Corporate General Clarification Text on the Protection of Personal Data

SENTE MAKİNA İNŞ. SAN. VE TİC. LTD. ŞTİ. As “SENTE MAKİNA”; we have prepared this clarification text to inform our Visitors, Online Visitors, Customers, Potential Customers, Supplier Employees, and Supplier Authorities about the processing, storage, and transfer of your personal data within the scope of the Personal Data Protection Law No. 6698 (“KVKK”) and related legislation and legal regulations.

What Personal Data Categories We Process and For What Purposes?

The personal information of our business partners is processed by SENTE MAKINA in accordance with Article 4.2 of the KVKK;

(i) Being in accordance with the law and the rules of honesty,

(ii) Being accurate and up-to-date when necessary,

(iii) Being processed for specific, explicit, and legitimate purposes,

(iv) Being relevant, limited, and proportionate to the purposes for which they are processed,

(v) To be stored for the period stipulated in the relevant legislation or as required for the purpose for which they are processed, in accordance with the principles, within the scope of our ongoing business relationships with our business partners (it is possible for one person to fall into multiple categories), may be processed for the purposes specified below.

Our Visitors

Physical location security information (e.g., camera recordings)

will be processed for the purposes of ensuring physical location security.

Our Online Visitors

The transaction security information (e.g., your IP address information) of our online visitors using our website and, if provided to us, identity information, contact information (e.g., your email address);

• conducting activities in accordance with the legislation,
• conducting information security processes,
• tracking requests/complaints,
• conducting communication activities,
• providing information to authorized persons, institutions, and organizations,
• will be processed to enable your access to our website via the internet.

Our Customers

identity information identity information, contact information, customer transaction information (e.g., order information), physical location security information, financial information (e.g., balance information), legal transaction information, marketing information (e.g., shopping history information);

• conducting activities in accordance with the legislation,
• conducting finance and accounting affairs,
• conducting/auditing business activities,
• conducting logistics activities,
• conducting post-sales support services for goods/services,
• conducting sales processes for goods/services,
• conducting marketing analysis studies,
• conducting contract processes,
• providing information to authorized persons, institutions, and organizations,
• ensuring physical location security,
• resolving legal disputes,
• conducting storage and archiving activities,
• conducting risk management processes,
• conducting advertising/campaign/promotion processes,
• conducting processes related to loyalty to the company/products/services,
• will be processed for the purpose of conducting communication activities.

Our Potential Customers

The identity information, contact information, customer transaction information, physical location security information, marketing information of our real or legal entity customers’ employees and/or customers;

• managing the sales processes of goods/services,
• conducting contract processes,
• ensuring physical location security,
• conducting advertising/campaign/promotion processes,
• will be processed for the purpose of conducting communication activities.

Our Supplier Employee

The identity information, contact information, physical location security information, professional experience information (e.g., in-service training information) of our supplier employee;

• conducting communication activities,
• conducting/auditing business activities,
• ensuring physical location security,
• conducting supply chain management processes,
• conducting logistics activities,
• conducting activities in accordance with the legislation,
• will be processed for the purpose of conducting occupational health and safety activities.

Our Supplier Official

The identity information of our real person suppliers or the officials of our legal entity suppliers identity information, contact information, physical location security, customer transaction information, financial information, marketing information, legal transaction information;

• conducting/auditing business activities,
• conducting purchasing processes for goods/services,
• conducting finance and accounting affairs,
• conducting contract processes,
• conducting investment processes,
• ensuring physical location security,
• will be processed for the purpose of following and conducting legal affairs.

What Are the Methods of Collecting Your Personal Data?

Your personal data specified above in categories; are collected by physical means such as order forms, contracts, visitor forms, or by information systems and electronic devices (e.g., telecommunications infrastructure, computers and phones), third parties (e.g., KKB and Findeks), our website and other documents declared by the relevant person, by automatic or non-automatic means.

What Is the Legal Reason for Collecting Your Personal Data?

Your personal data, by SENTE MAKINA; in line with the realization of the above-mentioned purposes, in accordance with Article 5 of the KVKK;

(i) Explicitly stipulated in the laws,

(ii) Being necessary for the establishment or performance of a contract, provided that it is directly related to the establishment or performance of the contract,

(iii) Being mandatory for the data controller to fulfill its legal obligation,

(iv) Being mandatory for the establishment, exercise, or protection of a right,

(v) Processing is necessary for the legitimate interests pursued by the data controller, provided it does not harm the fundamental rights and freedoms of the data subject.

When the data processing activity cannot be based on one of the above legal reasons, your personal data is processed based on your explicit consent.

Do We Transfer Your Personal Data to a Third Party?

a) Personal data of our visitors can be shared with law enforcement and judicial authorities if requested for resolving legal disputes and as required by relevant legislation.

b) Personal data of our online visitors can be shared with judicial authorities and authorized public institutions and organizations if requested for resolving legal disputes and as required by relevant legislation.

c) Personal data of our customers, within the scope stipulated by legal regulations, is transferred to authorized public institutions and organizations for the purpose of conducting activities in accordance with the legislation, following and conducting legal affairs, providing information to authorized persons, institutions and organizations; conducting business activities/audit, conducting risk management processes, and properly fulfilling our services, as necessary, to our group companies, suppliers, cargo companies, insurance companies, banks, and our financial advisor. Furthermore, the said personal data may be transferred to the law firm we receive services from and to judicial authorities to be used as evidence in potential future legal disputes.

d) Personal data of our potential customers may be transferred to the law firm we receive services from and to judicial authorities to be used as evidence in potential future legal disputes.

e) Personal data of our supplier employee, within the scope stipulated by legal regulations, is transferred to authorized public institutions and organizations for the purpose of conducting activities in accordance with the legislation, following and conducting legal affairs, providing information to authorized persons, institutions and organizations; conducting business activities/audit, and properly fulfilling the service, as necessary, to our group companies, suppliers, cargo companies, banks, and our financial advisor. Furthermore, the said personal data may be transferred to the law firm we receive services from and to judicial authorities to be used as evidence in potential future legal disputes.

f) Personal data of our supplier official, within the scope stipulated by legal regulations, is transferred to authorized public institutions and organizations for the purpose of conducting activities in accordance with the legislation, following and conducting legal affairs, providing information to authorized persons, institutions and organizations; conducting business activities/audit, and properly fulfilling the service, as necessary, to our group companies, suppliers, cargo companies, banks, and our financial advisor. Furthermore, the said personal data may be transferred to the law firm we receive services from and to judicial authorities to be used as evidence in potential future legal disputes.

Do We Transfer Your Personal Data Abroad?

As SENTE MAKINA, we do not transfer your personal data abroad.

How Can You Exercise Your Rights Regarding Your Personal Data?

You can submit your requests within the scope of Article 11 of the KVKK regulating the rights of relevant persons, through the “Application Form to Data Controller” prepared to facilitate this for you, available at “https://sentemakina.com.tr/”.

Data Controller: SENTE MAKİNA İNŞ. SAN. VE TİC. LTD. ŞTİ.

Address: Adnan Kahveci Mah. Gölboyu Cad. No:20 Beylikdüzü İstanbul

Mail: [email protected]