Office Rental
COMMERCIAL ELECTRONIC MESSAGE PERMISSION
This text indicates that, within the scope of the Law No. 6563 on the Regulation of Electronic Commerce, Office Rental Systems İnşaat Sanayi Ve Ticaret Anonim Şirketi (“Plaza Cubes”) sends me commercial electronic messages and other messages in accordance with the relevant laws, and that my contact information stated below has been received for these purposes and that I have preferred it. Messages will be sent to me through the channel I specified; that my contact information may be shared with third parties for the above-mentioned purposes in accordance with the legal principles regarding the processing of my contact information by taking the necessary measures to protect their confidentiality, and that it will be processed in other ways specified in the law, that I can change my communication preferences at any time or stop the communication by exercising my right to reject this communication permission I have given without giving any reason, and in all other relevant matters. informed/informed by the explanations herein and/or my agreement; Survey applications carried out within the scope of various information, publicity, advertising, promotion, sales and marketing activities regarding the products and services offered by Plaza Cubes, including sending newsletters, are carried out by Plaza Cubes in accordance with the law via SMS/text message, automatic call, telephone call, social media, etc. It includes my consent to send commercial electronic messages and other messages to me through the communication channels I have chosen below, among media and online advertising networks, e-mail/mail and other electronic communication tools-channels.
INFORMATION TEXT ON THE PROCESSING OF PERSONAL DATA FOR CUSTOMERS
This document is based on the Personal Data Protection Law No. 6698 (“Law”) regarding the processing of your personal data. It has been prepared to ensure that you are enlightened within the framework of 10.
Office Rental Systems İnşaat Sanayi ve Ticaret Anonim Şirketi (“Plaza Cubes”) has the title of Data Controller in accordance with the Law in terms of the personal data it obtains from you, our customers.
Purposes of Processing Your Personal Data
Plaza Cubes may use your personal data for the purposes listed below; It can be processed within the personal data processing conditions specified in Articles 5 and 6 of Law No. 6698;
Your identity information, contact information, camera images and other personal data declared by you during your visit to our company facility are processed for the purposes of creating and tracking visitor records and ensuring security for visitors in our company’s buildings and facilities.
Collection Method and Legal Reason of Your Personal Data
Your personal data can be collected by Plaza Cubes physically, verbally, in writing or electronically or via CCTV. Plaza Cubes processes and shares your personal data to fulfill its legal obligations, especially the establishment and execution of the contract, and for the reasons clearly stipulated by law.
Sharing of Your Personal Data
In this context, Plaza Cubes does not share your personal data with third parties
.
Storage of Your Personal Data
Your personal data may be stored for the period required for the purposes of processing. After the purpose of processing ceases, your personal data is deleted, destroyed or anonymized if there is no legal reason to keep it.
Security of Your Personal Data
In order to ensure that your personal data is processed and stored securely in accordance with the law and to prevent unlawful access to your personal data, Plaza Cubes takes all necessary technical and administrative measures to ensure the appropriate level of security.
Your Rights as a “Relevant Person” Regarding Your Personal Data
By applying to our company;
- Learning whether your personal data is being processed,
- If your personal data has been processed, requesting information about it,
- Learning the purpose of processing your personal data and whether your personal data is used in accordance with the purpose of processing,
- Knowing the third parties to whom your personal data is transferred at home or abroad,
- Request correction of your personal data if they are incomplete or incorrectly processed,
- Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in the relevant legislation,
- Requesting that correction, deletion and destruction operations carried out in accordance with the relevant legislation be notified to third parties with whom your personal data has been shared,
- To object to the emergence of a result unfavorable to you by analyzing your processed personal data exclusively through automatic systems,
- If you suffer damage due to unlawful processing of your personal data, request compensation for the damage,
You do not have the rights. In accordance with the procedures and principles of the Communiqué on the Procedures and Principles of Application to the Data Controller dated 10.03.2018 and numbered 30356, together with the documents showing your identity, with a wet signature to the address ………………………………; or you can apply to ………….…….. by using your registered e-mail (KEP) address, secure electronic signature, mobile signature or your e-mail address previously notified to our company and registered in our system. The requests in your application will be terminated free of charge within 30 days at the latest, depending on the nature of the request.
PERSONAL DATA PROTECTION AND PRIVACY POLICY
1. SCOPE
Personal Data Protection and Privacy Policy has been prepared in order to provide the necessary information by explaining the set of rules for the processing of personal data, and it was approved by the Board of Directors of Ofis Kiralama Sistemleri İnşaat Sanayi ve Ticaret Anonim Şirketi (“Plaza Cubes” or “Company”) and came into force on .
