The personal data of our customers is of great importance for our company.
Our company keeps all kinds of personal data shared by our customers in a way to take care of customer privacy and to take all necessary technical and administrative measures to ensure the appropriate level of security for your personal data.
This Disclosure on the Protection of Personal Data explains that; our personal data protection and processing policy and how we collect, transfer, use and protect your personal data during the services performed by ÖZDEMİR YÖNETİM ve BİLİŞİM DANIŞMANLIĞI A.Ş. (Turkey Relocation Management Services) (TRMS).
Personal Data Collected by TRMS
We collect various information from our customers within the framework of the services we provide. This information is collected under all circumstances in accordance with the data processing principles and conditions contained in the Law on the Protection of Personal Data No.6698 (“LPPD”).
The information we collect from you for the purposes described in Section 2 below may include:
- Name – Surname
- ID/Passport Number
- ID/Passport validity dates
- ID/Passport issuance place
- Place/Date of Birth
- Phone number
- Financial Data
- Private Health Insurance Policy
- Biometric Data
- Height/weight information
- Eye/hair colour
- Name and surname of your mother and father
- Your voice recording, based on your consent if you contact TRMS
- Emails your sent to TRMS
- The closed circuit camera system image of yours recording during your visit to TRMS,
- If you use the parking lot / valet service during your visit to TRMS,vehicle license plate information
- Other data you share when you contact us via e-mail, call center or other channels
- All of the above data requested of your spouse and children.
Purposes of Processing Your Personal Data
The personal data we collect within the scope of the services we provide are processed for various purposes, including:
- Providing you with information about your appointment in case of making an appointment in relation to the services offered,
- Planning and managing the internal operation of TRMS,
- Analyzing to improve our services,
- Verification of your identity,
- Verification of your relationship with contracted institutions;
- Responding to the requests of Republic of Turkey Ministry of Family, Labour and Social Services, Republic of Turkey Ministry of Interior Directorate General of Migration Management and other public institutions and organizations in accordance with the applicable legislation,
- Responding to your questions or complaints regarding our services;
- Analyzing informatıon about your social and family status in order to improve the services we offer,
- To adapt with TRMS’s internal policies and principles,
- Contacting you to inform you about our services,
- However, your personal data will not be used for commercial purposes in any way, except for the activities listed above and the situations required by the relevant legislation.
This Policy has been created in accordance with the rules and procedures stipulated in the provisions of the LPPD and other relevant legislation for the protection of personal data. In this sense, as the Data Controller is obliged to prevent and protect personal data from being processed illegally and unlawfully, in accordance with the LPPD, the data controller must take all necessary technical and administrative measures.
The company also has different policies regarding the protection of personal data and the provision of information security in relation to certain business activities and functions. This Policy does not override the data protection terms in these different policies of the Company, unless it includes additional terms or demands a higher standard for the protection of personal data.
The relevant legislative provisions regarding the processing and protection of personal data will primarily be applied; In case of conflict between the relevant legislation and the provisions of this Policy, the current legislation provisions will primarily prevail.
Principles to Be Followed When Processing Personal Data
TRMS acts in accordance with the general principles explained below:
- Processing of personal data in accordance with the law and the rule of honesty and transparently,
- Collection of personal data only for specific, explicit and legitimate purposes,
- Personal data being linked, limited and measured for the purposes for which they are processed,
- Personal data to be accurate and up-to-date when necessary, to be deleted or corrected without delay,
- Personal data to be kept as long as the period required or the period anticipated,
- Processing of personal data to ensure appropriate security.
Persons and Institutions to Which Your Personal Data can be Transferred
By ensuring that all kinds of technical and administrative measures are taken to ensure the appropriate level of security in accordance with the LPPD and the relevant legislation, you can collect your personal data for the purposes stated in Section 2 above;
- International Labor Law No. 6735, Implementation Regulation of the Law on Work Permits for Foreigners, Foreigners and International Protection Law No. 6458, Turkish Citizenship Law No. 5901 and institutions or organizations permitted by other relevant legislative provisions;
- Private insurance companies
- Our direct / indirect – domestic / foreign shareholders, subsidiaries and / or affiliates; our group companies,
- Auditors; consultants, business partners;
- Domestic / foreign organizations that we contractually serve, cooperate with to carry out our activities,
- With domestic or foreign systems and / or the group of companies that TRMS is affiliated with,
- With your employer,
- Our suppliers, support service providers, archive service providers and business partners whose services we benefit from or cooperate with.
- Social Security Institution,
- General Directorate of Security and other law enforcement agencies,
- General Directorate of Population,
- Judicial authorities,
- Your authorized legal representatives,
- Third parties we receive consultancy, including lawyers, tax consultants and auditors we work with,
- And we can pass it on to other third parties.
- Tax offices
- The Ministry of Foreign Affairs
- The Turkish Representatives abroad
- Information and communication technologies authority
- Private banks, hospitals, notary public offices, translation offices, international shipping companies, custıms, rent-a-car companies, real estate agencies
- Domestic Transfer: The Company does not transfer the personal data of the relevant persons to other persons without the explicit consent of the person concerned, without prejudice to the situations where the transfer of personal data to administrative and judicial institutions and organizations as required by the LPPD or the relevant legislation is reserved. However, in cases where there are matters numbered in Article 5 and/or Article 6 of the LPPD, your personal data will be transferred to the relevant institutions and organizations in the legal framework without seeking explicit consent due to the existence of a reason for compliance with the law
- Overseas Transfer: The company may transfer personal data abroad by taking the necessary security measures in accordance with the conditions stipulated in the LPPD and the relevant legislation and by obtaining the explicit consent of the relevant person. In cases where the explicit consent of the relevant person is not sought, the condition that the country to which the personal data will be transferred is in the status of “safe country” and provides sufficient protection. In cases where the country whose data is transferred by the Board is not considered as a safe country, a data transfer protocol is signed with the permission of the Board, which will commit to adequate protection.
