Gizlilik & KVKK

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PDPL Privacy Notice

NOTICE ON THE PROCESSING OF PERSONAL DATA

This Notice on the Processing of Personal Data applies to the data held by the Company, in its capacity as the data controller, for the data of data subjects who submit their requests via the Contact Form available at
https://manifesto.tr/iletisim/.

1. WHY ARE WE PROVIDING THIS NOTICE?

As MANİFESTO HALKLA İLİŞKİLER ANONİM ŞİRKETİ (hereinafter the “Data Controller” or the “Company”), in accordance with Law No. 6698 on the Protection of Personal Data (“KVKK/PDPL”) and the Communiqué on the Procedures and Principles to be Followed in Fulfilment of the Obligation to Inform published in the Official Gazette No. 30356 dated 10.03.2018, we provide this notice, in our capacity as Data Controller, to inform you—within the scope of Article 10 (“Obligation of the Data Controller to Inform”) and Article 11 (“Rights of the Data Subject”) of the PDPL and Articles 4 and 5 of the Communiqué—about the purposes for which your personal data will be processed, to whom and for what purposes your personal data may be transferred, the method and legal grounds for collection, and your other rights listed in Article 11 of the PDPL.

2. WHAT DOES THIS NOTICE COVER?

  • Which personal data of yours are collected
  • For which purposes your personal data are processed
  • With whom and for what purposes your personal data are shared
  • The method and legal grounds for collecting your personal data
  • Destruction (erasure/disposal/anonimization) of your data
  • Your rights under the PDPL

3. WHICH PERSONAL DATA DO WE PROCESS?

Category Data
Identity Information First name, Last name
Contact Information Mobile phone number, E-mail address
Customer Transaction Information Contact request and its subject, request details, explanations, date/time of communication, callback records

* Within the explanations you provide in your communications, we kindly ask you not to share any personal and/or special category personal data for which we must obtain your explicit consent under the PDPL. If you share such data with us within the explanations or documents you attach, it will be deemed that you have given explicit consent for the purposes stated below, and—where necessary—destruction processes will be carried out specifically for such data.

4. WITH WHOM AND FOR WHAT PURPOSES DO WE SHARE YOUR PERSONAL DATA?

Where required by legal obligations or where the conditions in Articles 8/2 and 9 of the PDPL are met, your personal data specified in Section 3 may be shared—aligned with the processing purposes in Section 6—with our contracted suppliers and service providers in order to provide our services via our website and to improve their quality; with the law firm we work with for follow-up of legal affairs; and, in the event of a potential legal dispute, investigation, judicial or administrative audit and similar cases, with judicial and administrative authorities requesting information for the purposes of exercising our right of legal defense and responding to official or other legal requests for information and documents.

Additionally, certain activities carried out by our Company use Microsoft Solutions (Office 365 [Word, Excel, PowerPoint, Teams, Outlook, etc.]). When these applications (“MS Solutions”) are used, personal data contained within the application (e.g., personal data included in e-mail correspondence) will, by the nature of the technical process, be transferred to Microsoft Ireland Operations Limited, whose servers are located in the European Union. Our Company has signed a standard contract with Microsoft Ireland Operations Ltd. pursuant to Article 9/4(c) of the PDPL, and cross-border transfers of personal data made through the use of MS Solutions are carried out in compliance with and safely under the PDPL.

5. WHAT ARE THE METHOD AND LEGAL GROUNDS FOR COLLECTING YOUR PERSONAL DATA?

Your personal data—by category, as detailed in Section 6 below—are collected by automated means through your completion of the Contact Form located at https://manifesto.tr/iletisim/, based on the legal grounds set out in Article 5/2 of the PDPL: “It is necessary for the establishment, exercise or protection of a right” and “Provided that it does not harm the fundamental rights and freedoms of the data subject, it is necessary for the legitimate interests of the data controller.”

6. PURPOSES AND LEGAL GROUNDS FOR PROCESSING YOUR PERSONAL DATA

Personal Data Category Purposes of Processing Legal Grounds
Identity Information Creation of records for requests, classification of contact subjects, conducting reviews per requests, fulfilling requests, managing the callback process, carrying out communication activities, fulfilling legal obligations, conducting our Company’s administrative/commercial processes, carrying out necessary activities within the scope of legitimate interests, ensuring activities are conducted in compliance with legislation, tracking and conducting legal affairs, conducting/monitoring business activities, managing assignment processes. Article 5/2(e) of the PDPL — “It is necessary for the establishment, exercise or protection of a right.”
Article 5/2(f) of the PDPL — “Provided that it does not harm the fundamental rights and freedoms of the data subject, it is necessary for the legitimate interests of the data controller.”
Contact Information Creation of records for requests, classification of contact subjects, conducting reviews, fulfilling requests and managing the callback process, carrying out communication activities, fulfilling legal obligations, conducting our Company’s administrative/commercial processes, fulfilling legitimate interests, ensuring activities are conducted in compliance with legislation, tracking legal affairs, conducting/monitoring business activities, managing assignment processes. Article 5/2(e) of the PDPL
Article 5/2(f) of the PDPL
Customer Transaction Information Creation of records for requests, classification of contact subjects, reviewing and fulfilling requests, managing the callback process, carrying out communication activities, fulfilling legal obligations, conducting administrative/commercial processes, fulfilling legitimate interests, ensuring activities are conducted in compliance with legislation, tracking legal affairs, conducting/monitoring business activities, managing assignment processes. Article 5/2(e) of the PDPL
Article 5/2(f) of the PDPL