The policy covers everyone whose personal data is processed by the company, except Plaza Cubes employees. There is also an “Employee Policy” for our company employees, Office Rental Systems Construction Industry and Trade Joint Stock Company Employees Personal Data Protection and Privacy Policy.
2. DEFINITIONS
| Explicit consent: |
It refers to consent regarding a specific subject, based on informed consent and expressed with free will. |
| Anonymization: |
It refers to making personal data impossible to associate with an identified or identifiable natural person in any way, even by matching it with other data. |
| Contact person |
Represents the real person whose personal data is processed. |
| Law |
Personal Data Protection Law |
| Personal data: |
It refers to all kinds of information regarding an identified or identifiable natural person. |
| Processing of personal data: |
Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, obtaining personal data by fully or partially automatic or non-automatic means provided that it is part of any data recording system. It refers to any operation performed on data such as making it accessible, classifying it or preventing its use. |
| Personal Data Protection Law (‘KVKK’): |
Although it is the subject of this Policy, Law No. 6698 dated 24 March 2016 published in the Official Gazette No. 29677 dated 7 April 2016 |
| Board |
Personal Data Protection Board |
| Institution |
Personal Data Protection Authority |
| Data processor: |
Natural or legal person who processes personal data on behalf of the data controller based on the authority given by him/her |
| Data recording system: |
Recording system where personal data is structured and processed according to certain criteria |
| Data controller: |
The natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system |
| Special personal data: |
Data regarding race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data. . |
| Policy: |
Personal Data Protection and Privacy Policy |
3. CHANGES
Changes to be made to this Policy with the entry into force of additional legislation within the scope of the Law or from time to time will be available on Plaza Cubes’ corporate website
www.plazacubes.com. The current version of this Policy can also be accessed from this corporate site.
4. BASIC PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA
Plaza Cubes processes personal data in accordance with the following principles, in accordance with the 2nd paragraph of Article 4 of the Law and within the scope of the purposes exemplified in the ‘Purposes of Processing Personal Data’ section of this Policy:
- Being in compliance with the law and the rules of honesty
- Accurate and up-to-date when necessary
- Processing for specific, clear and legitimate purposes
- Being related to the purpose for which they are processed, limited and proportionate
- Keeping for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed
5. CLARIFICATION AND INFORMATION OF THE PERSONAL DATA OWNER
In accordance with Article 10 of the Law, Plaza Cubes informs personal data owners during the acquisition of personal data. In this context, during the acquisition of personal data by our Company to personal data owners, the identity of our Company, 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 and legal reason of collecting personal data, and the personal data owner’s possession within the scope of Article 11 of the Law. Clarification regarding rights is provided.
- REASONS FOR COMPLIANCE WITH THE LAW IN THE PROCESSING OF PERSONAL DATA
Explicit consent of the personal data owner is only one of the legal bases that enable the lawful processing of personal data. Apart from explicit consent, personal data may also be processed if one of the other conditions listed below is met. The basis for personal data processing may be only one of the conditions listed below, or more than one of these conditions may be the basis for the same personal data processing activity. If the data processed is personal data of special nature; The following conditions apply.
- Explicit Consent of the Personal Data Owner
- Clearly Provided in Laws
- Failure to Obtain Explicit Consent of the Person Relevant Due to Actual Impossibility
- Directly Involved in the Establishment or Performance of the Contract
- Plaza Cubes Fulfills Its Legal Obligations
- Personal Data Owner’s Publicization of Personal Data
- Data Processing is Necessary for the Establishment or Protection of a Right
- Data Processing is Necessary for the Legitimate Interests of Plaza Cubes
Although the legal basis for processing personal data by our company varies, all kinds of personal data processing activities are carried out in accordance with the general principles specified in Article 4 of Law No. 6698.
7. REASONS FOR COMPLIANCE WITH THE LAW IN THE PROCESSING OF SPECIAL PERSONAL DATA
In Article 6 of the Law, some personal data that poses the risk of causing victimization or discrimination when processed unlawfully are designated as “special nature”. These data; Data regarding race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, appearance and clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data.
By Plaza Cubes in accordance with the law; Special categories of personal data are processed in the following cases, provided that adequate measures are taken to be determined by the KVK Board:
- If there is explicit consent of the personal data owner, or
- If there is no explicit consent of the personal data owner;
- Special categories of personal data, other than the health and sexual life of the personal data owner, in cases stipulated by law,
- Special personal data regarding the personal data owner’s health and sexual life can only be used by persons or authorized persons under the obligation of confidentiality for the purpose of protecting public health, preventive medicine, medical diagnosis, execution of treatment and care services, planning and management of health services and their financing. It is processed by institutions and organizations.
