aims to guide the implementation of the personal data protection law and the regulations set forth in the relevant legislation by BİRİKİM PİLLERİ.
2. DEFINITIONS OF THE GRIP
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OPEN CONSENT |
Consent on a particular subject, based on information and expressed with free will. |
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MAKING IT ANONYMOUS |
Making personal data incapable of being associated with an identified or identifiable natural person under any circumstances, even by matching with other data. |
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PERSONAL DATA OWNER |
The natural person whose personal data is processed. For example; customers, employees. |
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PERSONAL DATA |
Any information relating to an identified or identifiable natural person. |
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PRIVATE PERSONAL DATA |
Data on race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, dress code, membership in associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data are special data. |
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PROTECTION OF PERSONAL DATA |
Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, making available, classifying or using personal data in whole or in part by automatic or non-automatic means provided that it is a part of any data recording system. It is any operation performed on the data, such as blocking. |
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DATA PROCESSOR |
It is the natural and legal person who processes personal data on behalf of the data controller based on the authority given by the data controller. |
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DATA RESPONSIBLE |
It is the natural and 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. |
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PDPL |
Law No. 6698 on the Protection of Personal Data |
3. PERSONAL GIVEN RECORDING MEDIA
Personal data is processed by BİRİKİM PİLLERİ through the following recording media.
* Servers
* Removable memories (USB, Memory Card etc.)
* Information security devices (firewall, log file, antivirus, etc.)
* Personal computers
* Optical discs (CD, DVD, etc.)
* Printer, scanner, copier
* Software (office software, government software)
* Mobile devices (phone, tablet, etc.)
* Non-electronic written, printed and visual media
4. GROUPS OF EMPLOYEE, CANDIDATES, INTERNSHIP AND PHYSICAL VISITORS
4.1. Personal Data Collected Regarding the Intern and Candidate Person Group
BİRİKİM PİLLERİ, regarding the group of candidates who apply to it for job application.;
* Name and Surname
* Birt Place / Date
* Phone Number, Adress
* Educational Status
* Work Experiences
* Professional Experience
* Reference
* Driver's License Information
4.b. Personal Data Collected Regarding the Employee Group
BİRİKİM PİLLERİ, regarding the employee group for the reason and purpose of the employment relationship / performance of the employment contract;
* Name and Surname
* Residence address
* Close information (spouse and children)
* Number of children
* Spouse works / does not work
* Department Workplace
* Start date of work
* Gender
* Date of birth
* Marital Status
* Mission
* Fee
* Bank name-branch
* Account No-IBAN No
* Disability situation
* BES-AGI Form
* Copy of identity card
* Recruitment Periodic Inspection Form
* Certificate of residence
* Criminal record
* Business arrangement
* Overtime Consent
* SRC Certificate
* Diploma
* Recruitment / Periodic Inspection
* Address
* Telephone
* Gender
* Age
* Date/Place of Birth
* Medications Used
* Height Weight
* Hearing test
* Lung film
* Porter Examination
* Blood group
* SFT
* Whole Blood Test
* Disability and Occupational Disease Information
* Past surgeries
* Chronic Ailments
* OHS Expert Registry Number
* Occupational Physician Diploma No.
* IP ADDRESS
* MAC ADDRESS
* ACCESS LOG RECORDS
* Video-Photo
* File number
* Executive cuts
* IBAN NO
* Address
* TRNC
4.c. Purposes of Collection and Processing of Personal Data of Candidates and Interns
BİRİKİM PİLLERİ processes the personal data of the candidate for the following purposes, taking into account the nature of the application:
* Evaluating the qualification, experience, interest and suitability of the Intern or Candidate for the open position,
* If necessary, checking the accuracy of the information submitted by the candidate or contacting third parties and conducting a reference search about the candidate,
* To contact the candidate about the application and recruitment process or, if appropriate, to contact the candidate for any position opened later in the country or abroad,
* To meet the requirements of any legislation or the demands of the authorized institution or organization,
* To develop and improve the recruitment principles applied by BIKIM PILLERI,
* To carry out the activities that should be done within the framework of occupational health and safety
.
