1. General Provisions
This personal data processing policy is prepared in accordance with the requirements of the Personal Data Federal Law (hereinafter referred to as the Personal Data Law) and outlines the procedures for processing personal data and the measures taken to ensure the security of personal data by AEZ KİMYA SANAYİ VE DIŞ TİCARET LİMİTED ŞİRKETİ (hereinafter referred to as the Operator).
1.1. The Operator's primary objective and condition for conducting its activities is to respect the rights and freedoms of individuals when processing their personal data, including protecting the rights to privacy, personal, and family secrets.
1.2. This Operator's policy on the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://aez.com.tr/.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data - the processing of personal data using computer technology.
2.2. Blocking of personal data - the temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website - a collection of graphic and informational materials, as well as computer programs and databases that provide their availability on the Internet at the network address https://aez.com.tr/ .
2.4. Information system of personal data - a set of personal data contained in databases, as well as the information technology and technical means that ensure their processing.
2.5. Anonymization of personal data - actions that make it impossible to determine the ownership of personal data to a specific User or another subject of personal data without using additional information.
2.6. Processing of personal data - any action (operation) or a combination of actions (operations) performed with personal data, whether automated or not, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.
2.7. Operator - a state authority, a municipal authority, a legal entity, or an individual who independently or jointly with others organizes and (or) carries out personal data processing, as well as determines the purposes of personal data processing, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://aez.com.tr/
2.9. Personal data permitted for distribution by the data subject - personal data to which the data subject has granted access to an unlimited number of persons by giving consent to the processing of personal data, personal data permitted for distribution in the manner provided by the Personal Data Law (hereinafter - personal data permitted for distribution).
2.10. User - any visitor to the website https://aez.com.tr/.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an unspecified group of persons (transfer of personal data) or providing access to personal data to an unlimited number of persons, including the publication of personal data in mass media, placement in information and telecommunications networks, or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.
2.14. Destruction of personal data - any actions that result in the irreversible destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or the destruction of material carriers of personal data.
3. Operator's Basic Rights and Responsibilities
3.1. The Operator has the right to:
- Receive accurate information and/or documents containing personal data from the data subject.
- In case the data subject revokes their consent for personal data processing, the Operator has the right to continue processing the personal data without the data subject's consent, if there are grounds specified in the Personal Data Law.
- Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations prescribed by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The Operator is obligated to:
- Provide the data subject, upon request, with information concerning the processing of their personal data.
- Organize the processing of personal data in accordance with the current legislation of the Republic of Türkiye.
- Respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Personal Data Law.
- Provide the necessary information to the authorized authority for the protection of data subjects' rights upon request within 30 days from the date of receiving such a request.
- Publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data.
- Implement legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions in relation to personal data.
- Cease the transfer (distribution, provision, access) of personal data, stop processing, and destroy personal data in accordance with the cases and procedures specified in the Personal Data Law.
- Fulfill other obligations specified in the Personal Data Law.
- Basic Rights and Responsibilities of Data Subjects
4. Basic Rights and Obligations of Personal Data Subjects
4.1. Data subjects have the right to:
- Receive information about the processing of their personal data, except in cases provided by federal laws. The information is provided by the Operator in an accessible form and should not contain personal data related to other data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law.
- Demand that the Operator clarify their personal data, block it, or destroy it in cases where personal data is incomplete, outdated, inaccurate, unlawfully obtained, or no longer needed for the stated purpose of processing. Data subjects may also take legal measures to protect their rights.
- Demand prior consent for the processing of personal data for marketing purposes.
- Withdraw their consent to the processing of personal data.
- Appeal to the authorized authority for the protection of data subjects' rights or the court in cases of unlawful actions or inaction by the Operator regarding the processing of their personal data.
- Exercise other rights provided by the legislation of the Republic of Türkiye.
4.2. Data subjects are obligated to:
- Provide accurate information about themselves to the Operator.