8. PERSONAL DATA PROCESSED BY PLAZA CUBES
Plaza Cubes processes the following personal data it obtains, in accordance with the above-mentioned principles and legal compliance reasons, by informing the relevant persons in accordance with Article 10 of the Law. Owners of personal data belonging to the data categories specified below are specified in Section 9 of the Policy.
| Identity Information |
Information contained in identity cards, driver’s licenses and passport documents pertaining to an identified or identifiable natural person. |
| Contact Information |
E-mail, telephone number, address information related to an identified or identifiable natural person. |
| Customer Information |
Invoices, bank information, etc. obtained, provided that they are limited to the scope of commercial activities related to an identified or identifiable natural person. information. |
| Employee Candidate Information |
Personal information, educational information, work experience, etc. obtained, provided that it is limited to the scope of recruitment to our company, related to an identified or identifiable real person. information. |
| Benefits Information |
Information obtained, provided that it is limited to the side rights and benefits offered by our company, regarding an identified or identifiable natural person. |
| Facility Security Information |
Records, documents, camera images, fingerprint information obtained during logins to our company regarding an identified or identifiable natural person. |
| Legal Transaction Information |
Information obtained regarding an identified or identifiable natural person, provided that it is limited to fulfilling our company’s legal obligations. |
| Information Technologies Knowledge |
IP address, Mac address, Log records, etc. obtained regarding an identified or identifiable natural person. information. |
| Financial Information |
Bank account number, IBAN number, asset information, etc., limited to documents showing the financial result of an identified or identifiable real person. information. |
9. CATEGORIZATION REGARDING THE OWNERS OF PERSONAL DATA PROCESSED BY PLAZA CUBES
Real persons whose personal data is processed by Plaza Cubes; It is limited to customers, potential customers, third parties with whom our customers work, employee candidates, visitors, supplier/business partner employees, company officials and third parties. The persons included in the data subject categories in question are detailed in the table below; Our company employees are evaluated in the Employee Policy.
| Customer |
Real persons who benefit from our company’s products and services. |
| Potential Customer |
Real persons who are or may be interested in our company’s products and services. |
| Third Parties Our Customers Work With |
Real persons who benefit from our company’s products and services and who contact them through our company by any means. |
| Employee Candidate |
Real persons who have applied for a job to our company by any means and sent a resume. |
| Visitor |
Real persons who have entered our company’s premises or visited our website in any way. |
| Supplier/Partner Employees |
Employees and authorities of the institutions with which our company has any business relationship, receives service or cooperates. |
| Company Official |
Members of the Board of Directors and shareholders of our company. |
| With Third Parties |
Real persons (guarantors, family members, relatives, etc.) whose personal data our company processes in accordance with its legal obligations or company procedures. |
10. PRECAUTIONS TAKEN REGARDING THE PROTECTION OF PERSONAL DATA
In accordance with Article 12 of the Law, Plaza Cubes takes the necessary technical and administrative measures to ensure the appropriate level of security to prevent unlawful processing and access of the personal data it processes and to ensure the preservation of the data, and carries out the necessary inspections or has them carried out in this context.
In this context, Plaza Cubes; Personal data is of special nature; The degree to which it requires confidentiality due to its nature; It carries out its activities by taking into account the extent to which it may affect the rights and freedoms of the data owner in the event of a security breach.
Administrative Measures Taken by Plaza Cubes
- Employees were trained to raise awareness about the protection of personal data.
- A personal data security policy has been created; Necessary efforts have been made to comply with this policy.
- It has been ensured that personal data that is not needed for the processing purposes is no longer retained.
- Additional protocols regarding data security and transfer have been signed with data processors.
- A personal data processing inventory has been prepared.
Technical Measures Taken by Plaza Cubes
- Measures such as firewalls and gateways have been taken against unauthorized access over the Internet.
- Physical environments containing personal data are protected against external risks with appropriate methods, and entries and exits to these areas are controlled.
- A commitment has been received that the security measures taken by the cloud storage service provider are sufficient and appropriate.
- Data backup work is being carried out.
11. RIGHTS OF THE “RELATED PERSON” REGARDING PERSONAL DATA AND APPLICATION METHOD
Within the framework of Article 11 of the Law, the relevant person can apply to Plaza Cubes at any time. The person concerned;
- Learning whether your personal data is being processed,
- If your personal data has been processed, requesting information about it,
- Learning the purpose of processing your personal data and whether your personal data is used in accordance with the purpose of processing,
- Knowing the third parties to whom your personal data is transferred at home or abroad,
- Request correction of your personal data if they are incomplete or incorrectly processed,
- Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in the relevant legislation,
- Requesting that correction, deletion and destruction operations carried out in accordance with the relevant legislation be notified to third parties with whom your personal data has been shared,
- To object to the emergence of a result unfavorable to you by analyzing your processed personal data exclusively through automatic systems,
- If you suffer damage due to unlawful processing of your personal data, request compensation for the damage,
They have rights.