4.d. Purposes of Collecting and Processing Personal Data of Employees
BİRİKİM PİLLERİ processes the personal data of the employee group for the following purposes:
* Developing and improving the employment contract principles applied by BİRİKİM PİLLERİ,
* Execution of emergency processes,
* Carrying out audit ethical activities,
* Execution of human resources processes,
* Meeting the demands of authorized public institutions or organizations in disputes that may arise or in a judicial case that may occur,
* In order to fulfill the legal obligations regarding the employment of the employee,
* In order to open a salary account to the personnel, to provide rental cars when necessary, to provide telephone lines, to provide meal cards, to fulfill automatic individual retirement transactions,
* In order to monitor the health conditions necessary for the employee to fulfill his duty;
* In order to follow up the salary liens placed on the employee's salary,
* For the purpose of ensuring and auditing the privacy policies and standards of BİRİKİM PİLLERİ,
* In case of emergencies, in order to contact the persons given by the Employee voluntarily,
* For the purpose of detecting and controlling the entry and exit from work,
* In order to prepare reports and analyzes to the senior management,
* Software, enterprise resource planning, reporting, marketing etc. performing functions such as
* Recording of camera images due to privacy and security practices in the workplace,
* Fulfillment of the requirements determined by laws and regulations (tax legislation, social security legislation, law of obligations legislation, commercial law legislation, occupational health and safety law, electronic communication legislation, etc. all relevant legislation)
* To carry out the activities that should be done within the framework of occupational health and safety.
4.e. Methods of Collection and Processing of Personal Data of Employees and Candidates
During the recruitment process, the personal data of the candidates are collected by the following methods and means together with or in addition to other methods and means specified in this Policy:
* Application form published in print or electronic media,
* Resumes submitted by candidates to BİRİKİM PİLLERİ via e-mail, cargo, reference and similar methods.
* BİRİKİM PİLLERİ processes the collected personal data automatically or non-automatically through computer systems and human resources personnel.
* Employment or consultancy companies, İşkur, HR sites and Linkedin,
* Controls carried out to confirm the accuracy of the information submitted by the candidate and researches made by BİRİKİM PİLLERİ.
* BİRİKİM PİLLERİ processes the collected personal data automatically or non-automatically through computer systems and human resources personnel.
4.f. Reference Research on Candidates and Interns
BİRİKİM PİLLERİ, can conduct a reference search about candidates and interns with the information that candidates and interns have specified by filling in the relevant fields in the job application form. The reference research to be conducted will generally aim to confirm the accuracy of the information given by the candidate and the trainee. In addition, it will be among the aims of the research that can be done to determine the information that the candidate and the intern keep about himself and that may cause risks in terms of BİRİKİM PİLLERİ. The obligation to inform the persons who will be contacted for reference research will be fulfilled by the BİRİKİM PİLLERİ representative at the time of the first communication. Within the scope of the reference research to be made, necessary personal data such as identity information, work and education experiences of the candidates can be shared with third parties. In addition, personal data about interns and candidates can be obtained from third parties. Interns and Candidates can always contact BİRİKİM PİLLERİ about the reference research to be made about them.
4.g. Rights of Employees and Candidates Regarding Personal Data
Candidates who want to exercise their rights arising from Article 11 of the Law on the Protection of Personal Data No. 6698 (“PDPL”) can apply to BİRİKİM PİLLERİ within the scope of the procedures and principles explained in this Policy.
4.h. Of The Personal Data Collected During The Internship And Candidacy Process, Which Will Continue To Be Processed In The Case Of Recruitment
All personal data collected and processed about the intern and the candidate during the recruitment processes are transferred to the personnel file if the candidate is decided to be employed in the relevant vacant position.
4.ı.Security of Personal Data of Employees, Interns and Candidates
BİRİKİM PİLLERİ oes not discriminate between data subject groups (such as candidates, trainees) in terms of the security of the personal data it processes. Detailed information about the security of personal data can be found in the section of this document on the security of personal data.