- Inform the Operator of any changes (updates, modifications) in their personal data.
4.3. Individuals who provide inaccurate information about themselves to the Operator or provide information about another data subject without their consent bear responsibility in accordance with the legislation of the Republic of Türkiye.
5. The Operator May Process the Following User's Personal Data
5.1. Last name, first name, patronymic (if applicable).
5.2. Email address.
5.3. Phone numbers.
5.4. Year, month, date, and place of birth.
5.5. The website also collects and processes anonymized data about visitors (including "cookie" files) using internet statistics services such as Yandex.Metrica and Google Analytics, among others.
5.6. The above-listed data are collectively referred to as Personal Data throughout this Policy.
5.7. The Operator does not process special categories of personal data related to racial or ethnic origin, political opinions, religious or philosophical beliefs, or intimate life.
5.8. Processing of personal data permitted for distribution from the list of special categories of personal data specified in Article 10, Part 1 of the Personal Data Law is allowed, provided that the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are observed.
5.9. User's consent for the processing of personal data permitted for distribution is separate from other consents for processing their personal data. In this case, the conditions stipulated, in particular, in Article 10.1 of the Personal Data Law, must be observed. The content requirements of such consent are established by the authorized body for the protection of data subjects' rights.
5.9.1. The User provides their consent for the processing of personal data permitted for distribution directly to the Operator.
5.9.2. The Operator is obliged to publish information about the terms of processing, the presence of prohibitions and conditions for the processing of personal data permitted for distribution, no later than three working days from the moment of receiving the User's consent.
5.9.3. The transfer (distribution, provision, access) of personal data permitted for distribution by the data subject must be terminated at any time upon the data subject's request. This request must include the data subject's last name, first name, patronymic (if applicable), contact information (phone number, email address, or postal address), and a list of personal data the processing of which should be terminated. The personal data specified in this request may only be processed by the Operator to whom it is addressed.
5.9.4. Consent for the processing of personal data permitted for distribution ceases to be effective upon receipt of the request specified in paragraph 5.9.3 of this Policy regarding the processing of personal data by the Operator.
6. Principles of Personal Data Processing
6.1. Personal data processing is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing personal data that is incompatible with the purposes of collecting personal data is not allowed.
6.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.
6.4. Only personal data that corresponds to the purposes of their processing is subject to processing.
6.5. The content and scope of processed personal data correspond to the declared purposes of processing. Redundancy of processed personal data in relation to the declared purposes of processing is not allowed.
6.6. When processing personal data, accuracy, sufficiency, and, if necessary, relevance to the purposes of processing are ensured. The Operator takes necessary measures and/or ensures their adoption for the deletion or clarification of incomplete or inaccurate data.
6.7. Personal data is stored in a form that allows identifying the data subject for no longer than is required for the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract, where the beneficiary or guarantor is the data subject, or by the data subject. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or when the necessity for achieving these purposes is lost, unless otherwise provided by federal law.
7. Purposes of Personal Data Processing
7.1. The purpose of processing the User's personal data includes:
- Informing the User through the sending of emails.
- Entering into, performing, and terminating civil contracts.
- Providing the User with access to services, information, and/or materials contained on the website https://aez.com.tr/.
7.2. The Operator also has the right to send the User notifications regarding new products and services, special offers, and various events. The User can always opt out of receiving informational messages by sending an email to the Operator at the email address firstname.lastname@example.org with the subject line "Opt-out of notifications about new products and services and special offers."
7.3. Anonymized data of Users collected using internet statistics services is used to gather information about Users' actions on the website, improve the website's quality, and its content.
8. Legal Basis for Personal Data Processing
8.1. The legal bases for processing personal data by the Operator are as follows:
- The Operator's statutory (founding) documents.
- Federal laws and other regulatory legal acts in the field of personal data protection.
- Consent of Users to the processing of their personal data, including processing of personal data allowed for dissemination.