In accordance with the procedures and principles in the Communiqué on the Procedures and Principles of Application to the Data Controller dated 10.03.2018 and numbered 30356, together with the documents showing your identity, with a wet signature to the address ………………………………; or ………….…….. You can apply by using your registered e-mail (KEP) address, secure electronic signature, mobile signature or your e-mail address previously notified to our company and registered in our system. Requests in the application will be answered free of charge within 30 days at the latest, depending on the nature of the request.
12. PERSONAL DATA PROCESSED BY PLAZA CUBES AND THE PURPOSES OF PROCESSING
The data owners specified in Sections 8 and 9 of this policy and the personal data related to these data owners are processed for the following purposes;
- Fulfillment of contractual obligations,
- Conducting customer relations,
- Providing the services offered by the company according to the needs,
- Keeping data accurate and up-to-date,
- Planning customer satisfaction processes,
- Planning and execution of marketing activities,
- Management of requests or complaints,
- Creating and tracking visitor records,
- Ensuring security for visitors in our company’s buildings and facilities,
- Fulfillment of our legal obligations,
- Workforce planning and new personnel selection
- Management of human resources processes such as recruitment,
- It is processed for the purposes of evaluating your job application and managing employee recruitment processes.
13. STORAGE OF PERSONAL DATA
Personal data processed by Plaza Cubes can be stored for the period required for the purposes of processing. If there is no legal reason to store it after the purpose of processing is eliminated; personal data is deleted, destroyed or anonymized.
In this context, Plaza Cubes takes the necessary technical and administrative measures within the Company in order to fulfill its relevant obligations; It has developed the necessary operating mechanisms in this regard; It trains, assigns and raises awareness of the relevant business units in order to comply with these obligations.
14. THIRD PARTIES TO WHICH PERSONAL DATA IS TRANSFERRED BY PLAZA CUBES
Our company can transfer the personal data and sensitive personal data of the personal data owner to third parties (Group Companies, business partners, shareholders, affiliates, insurance companies, public institutions and/or organizations and other third parties) by taking the necessary security measures in line with the legal personal data processing purposes. . In this regard, our company acts in accordance with the regulations stipulated in Article 8 of the KVK Law.
Plaza Cubes may transfer the personal data of data owners managed by the Policy to the categories of persons listed below in accordance with Articles 8 and 9 of the Law:
| Supplier/Business Partner |
Plaza Cubes shares limited services with outsourced services that are necessary for the continuity of our company’s business processes. |
| To official institutions and organizations |
Plaza Cubes shares shares limited to fulfilling its legal obligations. |
| To legally authorized private legal persons |
Plaza Cubes shares shares limited to the purpose requested by private law persons within their legal authority. |
15. PLAZA CUBES PERSONAL DATA PROTECTION AND PROCESSING POLICY GOVERNANCE STRUCTURE
The principles set forth by Plaza Cubes with this Policy; It ensures that the relevant principles are implemented within the Company with the policies, procedures and application guides it puts forward for the execution. By establishing a connection between the policies, procedures and application guides regarding the protection of personal data and the basic policies, procedures and application guides carried out by the Company in other areas, compatibility is also ensured between the processes operated by the Company with different policy principles for similar purposes.
Plaza Cubes subjects all procedures established for the implementation of this Policy to each audit internally or by an independent third-party consultant. In this context, when a change is made to this Policy, the approval of Plaza Cubes’ senior management is required for the updated policy to come into force. In addition, Plaza Cubes takes the necessary legal actions to ensure compliance with its obligations within the scope of the Law and secondary legislation and to complete them in case of deficiencies. Plaza Cubes employees have sufficient awareness about the protection of personal data and have completed training on this subject. As a company, within the scope of the importance given to this issue, measures are taken regarding the security of personal data; Data owners are informed about their rights in this regard.
Office Real Estate
COMMERCIAL ELECTRONIC MESSAGE PERMISSION
This text indicates that, within the scope of the Law No. 6563 on the Regulation of Electronic Commerce, Office Rental Systems İnşaat Sanayi Ve Ticaret Anonim Şirketi (“Plaza Cubes”) sends me commercial electronic messages and other messages in accordance with the relevant laws, and that my contact information stated below has been received for these purposes and that I have preferred it. Messages will be sent to me through the channel I specified; that my contact information may be shared with third parties for the above-mentioned purposes in accordance with the legal principles regarding the processing of my contact information by taking the necessary measures to protect their confidentiality, and that it will be processed in other ways specified in the law, that I can change my communication preferences at any time or stop the communication by exercising my right to reject this communication permission I have given without giving any reason, and in all other relevant matters. informed/informed by the explanations herein and/or my agreement; Survey applications carried out within the scope of various information, publicity, advertising, promotion, sales and marketing activities regarding the products and services offered by Plaza Cubes, including sending newsletters, are carried out by Plaza Cubes in accordance with the law via SMS/text message, automatic call, telephone call, social media, etc. It includes my consent to send commercial electronic messages and other messages to me through the communication channels I have chosen below, among media and online advertising networks, e-mail/mail and other electronic communication tools-channels.