5. CUSTOMER
5.a. Personal Data Collected Regarding Customers
Although it may vary depending on the service, product or commercial activity offered to the customer by BİRİKİM PİLLERİ; Your personal data below is processed verbally, in writing or electronically, provided by BİRİKİM PİLLERİ and during your use of BİRİKİM PİLLERİ products and services:
* Name surname
* Address
* Telephone
* TRNC
* Bank IBAN Number Information (During return transactions)
* Billing information
5.b. Personal Data Collected Regarding Supplier or Supplier employee
* Name and surname
* Phone number,
* E-mail address (contact information),
* Address
* Turkish Identity Number
* Company Current Information
* Signature
5.c. Purposes of Collection and Processing of Customers and Supplier official or Supplier employee Data
BİRİKİM PİLLERİ, processes the personal data of the customer for the following purposes, taking into account the service it provides to the customer and the business relationship between them:
* Cargo provided to the customer, etc. the proper delivery of services.
* Making use of the data for sending the Waybill Invoice
* To use for dispute resolution in any dispute
* Execution of Activities in Compliance with the Legislation
* Execution of Goods Service After Sales Support Services
* Execution of Goods/Service Sales Processes
* Execution of Goods/Services Production and Operation Processes
* Execution of Goods/Service Purchasing Processes
* Performing audit activities
* It is processed for the purpose of closing the non-conformities.
* Execution of execution
* Information received from the supplier or customer for payment or collection transactions
5.d. Collection and Processing Methods of Customers' Personal Data
During the interview and/or evaluation process, customers' personal data may be collected by the following methods and means, together with or in addition to other methods and means specified in this Policy:
* Oral, written or electronic media; by e-mail, written petition/ suggestion-request forms/ technical service forms.
* It is requested from the relevant person, fair, meeting etc. events,
* Via website
* Via Call Center
5.e. Customers' Rights Regarding Personal Data
Customers who want to exercise their rights arising from the Personal Data Protection Law No. 6698 (“PDPL”) can apply to BİRİKİM PİLLERİ within the scope of the procedures and principles explained in this Policy.
6. PRINCIPLES ON THE PROCESSING OF PERSONAL DATA
BİRİKİM PİLLERİ, shows a special sensitivity to the protection of personal data as a company policy and acts in the light of the following basic principles in this direction.
6.a. Processing in Compliance with Law and Integrity
In the processing of personal data, the principles introduced by legal regulations and the general rule of trust and honesty are followed.
6.b. Ensuring Personal Data Is Accurate and Up-to-Date When Necessary
Periodic controls and updates are carried out to ensure that the processed personal data of individual groups are accurate and up-to-date, and necessary measures are taken accordingly. In this context, systems for checking the accuracy of personal data and making the necessary corrections are created within the body of BİRİKİM PİLLERİ.
6.c. Processing for Specific, Explicit, and Legitimate Purposes
Personal data is processed based on clear, specific and legitimate data processing purposes. The purpose for which the data will be processed is detailed below.
6.d. Being Related to the Purpose for which they are Processed, Limited and Measured
Personal data is processed in a measured, purpose-related and limited manner in order to achieve the foreseen purpose/purposes, and the processing of personal data that is not related to the realization of the purpose or that is not needed is avoided.
6.e. Retention for as Long as Required for the Purpose of Processing or Envisioned in the Relevant Legislation
BİRİKİM PİLLERİ retains personal data only for as long as required by the relevant legislation or for the purpose for which they are processed. In this context, first of all, it is determined whether a period is foreseen for the storage of personal data in the relevant legislation, if a period is determined, this period is acted upon. In the event that the period expires or the reasons requiring its processing are eliminated, personal data is deleted, destroyed or anonymized in accordance with the Personal Data Storage and Disposal Policy of BİRİKİM PİLLERİ, unless there is a legal reason allowing them to be processed for a longer period of time.