8.2. The Operator processes the User's personal data only if they are filled out and/or sent by the User independently through special forms located on the website https://aez.com.tr/ or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.4. The data subject independently makes a decision to provide their personal data and gives their consent freely, of their own accord, and in their own interest.
9. Conditions of Personal Data Processing
9.1. Personal data processing is carried out with the consent of the data subject to process their personal data.
9.2. Personal data processing is necessary for the purposes provided for by an international treaty of the Republic of Türkiye or by law, for the implementation of functions, powers, and duties assigned by the legislation of the Republic of Türkiye to the Operator.
9.3. Personal data processing is necessary for the administration of justice, the execution of a court decision, an act of another authority or official to be enforced in accordance with the legislation of the Republic of Türkiye on enforcement proceedings.
9.4. Personal data processing is necessary for the performance of a contract, where one of the parties is either the beneficiary or the guarantor under the contract, or for the conclusion of a contract at the initiative of the data subject or a contract under which the data subject will be the beneficiary or the guarantor.
9.5. Personal data processing is necessary to protect the rights and legitimate interests of the Operator or third parties, or to achieve socially significant purposes, provided that the rights and freedoms of the data subject are not violated.
9.6. Personal data that are made publicly available by the data subject or at their request are processed (hereinafter referred to as publicly available personal data).
9.7. Personal data are processed when it is required for publication or mandatory disclosure in accordance with federal law.
10. Procedure for the Collection, Storage, Transmission, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation on personal data protection.
10.1. The Operator ensures the integrity of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties except in cases related to the compliance with current legislation or if the data subject has given their consent to the Operator to transfer the data to a third party for the execution of a civil contract.
10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator via email at the Operator's email address email@example.com with the subject "Updating Personal Data."
10.4. The processing period of personal data is determined by the achievement of the purposes for which personal data were collected, unless another period is provided by the contract or the current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email to the Operator's email address firstname.lastname@example.org with the subject "Withdrawal of Consent to Personal Data Processing."
10.6. The restrictions imposed by the data subject on the transfer (except for granting access) or on the processing (except for obtaining access) of personal data allowed for dissemination do not apply in cases of processing personal data in the state's, public, and other public interests as defined by the legislation of the Republic of Türkiye.
10.7. The Operator ensures the confidentiality of personal data during processing.
10.8. The Operator stores personal data in a form that allows for the identification of the data subject for no longer than the purposes of personal data processing require unless the data storage period is established by federal law, a contract, where the data subject is the beneficiary or the guarantor, or an agreement made with the data subject.
10.9. The termination of personal data processing may result from the achievement of the purposes of processing personal data, the expiration of the consent of the data subject, or the data subject's withdrawal of consent, as well as the identification of unlawful personal data processing.
11. List of Actions Performed by the Operator with Received Personal Data
11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
11.2. The Operator conducts automated processing of personal data by obtaining and/or transmitting the received information via information and telecommunication networks or without them.
12. Cross-Border Transfer of Personal Data
12.1. Before commencing the cross-border transfer of personal data, the Operator must ensure that the foreign state to which the transfer of personal data is planned provides reliable protection of the rights of data subjects.
12.2. Cross-border transfer of personal data to foreign states that do not meet the above requirements can only be carried out with the written consent of the data subject for the cross-border transfer of their personal data and/or the execution of a contract in which the data subject is a party.
13. Confidentiality of Personal Data
The Operator and other parties with access to personal data are obligated not to disclose personal data to third parties or distribute personal data without the consent of the data subject, unless otherwise provided by federal law.
14. Final Provisions
14.1. The User can obtain any clarifications on matters related to the processing of their personal data by contacting the Operator via email at email@example.com .
14.2. Any changes to the personal data processing policy by the Operator will be reflected in this document. The policy is valid indefinitely until it is replaced by a new version.
14.3. The current version of the Policy is available online at https://aez.com.tr/policy/