INFORMATION TEXT ON THE PROCESSING OF PERSONAL DATA FOR CUSTOMERS
This document is based on the Personal Data Protection Law No. 6698 (“Law”) regarding the processing of your personal data. It has been prepared to ensure that you are enlightened within the framework of 10.
Ofis Gayrimenkul Turizm Pazarlama Ticaret Limited Şirketi (“Plaza Cubes”) has the title of Data Controller in accordance with the Law in terms of the personal data it obtains from you, our customers.
Purposes of Processing Your Personal Data
Plaza Cubes may use your personal data for the purposes listed below; It can be processed within the personal data processing conditions specified in Articles 5 and 6 of Law No. 6698;
Your identity information, contact information, camera images and other personal data declared by you during your visit to our company facility are processed for the purposes of creating and tracking visitor records and ensuring security for visitors in our company’s buildings and facilities.
Collection Method and Legal Reason of Your Personal Data
Your personal data can be collected by Plaza Cubes physically, verbally, in writing or electronically or via CCTV. Plaza Cubes processes and shares your personal data to fulfill its legal obligations, especially the establishment and execution of the contract, and for the reasons clearly stipulated by law.
Sharing of Your Personal Data
In this context, Plaza Cubes does not share your personal data with third parties
.
Storage of Your Personal Data
Your personal data may be stored for the period required for the purposes of processing. After the purpose of processing ceases, your personal data is deleted, destroyed or anonymized if there is no legal reason to keep it.
Security of Your Personal Data
In order to ensure that your personal data is processed and stored securely in accordance with the law and to prevent unlawful access to your personal data, Plaza Cubes takes all necessary technical and administrative measures to ensure the appropriate level of security.
Your Rights as a “Relevant Person” Regarding Your Personal Data
By applying to our company;
- Learning whether your personal data is being processed,
- If your personal data has been processed, requesting information about it,
- Learning the purpose of processing your personal data and whether your personal data is used in accordance with the purpose of processing,
- Knowing the third parties to whom your personal data is transferred at home or abroad,
- Request correction of your personal data if they are incomplete or incorrectly processed,
- Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in the relevant legislation,
- Requesting that correction, deletion and destruction operations carried out in accordance with the relevant legislation be notified to third parties with whom your personal data has been shared,
- To object to the emergence of a result unfavorable to you by analyzing your processed personal data exclusively through automatic systems,
- If you suffer damage due to unlawful processing of your personal data, request compensation for the damage,
You do not have the rights. In accordance with the procedures and principles of the Communiqué on the Procedures and Principles of Application to the Data Controller dated 10.03.2018 and numbered 30356, together with the documents showing your identity, with a wet signature to the address ………………………………; or you can apply to ………….…….. by using your registered e-mail (KEP) address, secure electronic signature, mobile signature or your e-mail address previously notified to our company and registered in our system. The requests in your application will be terminated free of charge within 30 days at the latest, depending on the nature of the request.
PROTECTION OF PERSONAL DATA ANDPRIVACY POLICY
CONTENTS
SCOPE
DEFINITIONS
CHANGES
BASIC PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA
CLARIFICATION AND INFORMATION OF THE PERSONAL DATA OWNER
REASONS FOR LAW COMPLIANCE IN THE PROCESSING OF SPECIAL PERSONAL DATA
PERSONAL DATA PROCESSED BY PLAZA CUBES
CATEGORIZATION REGARDING THE OWNERS OF PERSONAL DATA PROCESSED BY PLAZA CUBES
PRECAUTIONS TAKEN REGARDING THE PROTECTION OF PERSONAL DATA
RIGHTS OF THE “RELATED PERSON” REGARDING PERSONAL DATA AND APPLICATION METHOD.
PERSONAL DATA PROCESSED BY PLAZA CUBES AND THE PURPOSES OF PROCESSING
STORAGE OF PERSONAL DATA.
THIRD PARTIES TO WHICH PERSONAL DATA IS TRANSFERRED BY PLAZA CUBES.
PLAZA CUBES PERSONAL DATA PROTECTION AND PROCESSING POLICY GOVERNANCE STRUCTURE.
