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a) Data Controller and Representative

Transvaro Elektron Aletleri Sanayi ve Ticaret Anonim Şirketi (“TRANSVARO”) gives utmost importance to security of your personal data. Thus, TRANSVARO attaches particular value to achieving full compliance with Personal Data Protection Law numbered 6698 (“Law”) while processing and storing personal data of natural persons (“individuals”, “data subjects”). Data subjects personal data will be processed by TRANSVARO as a Data Controller within the scope described below. 

b) Purposes of Processing Personal Data

Data subjects personal data that indicated below will be processed within the personal data processing conditions specified in Articles 5 and 6 of the Law. 

• Data subjects personal data will be processed regarding the necessary operations and related business processes conducting by TRANSVARO, for establishing and managing the information technology infrastructure, ensuring planning and performing business continuity activities and transactions, arranging and fulfilling corporate communication activities, event management, carrying out procurement activities and transactions, planning and performing corporate sustainability activities,

• Personal Data and photos of data subjects, which is processed and stored by TRANSVARO in accordance with the Law, can be used in all corporate affiliation activities, including advertising and promotion,

• Employees or candidates’ personal data will be processed  for conducting internship/vocational training/scholarship/training scheme activities pursuant to  applicable legislation and contracts,

• Data subjects personal data will  be processed  for fulfilling the liabilities of informing, storing, reporting and any other obligations defined and foreseen in the relevant legislation,

• Regarding the necessary operations and related business processes, personal data of the individuals who will benefit from goods, services and support provided by TRANSVARO will be processed,

• Personal data, of the data subjects which are customized with the likes, usage habits and needs will be processed for the planning and performing of the activities required for the recommendation and promotion of the goods, services and supports offered by TRANSVARO,

To find detailed information regarding the purposes of processing personal data please check TRANSVARO Personal Data Protection and Processing Policy on the website

c) Transfer of Personal Data 

Personal data can be transferred domestically and internationally through processing to our shareholders, affiliates and subsidiaries, business partners, suppliers and authorized public institutions or third parties in accordance with applicable legislation regarding the purposes specified in the “TRANSVARO Personal Data Protection and Processing Policy” in accordance with achieving the objectives stated above and within the framework of the personal data processing conditions and purposes specified in Articles 8 and 9 of the Law.

ç) The Method and Legal Basis of Collection of Personal Data

Personal data is collected and stored based on different legal or commercial reasons via physically or electronically by TRANSVARO through different communication channels, in order to develop, continue or fulfil the obligations of TRANSVARO arising from the legislation and to serve in favour of individual.

d) Rights of the Data Subject, Listed in Article 11 of the Law

As the data subjects, by submitting your requests regarding the rights listed in Article 11 of the Law using the methods described herein and TRANSVARO Processing and Personal Data Protection and Processing Policy, TRANSVARO will finalize the request free of charge as soon as possible and within thirty days at the latest, depending on the nature of the request. However, if the transaction requires an additional cost, TRANSVARO will charge the fee listed in the tariff determined by the Personal Data Protection Board. In this context, the rights of personal data owners are as follows.

• to learn whether his/her personal data is processed or not,

• to demand for information as to whether his/her personal data have been processed,

• to learn the purpose of the processing of his/her personal data and whether these personal data are used in compliance with the purpose,

• to know the third parties to whom his personal data is transferred within the country or abroad,

• to request the rectification of the incomplete or inaccurate data, if any,

• If, in despite of processing compliant with the provisions of Law and other applicable laws, reasons that require processing of personal data are no longer available, to request the erasure or destruction of his/her personal data under the condition and to request information regarding the third parties, to whom the personal data is transferred, to be notified about the actions performed under this sub-paragraph,

• to object to the occurrence of a result against the person himself/herself by analysing the data processed solely through automated systems,

• to claim compensation for damages arising from the unlawful processing of his/her personal data. 

e) Storage Period for Personal Data

The personal data shared with TRANSVARO through the channels mentioned in such Information Note will be stored in accordance with the prescribed periods stipulated in the Law and the relevant legislation. Actions that will be taken after the expiry of the said period or in case there is no storing period stipulated in Law and relevant legislation are prescribed in the TRANSVARO Personal Data Storage and Destruction Policy.

Pursuant to the first paragraph of Article 13 of the Law titled “Application to Data Supervisor”, you as a data subject, can use the rights stated above and submit a application to TRANSVARO in written form or by other methods determined by the Personal Data Protection Board. You must submit your application to TRANSVARO in accordance with the Law, within this framework; the channels and procedures regarding your application are explained below.

You can submit your request to use your rights mentioned in Article 11 of the Law by completing the form given in www.transvaro/en/pdp and sending a signed copy of it to [email protected] or delivering it to TRANSVARO Elektronik Sanayi ve Ticaret Anonim Şirketi at the address; Halkalı Merkez Mh. Dereboyu Cd. Çalışkan Sokak, No.4 34303 Küçükçekmece/İstanbul/Turkey with the required information to make your identity specific or through public notary or through other means described in Law or sending the form to [email protected] with your secure electronic signature.

In case of a discrepancy between Turkish and English version of this Policy, the Turkish version shall prevail which is available on TRANSVARO’s official website (