Clarification Text for Personal Data Processing of WYG Türkiye
As WYG INTERNATIONAL DANIŞMANLIK LİMİTED ŞİRKETİ (Company), we are committed to protecting your personal data. In this regard, we attach great importance to the processing and storage of any sort of personal data belonging to the persons relevant to the Company and under our responsibility including the persons benefitting from our services in accordance with Turkish Personal Data Protection Law no. 6698. As a result of this obligation vested in us, we process your personal data as stated below and in the capacity of “Data Controller” as defined in Turkish Personal Data Protection Law and within the principles of proportionality, restriction, correlativity with the purposes as provided by Turkish Personal Data Protection Law. Within this framework, we would like to clarify the terms for you in the capacity of Data Controller in the scope of Turkish Personal Data Protection Law.
1. What is Personal Data?
Personal data refers to any information relating to an identified or identifiable natural person. Personal data occurs only if the data are related to a natural person who is identified or identifiable.
Personal data belong to a natural person who is identified or identifiable, which is registered singularly by reference to an identifier (ID, IP address, name); as well as being reports (such as customer complaint reports, performance appraisal reports, interviewer’s appraisal reports) records (such as voice or visual records, pictures, user records), documents (such as CVs, pay rolls, invoices, bank receipts, credit card statements, copies of the birth certificate), correspondences (such as letters, invitation letters) relevant to that natural person, who is identified or identifiable.
2. What Does Personal Data Processing Mean?
Personal data processing means any operation which is performed on personal data by partly or completely automated means, or on sets of personal data by non-automated means such as collection, recording, organisation, structuring, storage, maintenance, alteration, retrieval, acquisition, dissemination or making available, alignment or restriction of use.
3. What are the Purposes for Which We Process Your Personal Data and How Do We Process Them?
Your personal data, which varies by the services provided by our Company and the commercial activities of our Company, is processed after their collection in writing, orally or electronically and whether or not by automated means, by the units and offices of our Company, other companies we are in cooperation with, suppliers, websites, social media, mobile applications and similar instruments. Your personal data can be updated and processed with a view to knowing you and understanding your needs better, responding your requests more quickly and improving our communication with you as long as you benefit from the products and services offered by our company and we are in cooperation.
Your personal data may also be processed when you refer to our website to benefit from our products and services, visit our website or Company, participate in the training programmes, seminars or events organised by our Company.
Your collected personal data will be processed within processing terms and conditions specified in the Article 5 and 6 of Turkish Personal Data Protection Law for the purposes of conducting required activities within our departments so that you can benefit from the products and services offered by our Company, measuring your satisfaction about the products and services offered by our Company, improving and diversifying our products and services in line with your demands and needs, as well as practising necessary quality and standard auditing in accordance with the relevant law and legislations or fulfilling our reporting and other obligations in accordance with the law and legislations which our Company or subsidiaries are subject to.
The data of our employees can be processed by the Company, by a natural or legal person that is authorised by or in cooperation with our Company due to such operational reasons as to increase the the employee performance level and satisfaction, ensure work safety and peace within our human resources policy and in accordance with the obligations provided by Labour Law, labour and social security legislation and other legislation in effect.
4. Procedures and Purposes for Transfer of Personal Data to Third Parties
Your personal data can be transferred at home or abroad for the purposes stated above but not limited thereto, in accordance especially with Turkish Constitution and Turkish Personal Data Protection Law and shared with but not limited to subsidiaries and affiliates within our Company; business associates, suppliers, company officials, shareholders, public agencies and private persons authorised by law within the framework of the terms and purposes on transfer of personal data laid down in the Article 8 and 9 of the Turkish Personal Data Protection Law.
5. The Rights of Data Subject As Per the Article 11 Of Turkish Personal Data Protection Law
As per the Article 11 of Turkish Personal Data Protection Law, natural persons whose personal data are under process have the right to:
- Learn whether or not her/his personal data have been processed;
- Request information as to processing if her/his data have been processed;
- Learn the purpose of processing of the personal data and whether data are used in accordance with their purpose;
- Know the third parties in the country or abroad to whom personal data have been transferred;
- Request rectification in case personal data are processed incompletely or inaccurately and request notification of the operations made in this respect to third parties to whom personal data have been transferred;
- Request deletion or destruction of personal data although they have been processed in accordance with Turkish Personal Data Protection Law and other provisions in case where the reasons for the personal data processing have expired; and request notification of the operations made in this regard to third parties to whom personal data have been transferred
- Object to occurrence of any result that is to her/his detriment by means of analysis of personal data exclusively through automated systems;
- Request compensation for the damages in case the person incurs damages due to unlawful processing of personal data.
Our company will conclude the requests included in the application free of charge and as soon as possible considering the nature of the request and within 30 days at the latest should you, as data subject, send your requests regarding your rights through the means specified in the clarification text herein. However, in case the operation necessitates a separate cost, the fee in the tariff designated by the Board of Protection of Personal Data may be collected.
In accordance with the Article 13 (1) of Turkish Personal Data Protection Law, you may submit your requests to our Company in writing or by other means that will be specified by the Board of Protection of Personal Data. In this framework, the means and procedures that you should follow in order to submit your application including your requests within the scope of the Article 11 of Turkish Personal Data Protection Law are as follows:
In order to use the rights aforementioned, please submit your application including the requests regarding the right you would like to use along with the information necessary to determine your identity in accordance with the article 11 of Turkish Personal Data Protection Law;with original signed version of Data Subject Access Request Form which you may find enclosed that may be submitted in person through a registered and reply-paid letter or notary to the address: WYG Binası Mustafa Kemal Mahallesi 2128. Sokak No:14 06520 Çankaya, Ankara / TÜRKİYE; or through other means specified in Turkish Personal Data Protection Law. Otherwise, original signed version of the data subject access request form should be submitted to firstname.lastname@example.org via e-mail with a secure electronic signature.
In your application including the requests regarding the right you would like to use as data subject, the requested subject should be a personal matter, which should be stated clearly and precisely; if you act on behalf of another person, you should have the specific authority therefor and be capable of certifying thereof in addition to which the application should include the credentials and address details along with the supporting documents certifying your identity.
We kindly request your information.