1. SCOPE
Personal Data Protection and Privacy Policy has been prepared to provide the necessary information by explaining the set of rules for the processing of personal data, and it was approved by the Board of Directors of Ofis Gayrimenkul Turizm Pazarlama Ticaret Limited Şirketi (“Plaza Cubes” or “Company”) and came into force on .
The policy covers everyone whose personal data is processed by the company, except Plaza Cubes employees. There is also an “Employee Policy” for our company employees, Office Rental Systems Construction Industry and Trade Joint Stock Company Employees Personal Data Protection and Privacy Policy.
2. DEFINITIONS
| Explicit consent: |
It refers to consent regarding a specific subject, based on informed consent and expressed with free will. |
| Anonymization: |
It refers to making personal data impossible to associate with an identified or identifiable natural person in any way, even by matching it with other data. |
| Contact person |
Represents the real person whose personal data is processed. |
| Law |
Personal Data Protection Law |
| Personal data: |
It refers to all kinds of information regarding an identified or identifiable natural person. |
| Processing of personal data: |
Obtaining, recording, storing, preserving, changing, rearranging, disclosing, transferring, taking over, obtaining personal data by fully or partially automatic or non-automatic means provided that it is part of any data recording system. It refers to any operation performed on data such as making it accessible, classifying it or preventing its use. |
| Personal Data Protection Law (‘KVKK’): |
Although it is the subject of this Policy, Law No. 6698 dated 24 March 2016 published in the Official Gazette No. 29677 dated 7 April 2016 |
| Board |
Personal Data Protection Board |
| Institution |
Personal Data Protection Authority |
| Data processor: |
Natural or legal person who processes personal data on behalf of the data controller based on the authority given by him/her |
| Data recording system: |
Recording system where personal data is structured and processed according to certain criteria |
| Data controller: |
The natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data recording system |
| Special personal data: |
Data regarding race, ethnicity, political thought, philosophical belief, religion, sect or other beliefs, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data. . |
| Policy: |
Personal Data Protection and Privacy Policy |
3. CHANGES
Changes to be made to this Policy with the entry into force of additional legislation within the scope of the Law or from time to time will be available on Plaza Cubes’ corporate website www.plazacubes.com. The current version of this Policy can also be accessed from this corporate site.
4. BASIC PRINCIPLES REGARDING THE PROCESSING OF PERSONAL DATA
Plaza Cubes processes personal data in accordance with the following principles, in accordance with the 2nd paragraph of Article 4 of the Law and within the scope of the purposes exemplified in the ‘Purposes of Processing Personal Data’ section of this Policy:
- Being in compliance with the law and the rules of honesty
- Accurate and up-to-date when necessary
- Processing for specific, clear and legitimate purposes
- Being related to the purpose for which they are processed, limited and proportionate
- Keeping for the period stipulated in the relevant legislation or necessary for the purpose for which they are processed
5. CLARIFICATION AND INFORMATION OF THE PERSONAL DATA OWNER
In accordance with Article 10 of the Law, Plaza Cubes informs personal data owners during the acquisition of personal data. In this context, during the acquisition of personal data by our Company to personal data owners, the identity of our Company, 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 and legal reason of collecting personal data, and the personal data owner’s possession within the scope of Article 11 of the Law. Clarification regarding rights is provided.
5. REASONS FOR COMPLIANCE WITH THE LAW IN THE PROCESSING OF PERSONAL DATA
Explicit consent of the personal data owner is only one of the legal bases that enable the lawful processing of personal data. Apart from explicit consent, personal data may also be processed if one of the other conditions listed below is met. The basis for personal data processing may be only one of the conditions listed below, or more than one of these conditions may be the basis for the same personal data processing activity. If the data processed is personal data of special nature; The following conditions apply.
- Explicit Consent of the Personal Data Owner
- Clearly Provided in Laws
- Failure to Obtain Explicit Consent of the Person Relevant Due to Actual Impossibility
- Directly Involved in the Establishment or Performance of the Contract
- Plaza Cubes Fulfills Its Legal Obligations
- Personal Data Owner’s Publicization of Personal Data
- Data Processing is Necessary for the Establishment or Protection of a Right
- Data Processing is Necessary for the Legitimate Interests of Plaza Cubes
Although the legal basis for processing personal data by our company varies, all kinds of personal data processing activities are carried out in accordance with the general principles specified in Article 4 of Law No. 6698.
7. REASONS FOR COMPLIANCE WITH THE LAW IN THE PROCESSING OF SPECIAL PERSONAL DATA
In Article 6 of the Law, some personal data that poses the risk of causing victimization or discrimination when processed unlawfully are designated as “special nature”. These data; Data regarding race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, appearance and clothing, association, foundation or union membership, health, sexual life, criminal conviction and security measures, as well as biometric and genetic data.