7. TERMS OF PROCESSING PERSONAL DATA OF PERSON GROUPS
The explicit consent of the relevant groups of persons is only one of the reasons for compliance with the law that makes it possible to process personal data in accordance with the law. Apart from express consent, personal data may also be processed in the presence of one of the other legal compliance reasons listed below. The basis of the personal data processing activity can be only one of the following reasons for compliance with the law, or more than one of these conditions can be the basis of the same personal data processing activity. If the processed personal data is special quality personal data; The conditions set out in the heading "Conditions in which Special Categories of Personal Data may be Processed" below apply. Person groups are informed about the personal data processed by this Policy, for what purposes and for what reasons their personal data is processed, from which sources their personal data is collected, with whom this personal data will be shared and how it will be used.
7.a. Explicitly Provided in Laws
In cases where the laws expressly stipulate the processing of personal data, BİRİKİM PİLLERİ processes personal data without obtaining the explicit consent of the groups of persons whose data will be processed. For example, processing personal data in processes such as membership, granting commercial electronic permission, order, payment, delivery, cancellation or return of the product in accordance with the Law on the Regulation of Electronic Commerce.
7.b. Failure to Obtain the Explicit Consent of the Person Related to the Cause of Actual Impossibility
If the personal data of the group of persons who are unable to express their consent due to actual impossibility or whose consent cannot be validated are required to be processed in order to protect the life or bodily integrity of the person or another person, the data may be processed without the explicit consent of the individual group.
7.c. Being Directly Related to the Establishment or Performance of the Contract
Provided that it is directly related to the establishment or performance of a contract, the data may be processed if it is necessary to process the personal data of the parties to the contract.
7.d. The Fulfillment of its Legal Obligation by BİRİKİM PİLLERİ
In case the processing is necessary to fulfill legal obligations as a data controller, personal data of the individual group may be processed without obtaining explicit consent.
7.e.Making Personal Data of Person Groups Public
If the personal data of the person group has been made public by him, the data may be processed without the need for explicit consent. For example, the personal data shared by the Member publicly on the internet and social media accounts can be processed if this sharing is in accordance with his will and to the extent.
7.f.Mandatory Data Processing for the Establishment or Protection of a Right
If data processing is necessary for the establishment, exercise or protection of a right, the data may be processed without the explicit consent of the individual group. For example, putting the information in this complaint file based on a complaint made by the member to the court.
7.g.Processing of Data Based on Legitimate Interest
Provided that it does not harm the fundamental rights and freedoms of the individual group, personal data may be processed without the explicit consent of the individual group, if data processing is necessary for the legitimate interests of BİRİKİM PİLLERİ. For example, making satisfaction surveys by BİRİKİM PİLLERİ in order to ensure customer satisfaction.
7.e.Processing of Personal Data of Person Group Based on Explicit Consent
In cases where the personal data of the person group cannot be processed based on any of the conditions specified in article 5(2) above, it will be processed on the basis of express consent.
8. SITUATIONS WHERE SPECIAL QUALITY PERSONAL DATA MAY BE PROCESSED
Some of the personal data is regulated separately as "personal data of special nature" and is subject to special protection.
8.a.Processing of Private Personal Data Based on Explicit Consent
Special categories of personal data can be processed by taking the necessary administrative and technical measures and the principles set forth in this Policy, in case of the explicit consent of the person group.
8.b.Cases in which Private Personal Data can be Processed without Express Consent
Special categories of personal data may be processed in the following cases, provided that adequate measures to be determined by the Personal Data Protection Board (“Board”) are taken, in cases where there is no explicit consent of the person group:
* Special categories of personal data other than the health and sexual life of the person group, in cases stipulated by the laws,
* Special categories of personal data related to the health of the individual group, on the other hand, can only be collected by persons or authorized institutions and organizations under the obligation of confidentiality for the purposes of protecting public health, conducting preventive medicine, medical diagnosis, treatment and care services, planning and management of health services and financing.
9. ENLIGHTENING AND INFORMING THE PERSON GROUP
During the acquisition of personal data, the person group is informed by BİRİKİM PİLLERİ. In this context, the identity of the BİRİKİM PİLLERİ contact person, the purpose for which the personal data will be processed, to whom and for what purpose the processed personal data can be transferred, the method of collecting personal data and the rights of the individual groups for legal reasons are notified to them.
