DISCLOSURE TEXT ON PROCESSING OF PERSONAL DATA

As the Data Controller, Alarko Carrier Sanayi ve Ticaret A.Ş (”Alarko Carrier”) attaches great importance to act in accordance with the Law No 6698 on Protection of Personal Data (“GDPR”) in processing and protection of the personal data. In this sense, our Company, as the “Data Controller” processes the data of with whom we have relations, including but not limited to our prospective customers, employees, their unions, representatives, our interns, trainees, candidate employees, shareholders, authorized representatives, suppliers, consultants, business partners and their employees, shareholders, authorized representatives, visitors and other persons involved in any transaction with our company.

What is Personal Data

Personal data is not limited to the names, surnames, birth dates and birth places revealing your identity information; SSI number, passport number, resume, CV, image and sound recordings, finger prints, genetic information, IP address, e-mail address, hobbies, preferences, people interacting with you, group memberships, family information, including but not limited to all data that makes the person directly or indirectly identifiable shall also be considered as personal data.

Your personal data is processed or disclosed by our Company in accordance with the articles 5 and 6 of the Law No 6698 on Protection of Personal Data, where such processing or disclosure is

·         Stipulated in the Laws explicitly,

·         Required or directly related to establishment or performance of a contract,

·         Required for performance of a legal obligation of our company,

·         If the personal data is publicized already by the data subject

·         Required to conduct personal data processing operations for legitimate benefits of our company without any prejudice to the fundamental rights and freedoms

·         Required for protection of the life or bodily integrity of the data subject or another person, and provided that the data subject is unable to give his/ her consent due to physical impossibility of legal invalidity,

·         Stipulated in the legislations that personal data other than those related to the health and sexual life of the data subject may be processed,

·         Special purpose personal data of the data subject related to his/ her health and sexual life is processed by the persons under the confidentiality obligation or competent authorities and organizations for protection of public health, execution of preventive medicine, medical diagnosis and care services. Where the above requirements do not exist, our company requests express consent of the data subjects to be involved in processing of personal data.

PURPOSES FOR OUR PROCESSING OF THE PERSONAL DATA?

Our Company carries out data processing activities in accordance with the above stated terms and conditions:

a)      For the purposes of carrying out commercial activities and management of business processes in the company in line with such commercial activities

b)      For conduct of compulsory works required for the persons utilizing our products and services,

-          make the necessary improvements in order to ensure customer satisfaction by collecting customer requests and complaints;

-          send necessary notifications to protect customer rights,

-          Plan and conduct marketing activities,

-          Call our company's call center, use the website or mobile applications (Alarko Carrier-Gerçek Konfor and Alarko Carrier-Kombi Kontrol),

-          Carry out after sales support services,

c)      For carrying out of the works by our Human resources Department,

-          Be able to receive and evaluate job applications,

-          Fulfillment of the company's obligations in accordance with the rights of the employees arising from the law and the service contract,

-          Carrying out the obligations on Occupational Health and Safety,

d)      For application of commercial strategies of our company

-          Financial operations, communication and market research activities, procurement operations, production and quality processes and operations carried out by our company,

-          Management of internal systems and applications,

e)      For protecting health, legal and commercial security of persons who come into contact with our company for commercial, business, service contract and / or any other reason.

-          Provision of visitor records,

-          Ensuring the security of the company in its physical environment,

-          Fulfill the obligations regarding Occupational Health and Safety,

-          Be able to follow the legal affairs of which our company is a party, and to make necessary notifications to official institutions as required by law,

and conduct data processing activities for the similar other purposes.

OUR METHODS TO COLLECT AND KEEP PERSONAL DATA

Your personal data can be collected by means of automated or manual methods verbally, in written or electronically via call centers, web sites, social media, mobile applications (Alarko Carrier-Gerçek Konfor and Alarko Carrier-Kombi Kontrol) and similar other methods. Your personal data will be stored in electronic and / or physical environments. All necessary administrative and technical measures are taken in order to ensure that your personal data provided and stored by our company are kept in proper and safe manner and is not exposed to unauthorized access, damage or losses.