By Plaza Cubes in accordance with the law; Special categories of personal data are processed in the following cases, provided that adequate measures are taken to be determined by the KVK Board:
- If there is explicit consent of the personal data owner, or
- If there is no explicit consent of the personal data owner;
- Special categories of personal data, other than the health and sexual life of the personal data owner, in cases stipulated by law,
- Special personal data regarding the personal data owner’s health and sexual life can only be used by persons or authorized persons under the obligation of confidentiality for the purpose of protecting public health, preventive medicine, medical diagnosis, execution of treatment and care services, planning and management of health services and their financing. It is processed by institutions and organizations.
8. PERSONAL DATA PROCESSED BY PLAZA CUBES
Plaza Cubes processes the following personal data it obtains, in accordance with the above-mentioned principles and legal compliance reasons, by informing the relevant persons in accordance with Article 10 of the Law. Owners of personal data belonging to the data categories specified below are specified in Section 9 of the Policy.
| Identity Information |
Information contained in identity cards, driver’s licenses and passport documents pertaining to an identified or identifiable natural person. |
| Contact Information |
E-mail, telephone number, address information related to an identified or identifiable natural person. |
| Customer Information |
Invoices, bank information, etc. obtained, provided that they are limited to the scope of commercial activities related to an identified or identifiable natural person. information. |
| Employee Candidate Information |
Personal information, educational information, work experience, etc. obtained, provided that it is limited to the scope of recruitment to our company, related to an identified or identifiable real person. information. |
| Benefits Information |
Information obtained, provided that it is limited to the side rights and benefits offered by our company, regarding an identified or identifiable natural person. |
| Facility Security Information |
Records, documents, camera images, fingerprint information obtained during logins to our company regarding an identified or identifiable natural person. |
| Legal Transaction Information |
Information obtained regarding an identified or identifiable natural person, provided that it is limited to fulfilling our company’s legal obligations. |
| Information Technologies Knowledge |
IP address, Mac address, Log records, etc. obtained regarding an identified or identifiable natural person. information. |
| Financial Information |
Bank account number, IBAN number, asset information, etc., limited to documents showing the financial result of an identified or identifiable real person. information. |
9. CATEGORIZATION REGARDING THE OWNERS OF PERSONAL DATA PROCESSED BY PLAZA CUBES
Real persons whose personal data is processed by Plaza Cubes; It is limited to customers, potential customers, third parties with whom our customers work, employee candidates, visitors, supplier/business partner employees, company officials and third parties. The persons included in the data subject categories in question are detailed in the table below; Our company employees are evaluated in the Employee Policy.
| Customer |
Real persons who benefit from our company’s products and services. |
| Potential Customer |
Real persons who are or may be interested in our company’s products and services. |
| Third Parties Our Customers Work With |
Real persons who benefit from our company’s products and services and who contact them through our company by any means. |
| Employee Candidate |
Real persons who have applied for a job to our company by any means and sent a resume. |
| Visitor |
Real persons who have entered our company’s premises or visited our website in any way. |
| Supplier/Partner Employees |
Employees and authorities of the institutions with which our company has any business relationship, receives service or cooperates. |
| Company Official |
Members of the Board of Directors and shareholders of our company. |
| With Third Parties |
Real persons (guarantors, family members, relatives, etc.) whose personal data our company processes in accordance with its legal obligations or company procedures. |
10. PRECAUTIONS TAKEN REGARDING THE PROTECTION OF PERSONAL DATA
In accordance with Article 12 of the Law, Plaza Cubes takes the necessary technical and administrative measures to ensure the appropriate level of security to prevent unlawful processing and access of the personal data it processes and to ensure the preservation of the data, and carries out the necessary inspections or has them carried out in this context.
In this context, Plaza Cubes; Personal data is of special nature; The degree to which it requires confidentiality due to its nature; It carries out its activities by taking into account the extent to which it may affect the rights and freedoms of the data owner in the event of a security breach.
Administrative Measures Taken by Plaza Cubes
- Employees were trained to raise awareness about the protection of personal data.
- A personal data security policy has been created; Necessary efforts have been made to comply with this policy.
- It has been ensured that personal data that is not needed for the processing purposes is no longer retained.
- Additional protocols regarding data security and transfer have been signed with data processors.
- A personal data processing inventory has been prepared.
Technical Measures Taken by Plaza Cubes
- Measures such as firewalls and gateways have been taken against unauthorized access over the Internet.
- Physical environments containing personal data are protected against external risks with appropriate methods, and entries and exits to these areas are controlled.
- A commitment has been received that the security measures taken by the cloud storage service provider are sufficient and appropriate.
- Data backup work is being carried out.