7. YOUR RIGHTS UNDER THE PDPL

By applying to our Company, you have the right to:

  • a) Learn whether your personal data are processed,
  • b) Request information if your personal data have been processed,
  • c) Learn the purpose of processing and whether they are used in accordance with their purpose,
  • ç) Know the third parties to whom your personal data are transferred domestically/abroad,
  • d) Request correction if your personal data are incomplete/incorrectly processed,
  • e) Request deletion/destruction within the framework of the conditions stipulated in Article 7 of the PDPL,
  • f) Request that the transactions carried out pursuant to sub-paragraphs (d) and (e) be notified to third parties to whom your personal data have been transferred,
  • g) Object to the occurrence of a result against you by analyzing your data exclusively through automated systems,
  • ğ) Request compensation in case you suffer damage due to unlawful processing of your personal data.

You may submit your requests regarding the exercise of the rights listed above in Turkish and in writing pursuant to Article 13(1) of the PDPL and the Communiqué on the Principles and Procedures of Application to the Data Controller published in the Official Gazette No. 30356 dated 10.03.2018, or via registered electronic mail (KEP), secure electronic signature, mobile signature, or by using the electronic mail address previously notified to our Company and registered in our system. Only information regarding the applicant will be provided; it is not possible to obtain information about other family members or third parties. Our Company reserves the right to verify your identity before responding.

Information that must be included in your application:

  • Your name, surname, and signature if the application is in writing,
  • Your Turkish ID number for Turkish citizens; for foreigners, your nationality, passport number, or identity number if available,
  • Your residential or workplace address for notification,
  • Your e-mail address, telephone and fax numbers for notification, if any,
  • Your request (mandatory) and any additional information/documents, if applicable.

You may deliver your written applications, together with the necessary documents, to the data controller at the address:
Atatürk Mahallesi Ertuğrul Gazi Sokak D2 Blok No:2 R İç Kapı No:13 Ataşehir / İstanbul.

You may send your applications using the e-mail address previously notified to our Company and registered in our system via the contact channels available at https://manifesto.tr.

You may also submit your application by signing it with a secure electronic signature within the scope of Law No. 5070 on Electronic Signatures and sending it via your Registered Electronic Mail (KEP) address. (Note: Messages can be sent to KEP addresses only from KEP domain addresses.)

Depending on the nature of your request, information and documents enabling identity verification must be provided to us completely and accurately. If incomplete/incorrect information is provided, it may not be possible to properly conduct the necessary reviews regarding your request. In such a case, our Company declares that it reserves its legal rights.

8. MEASURES FOR THE PROTECTION OF YOUR PERSONAL DATA

The protection of personal data is an important matter for our Company. We take the necessary technical and administrative measures to protect personal data against unauthorized access or loss, misuse, disclosure, alteration, or destruction. Our Company undertakes to keep your personal data confidential, to take all necessary technical and administrative measures to ensure confidentiality and security, and to exercise due care.

Despite the necessary information security measures taken by our Company, in the event that personal data are damaged or fall into the hands of third parties as a result of attacks on the website and system, our Company will promptly notify you and the Personal Data Protection Board.

9. ACCURACY AND UP-TO-DATE STORAGE OF YOUR PERSONAL DATA

Those who share their personal data with our Company acknowledge and declare that keeping such data accurate and up-to-date is important both in terms of the rights they have over their personal data under the PDPL and other relevant legislation, and that any responsibility arising from providing incorrect information will rest entirely with them.

You may notify changes and/or updates regarding your personal data to the postal address indicated below via physical mail or through the contact channels on the website https://manifesto.tr.

10. DELETION, DESTRUCTION OR ANONYMIZATION OF YOUR PERSONAL DATA

Your personal data processed for the purposes stated in this Notice will be deleted, destroyed or anonymized—ex officio or upon your request—when the purpose requiring processing ceases to exist and the statutory retention periods, if any, expire, in accordance with Article 7/1 of the PDPL and in line with our Company’s Regulation on the Deletion, Destruction or Anonymization of Personal Data and the Personal Data Retention and Destruction Policy prepared pursuant thereto.

11. IDENTITY OF THE DATA CONTROLLER

MANİFESTO HALKLA İLİŞKİLER ANONİM ŞİRKETİ

Mersis No: Mersisi No Olacak

Address: Buraya Adres gelecek

KEP Address: info@manifesto.tr