The User may request the deletion or destruction of his/her personal data. To delete his/her account, the user can click on the 'Delete/Close My Account' button provided in the profile settings in Alarko Carrier Applications (Alarko Carrier-Gerçek Konfor and Alarko Carrier-Kombi Kontrol). Upon clicking this button and confirming the deletion of his/her account, the user's personal data will be removed from Alarko Carrier data streams through deletion, destruction or anonymization methods.

Your personal data will be processed and processed for purposes not covered by the purposes and scope of the report and will be retained only for the legally allowed period and for the period required for the purpose of the processing if no legal storage period given. When this period expires, your personal data will be removed from our Company's data streams by deletion, destruction or anonymization.

TRANSFER OF PERSONAL DATA

Pursuant to the articles 8 and 9 of the GDPR Law,  our Company transfers the personal data to the Business partners for establishment of business partnerships, to our Suppliers for the products and services provided by our company from outside, to our Subsidiaries to secure the compulsory strategies for carrying out the commercial operations of our Company, to Authorized Public/ private Entities and organizations and natural persons only for the purposes requested and within the jurisdiction of the entity requesting such where such transfer is compulsory in the applicable laws, tax consultants and other advisors, to the persons required for legal processes, third party consultants of our Company including the auditors, and including but not limited to the business partners, third parties, competent persons and organizations providing services to our company in the country and abroad.

Your Rights as per Law on GDPR

Everyone, in connection with herself/himself, has 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; request deletion or destruction of personal data within the framework of the conditions set forth in the legislations; request notification of the operations made 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 by applying to the data controller.

Provisions of this Law shall not be applied in processing of personal data for the purposes of official statistics and, through anonymization, research, planning, statistics and similar,  processing of personal data for the purposes of art, history, and literature or science, or within the scope of freedom of expression, provided that national defense, national security, public safety, public order, economic safety, privacy of personal life or personal rights are not violated, in processing of personal data within the scope of preventive, protective and intelligence-related activities by public institutions and organizations who are assigned and authorized for providing national defense, national security, public safety, public order or economic safety, and processing of personal data by judicial authorities and execution agencies with regard to investigation, prosecution, adjudication or execution procedures since such circumstances are exempted pursuant to the GDPR Law.

Data subjects may not use the above stated rights excluding the right to request indemnification of the losses and damages, where processing of personal data is necessary for prevention of crime or investigation of a crime; processing of personal data revealed to the public by the data subject herself/himself, processing of personal data is necessary, deriving from the performance of supervision or regulatory duties, or disciplinary investigation or prosecution by assigned and authorized public institutions and organizations and professional organizations with public institution status; processing of personal data is necessary for the protection of economic and financial interests of the state related to budget, tax, and financial matters.

Pursuant to the clause 1 of the article 13 of the GDPR Law, you may notify our company of your request to use any of the rights stated above in written or via other methods defined by the Personal Data Protection Board.

Utilization of Your Rights

Data subjects may use their above stated rights notifying our company directly or by the other persons empowered via special power of attorney on personal data in written or via registered electronic mail (KEP) using secure electronic signature, mobile signature or from a registered electronic e-mail address notified to and registered with our company.

Postal address: Alarko Carrier Sanayi ve Ticaret A.Ş., GOSB – Şahabettin Bilgisu Cad., 41480, Gebze, Kocaeli

Electronic mail address: kvkk@alarko-carrier.com.tr

KEP address: alarkocarrier.alarko@hs01.kep.tr

Any request or application sent by the data subjects to our company by the data subjects shall be responded within no later than 30 days. As per the applicable legislations, our Company is entitled to request additional information or payment of the cost, where any cost is required, from the applicant.

The data subject is entitled to file complaint against the response given by our company to the GDPR Board within legally allowable period pursuant to the GDPR Law.



Alarko Carrier GDPR Policy

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