11. RIGHTS OF THE “RELATED PERSON” REGARDING PERSONAL DATA AND APPLICATION METHOD
Within the framework of Article 11 of the Law, the relevant person can apply to Plaza Cubes at any time. The person concerned;
- Learning whether your personal data is being processed,
- If your personal data has been processed, requesting information about it,
- Learning the purpose of processing your personal data and whether your personal data is used in accordance with the purpose of processing,
- Knowing the third parties to whom your personal data is transferred at home or abroad,
- Request correction of your personal data if they are incomplete or incorrectly processed,
- Requesting the deletion or destruction of your personal data within the framework of the conditions stipulated in the relevant legislation,
- Requesting that correction, deletion and destruction operations carried out in accordance with the relevant legislation be notified to third parties with whom your personal data has been shared,
- To object to the emergence of a result unfavorable to you by analyzing your processed personal data exclusively through automatic systems,
- If you suffer damage due to unlawful processing of your personal data, request compensation for the damage,
They have rights.
In accordance with the procedures and principles in the Communiqué on the Procedures and Principles of Application to the Data Controller dated 10.03.2018 and numbered 30356, together with the documents showing your identity, with a wet signature to the address ………………………………; or ………….…….. You can apply by using your registered e-mail (KEP) address, secure electronic signature, mobile signature or your e-mail address previously notified to our company and registered in our system. Requests in the application will be answered free of charge within 30 days at the latest, depending on the nature of the request.
12. PERSONAL DATA PROCESSED BY PLAZA CUBES AND THE PURPOSES OF PROCESSING
The data owners specified in Sections 8 and 9 of this policy and the personal data related to these data owners are processed for the following purposes;
- Fulfillment of contractual obligations,
- Conducting customer relations,
- Providing the services offered by the company according to the needs,
- Keeping data accurate and up-to-date,
- Planning customer satisfaction processes,
- Planning and execution of marketing activities,
- Management of requests or complaints,
- Creating and tracking visitor records,
- Ensuring security for visitors in our company’s buildings and facilities,
- Fulfillment of our legal obligations,
- Workforce planning and new personnel selection
- Management of human resources processes such as recruitment,
- It is processed for the purposes of evaluating your job application and managing employee recruitment processes.
13. STORAGE OF PERSONAL DATA
Personal data processed by Plaza Cubes can be stored for the period required for the purposes of processing. If there is no legal reason to store it after the purpose of processing is eliminated; personal data is deleted, destroyed or anonymized.
In this context, Plaza Cubes takes the necessary technical and administrative measures within the Company in order to fulfill its relevant obligations; It has developed the necessary operating mechanisms in this regard; It trains, assigns and raises awareness of the relevant business units in order to comply with these obligations.
14. THIRD PARTIES TO WHICH PERSONAL DATA IS TRANSFERRED BY PLAZA CUBES
Our company can transfer the personal data and sensitive personal data of the personal data owner to third parties (Group Companies, business partners, shareholders, affiliates, insurance companies, public institutions and/or organizations and other third parties) by taking the necessary security measures in line with the legal personal data processing purposes. . In this regard, our company acts in accordance with the regulations stipulated in Article 8 of the KVK Law.
Plaza Cubes may transfer the personal data of data owners managed by the Policy to the categories of persons listed below in accordance with Articles 8 and 9 of the Law:
| Supplier/Business Partner |
Plaza Cubes shares limited services with outsourced services that are necessary for the continuity of our company’s business processes. |
| To official institutions and organizations |
Plaza Cubes shares shares limited to fulfilling its legal obligation. |
| To legally authorized private legal persons |
Plaza Cubes shares shares limited to the purpose requested by private law persons within their legal authority. |
15. PLAZA CUBES PERSONAL DATA PROTECTION AND PROCESSING POLICY GOVERNANCE STRUCTURE
The principles set forth by Plaza Cubes with this Policy; It ensures that the relevant principles are implemented within the Company with the policies, procedures and application guides it puts forward for the execution. By establishing a connection between the policies, procedures and application guides regarding the protection of personal data and the basic policies, procedures and application guides carried out by the Company in other areas, compatibility is also ensured between the processes operated by the Company with different policy principles for similar purposes.
Plaza Cubes subjects all procedures established for the implementation of this Policy to each audit internally or by an independent third-party consultant. In this context, when a change is made to this Policy, the approval of Plaza Cubes’ senior management is required for the updated policy to come into force. In addition, Plaza Cubes takes the necessary legal actions to ensure compliance with its obligations within the scope of the Law and secondary legislation and to complete them in case of deficiencies. Plaza Cubes employees have sufficient awareness about the protection of personal data and have completed training on this subject. As a company, within the scope of the importance given to this issue, measures are taken regarding the security of personal data; Data owners are informed about their rights in this regard.