In case groups of individuals request information regarding their personal data, they can be sent to the e-mail addresses of cumulative@hs01.kep.tr and kvkk@birikimpilleri.com, registered e-mail (KEP) address, secure electronic signature, mobile signature or e-mail registered in BIRIKIM PILLERI systems. By sending an e-mail using the -mail address or by sending a written application to the address KEMANKEŞ KARAMUSTAFAPAŞA MAHALLESİ HALİL PAŞA SOKAK NO: 1A/ BEYOĞLU İSTANBUL, the necessary information is given.
10. CATEGORIZATION OF PERSONAL DATA
Within the scope of this POLICY, the personal data of the person groups in the following categories are processed by BİRİKİM PİLLERİ:
* Credential
* Communication information
* Location Data
* Personal Information
* Legal Process and Compliance Information
* Customer Transaction Information
* Physical Space Security Information
* Transaction Security Information
* Financial Information
* Professional Experience Information
* Visual and Audio Data
* Health Information
11. PURPOSE OF PROCESSING PERSONAL DATA
11.a.Processing Conditions
Personal data is processed limited to the following conditions. These conditions are;
* The relevant activity regarding the processing of your personal data is clearly stipulated in the law,
* The processing of your personal data by BİRİKİM PİLLERİ is directly related to and necessary for the establishment or performance of a contract,
* Processing of personal data is mandatory for BİRİKİM PİLLERİ to fulfill its legal obligation,
* Provided that the personal data has been made public by the person group; processing by BİRİKİM PİLLERİ in a limited way for the purpose of publicizing,
* Processing of personal data by BİRİKİM PİLLERİ is mandatory for the establishment, exercise or protection of rights of BİRİKİM PİLLERİ or individual groups or third parties,
* It is obligatory to process personal data for the legitimate interests of BİRİKİM PİLLERİ, provided that it does not harm the fundamental rights and freedoms of individual groups,
* If the personal data processing activity by BİRİKİM PİLLERİ is necessary for the protection of the life or physical integrity of the data subject or someone else, and in this case, the person concerned is unable to express his consent due to actual impossibility or legal invalidity.
In the absence of the above-mentioned conditions; BİRİKİM PİLLERİ seeks the express consent of personal data owners in order to process personal data.
11.b. Processing Purposes
BİRİKİM PİLLERİ processes personal data for the following purposes:
For Candidate-Employee-Trainee Group:
* Realization of recruitment processes,
* Evaluation of candidates,
* Creation of the personnel file,
* Ability to evaluate performance,
* Determining whether it is capable of constantly fulfilling the requirements of the job,
* Carrying out general insurance, private insurance and other transactions of people working within the framework of employment contracts,
* Managing the fringe benefits processes, performing periodic health checks, making entry and exit procedures,
* Carrying out legal proceedings
For Customer Group:
* Evaluation of the proposal and request forms filled in by the customer and development of the business.
* Performing the services provided to customers in a healthy manner.
* Carrying out legal proceedings
* Installation, shipping, etc. provided to customers. healthy delivery of services..
For the public official, administrative institution employee, representing the authority carrying out the investigation or trial:
* Providing information and documents that may be needed in the management of legal and administrative processes.
* Fulfillment of legal obligations.
* Receiving and Evaluating Suggestions for Improving Business Processes for Execution / Supervision of Business Activities
* Execution of Logistics Activities
* Execution of Goods/Service Procurement Processes
* Execution of Goods Service After Sales Support Services
* Execution of Goods/Service Sales Processes
* Execution of Goods/Services Production and Operation Processes
* Legal requirement
* Dispute Resolution
For Online Visitor:
* Compliance with legal regulations.
* Logging of system activities of online visitors and users..
For Shareholder/Partner:
* Providing information and documents that may be needed in the management of legal and administrative processes
12. TRANSFER OF PERSONAL DATA TO DOMESTIC AND/OR OVERSEAS THIRD PARTIES
Personal data belonging to the business group can be transferred to third parties (third party companies, third real persons) by taking the necessary security measures in line with the processing purposes.