Method and Legal Reason for Collecting Personal Data
Your personal data are collected in all kinds of verbal, written, visual or electronic media, for the purposes stated above and for the legal framework of all kinds of work included in the field of activity of TRMS and in this context, in order for TRMS to fulfill its contractual and legal obligations fully and properly. and processed.
Legal reason for collecting your data from these persons;
- Law No. 6698 on Protection of Personal Data,
- Regulation on Processing of Personal Health Data and Protection of Privacy,
- T.C. Ministry of Internal Affairs regulations and other legislative provisions.
Storage and Destruction of Personal Data
- TRMS determines the retention periods of personal data by taking into account the legislation in force and the purposes of processing the data subject to the process. In this context, legal obligations related to Personal Data Processing activity and limitation periods are definitely taken into consideration. In accordance with Article 7 of the LPPD and other relevant legislation provisions, in case the reasons for the processing of the processed personal data are eliminated, the personal data are deleted, destroyed or anonymized upon the Company’s decision, periodic control and / or the request of the person concerned.
- Personal data transferred to TRMS by any means incorrectly or in cases where it is understood that the will of the relevant person is not directed to give explicit consent, is immediately destroyed by our Company by methods in accordance with the Law.
- Our company will not store personal data for longer than necessary in a way that allows the identification of the data owner, in connection with the reason for the data collection.
- Our company may keep personal data for a longer period of time only for public benefit, scientific or historical research or statistical purposes by taking appropriate technical and organizational measures in order to protect the rights and freedoms of the data owner and to ensure data security.
- The criteria used in determining this period, including the retention period for each category of personal data and the legal obligations that the Company has to store the data, are specified in our Company’s Personal Data Storage and Destruction Policy and will be applied in all cases.
Measures to Ensure Data Security
Şirketimiz, kişisel verilerin güvenliğini sağlamaya yönelik veri ihlallerini engelleyecek teknik ve idari tedbirleri almaktadır. Bu kapsamda Şirketimiz;
- Conducts a risk audit to identify existing risks and threats.
- Awareness studies for employees are carried out periodically.
- There are personal data security policies and procedures.
- Ensuring cyber security,
- Monitoring of personal data security,
- Ensuring the security of environments containing personal data,
- Storing personal data in secure areas and cloud computing systems,
- It processes personal data under the conditions stipulated by law, by taking the necessary software and hardware measures for the procurement, development and maintenance of information technology systems.
Data Protection Officer
The Data Protection Officer has specific responsibilities in terms of procedures. It is the first channel to be contacted by the Employees/Personnel when looking for any explanation about data protection compliance, but it is the person to be directly addressed to your personal data in terms of the responsibility it takes regarding your personal data.
In this context, the Data Protection Officer, whom the Company’s Board of Directors considers as authorized and experienced, has been appointed to take responsibility for the daily compliance of the Company with this Policy, and in particular, in terms of data processing activities carried out in their area of responsibility, the Company ‘ has a direct responsibility to ensure compliance with LPPD.
Your Rights Regarding Your Personal Data
To the extent that your personal data is processed by TRMS as a data controller, in accordance with Article 11 of the LPPD, by filling in the “LPPD Access/Information Request Form” below, delivering it by hand to TRMS, sending it via a notary public or sending it to firstname.lastname@example.org, Your personal data by transmitting with electronic signature;
- Learning whether any of your personal data has been processed;
- Requesting information regarding the processing activities of your personal data;
- Learning the purposes of processing your personal data;
- To learn about personal data in case of being transferred to third parties in the country or abroad;
- To request correction of personal data in case of incomplete or incorrect processing;
- To request the deletion or destruction of personal data in the event that the reasons for the processing of personal data are eliminated or the Group does not have a legal basis or legitimate interest to process such data;
- If you suffer damage due to unlawful processing of your personal data, you have the right to demand compensation for this damage.
Depending on the qualification of the request, TRMS will finalize the request free of charge as soon as possible and within thirty days at the latest.
However, if the transaction requires an additional cost, TRMS will charge the fee in the tariff determined by the Personal Data Protection Board.
Data Security and Application Right
Your personal data is meticulously protected within the scope of technical and administrative possibilities and is provided at a level suitable for possible risks, taking into account the necessary security measures and technological possibilities.
By filling out the “Application Form Pursuant to the Law on the Protection of Personal Data” on the website “www.turkeyrelocation.com” for your requests under the Law; Yeniköy Mahallesi Sait Halim Paşa Caddesi Doğramacı Emin Sokak No:7 34464 Sarıyer, İstanbul, can deliver it to Istanbul address in person, send it via a notary or secure electronic or mobile signature to the address email@example.com, registered e-mail address or e-mail registered in our system. You can forward it via your address.
ÖZDEMİR YÖNETİM ve BİLİŞİM DANIŞMANLIĞI A.Ş.