12.a. Transfer of Personal Data
Personal data may be transferred to third parties if the conditions stipulated in Article 8 and Article 9 of the PDPL are fulfilled. Anonymous information and site usage habits of online visitors who are not members of the site are collected and shared with cookies.
12.b. Third Parties and Purposes of Transfer of Personal Data
Your personal data may be transferred to the following data subject groups:
* To business partners (Independent Auditors, Contracted insurance companies),
* With the people who follow these accounts on the company's social media accounts (for photos and videos taken with the express consent of the people (including photo sharing) at celebrations and events within the company),
* Legally authorized public institutions and organizations,
* Legally authorized private legal persons (Company Lawyer/Legal Advisor, Workplace Physician). Your personal data is transferred for the following purposes:
* Developing and improving the employment contract principles applied by BİRİKİM PİLLERİ,
* Execution of emergency processes,
* Meeting the demands of authorized public institutions or organizations in disputes that may arise or in a judicial case that may occur,
* Evaluating performance and determining wage policies.
13. SECURITY OF PERSONAL DATA
In order to ensure the security of personal data, reasonable measures are taken to prevent unauthorized access risks, accidental data loss, deliberate deletion of data or damage to data.
All necessary technical and physical measures are taken to prevent access to personal data by anyone other than the authorized persons. In this context, the authorization system is designed in such a way that it is not possible for anyone to access more personal data than necessary. While ensuring the security of sensitive personal data such as health data, more stringent measures are taken compared to other personal data.
Authorized persons are subject to necessary security checks. In addition, these people are educated about their duties and responsibilities. Access to personal data records are kept to the extent technical possibilities allow, and these records are reviewed at regular intervals. In case of unauthorized access, an investigation is initiated immediately.
BİRİKİM PİLLERİ complies with the following obligations in order to ensure the security of the data processed:
* Acting lawfully and honestly in matters related to the protection of personal data,
* Accurate, complete and complete processing of personal data,
* Carrying out the necessary work in order to update the outdated personal data,
* Informing the relevant manager when he/she realizes any illegality in the processing of personal data,
* To make the necessary guidance in order to exercise the legal rights regarding personal data.
14. LEGAL RIGHTS OF PERSON GROUPS AND METHODS OF USE
14.a. Rights Regarding Personal Data Under PDPL
The rights that individual groups can use regarding personal data are included in Article 11 of the PDPL and are as follows::
* Learning whether personal data is processed,
* If personal data has been processed, requesting information about it,
* Learning the purpose of processing personal data and whether they are used in accordance with the purpose,
* Knowing the third parties to whom personal data is transferred in the country or abroad,
* Requesting correction of personal data in case of incomplete or incorrect processing,
* Requesting the deletion or destruction of personal data within the framework of the conditions stipulated in the relevant legislation,
* Requesting notification of the transactions made pursuant to subparagraphs (d) and (e) to third parties to whom personal data has been transferred,
* Objecting to the emergence of a result against the person himself by analyzing the processed data exclusively through automated systems,
* To request the compensation of the damage in case of loss due to the unlawful processing of personal data.
14.b. Principles Regarding the Exercise of Rights Regarding Personal Data
In order to exercise their rights regarding personal data, individuals can send their e-mail addresses to bilgikk@hs01.kep.tr and kvkk@birikimpilleri.com, registered e-mail (KEP) address, secure electronic signature, mobile signature or e-mail registered in BIRIKIM PILLERI systems. They will be able to apply by sending an e-mail using their address or using the KVK Application Form on the www.birikimpilleri.com page. Applications made in this way will be answered within 30 days at the latest.
15. EFFECTIVENESS AND UPDATE
This Policy entered into force on 26.11.2020. The policy may be updated in order to adapt to changing conditions and legislation. Information about the relevant update will be given at www.birikimpilleri.com.
Click for the BİRİKİM PİLLERİ PDPL Application Form.