Personal Data Protection and Processing Information Text

As Progress Tekstil San. ve Dış Tic. Ltd. Şti., as the Data Controller, we would like to inform you within the scope of the Personal Data Protection Law No. 6698 (“KVKK”), published in the Official Gazette dated 7 April 2016 and numbered 29677, in order to determine the obligations of individuals and legal entities during the processing of personal data to protect fundamental rights and freedoms, especially the privacy of private life.

1.2. Progress Tekstil San. ve Dış Tic. Ltd. Şti., located at Mehmet Nesih Özmen Mah. Akasya Sok. Akasya İş Mrk. No: 6/8 Merter – Güngören / ISTANBUL, has prepared this information text to ensure that the personal data of our citizens are processed in accordance with the relevant legislation, especially the Constitution of the Republic of Turkey and the international agreements on Human Rights to which our country is a party, and to enable the owners of processed data to effectively exercise their rights. All personal data shared with our company may be processed in compliance with the law, in connection with our activities and service purposes, and in a proportionate manner.

2. Definitions

2.1. The concepts of personal data, sensitive personal data, and data processing used in the explanation text are used in accordance with the definitions set forth in the Law on Protection of Personal Data (“LPPD”). Within the scope of the GDPR:

2.1.1. Personal Data Protection Law (“KVKK”): The Law on Protection of Personal Data (“KVKK”), published in the Official Gazette dated 7 April 2016 and numbered 29677 (known as GDPR).

2.1.2. Personal Data: Any kind of information relating to an identified or identifiable natural person.

2.1.3. Data Processor: Natural or legal person who processes Personal Data on behalf of the Data Controller, authorized by the Data Controller.

2.1.4. Data Controller: Natural or legal person who determines the purposes and means of processing Personal Data and is responsible for establishing and managing the data recording system.

2.1.5. Processing of Personal Data: Any operation performed on Personal Data, whether fully or partially automatic or not, including but not limited to obtaining, recording, storing, preserving, altering, rearranging, disclosing, transferring, taking over, making available, classifying, or preventing the use of Personal Data, provided that such operations are carried out as part of any data recording system, and encompasses all kinds of transactions carried out on Personal Data.

3. Principles of Processing Personal Data

3.1. Personal data belonging to the data subject, as stated in Article 4 of the KVKK, will be processed by the Company in accordance with legal and honesty rules, for specific, clear, and legitimate purposes, accurately and necessarily where required, limited and measured for the purpose of processing, and stored for the period prescribed by the relevant legislation or for the time required for the purpose of processing.

4. Purpose of Processing Your Personal Data

4.1. Your personal data will be processed in accordance with Articles 4, 5, and 6 of the KVKK;

4.1.1. In accordance with the law and honesty rules,

4.1.2. In compliance with the storage rules for the period prescribed by the relevant legislation or for the time required for the purpose of processing,

4.1.3. In compliance with the storage rules for the period prescribed by the relevant legislation or for the time required for the purpose of processing,

4.1.4. For specific, clear, and legitimate purposes, and for the period prescribed by the relevant legislation or for the time required for the purpose of processing.

4.2. Your personal data may be used by our business units to carry out necessary activities for you to benefit from the products and services offered by our company; to recommend our company’s products and services to you; to plan and/or conduct market research activities for the sale and marketing of products and services; to plan and/or conduct after-sales support services activities; to follow up contract processes and/or legal requests, to ensure the legal, technical, and commercial security of the relevant persons in business relations; to ensure the implementation of our company’s human resources policies, to evaluate your application if you apply for a job, to fulfill our legal and statutory obligations if you become an employee of our company; to ensure quality control; to track the procurement of products; for security and identification purposes when you visit our business premises; to contact you if you request information from our company; for the execution of this contract if you purchase a product; to plan, audit, and execute information security processes; to establish and manage information technology infrastructure; to follow up financial and/or accounting transactions; to follow up legal affairs; to plan and execute business activities; to plan and execute corporate communication activities; to determine and implement our company’s commercial and business strategies. In addition, workplace data may be processed by our company or by natural or legal persons authorized by our company, for operational reasons such as increasing work performance, ensuring employee satisfaction, and ensuring occupational safety and peace, in accordance with the Labor Law and the Legislation on Occupational Health and Safety and other current legislation.

5. Transfer of Personal Data

5.1. Your personal data may be transferred within the company and to our affiliates, suppliers, stakeholders, legally authorized public institutions, and private persons by our business units within the company, for the purpose of carrying out the necessary activities for you to benefit from the products and services offered by our company, within the framework of the conditions and purposes of processing personal data specified in Articles 8 and 9 of the KVKK.

6. Method of Collecting Personal Data and Legal Basis

6.1. Personal data is collected, used, recorded, stored, and processed by our company in accordance with legal and good faith principles, by obtaining explicit consent orally, in writing, and/or electronically in a specific and understandable manner from the data subjects, and when necessary, clear and understandable information is provided to the data subjects. Additionally, your personal data is collected through different channels and based on different legal reasons within the commercial purpose of our company, such as contacting you by our business units, establishing a contractual relationship, visiting our business premises, providing your contact information for commercial activities, and sharing information in promotional events. Your personal data collected on the basis of this legal reason may be processed and transferred within the scope of the personal data processing conditions and purposes specified in this Information Text.

6.2. Furthermore, we guarantee that your personal data will not be processed for purposes other than those stated in this information document and will not be transferred to third parties within or outside Turkey.

7. Storage and Deletion of Data

7.1. Our company stores the personal data it processes for the periods specified in the legislation, and in cases where additional periods are not specified in the legislation; it stores the data processed during the processing of personal data in accordance with the application and customs of our company’s commercial life, depending on the services provided for processing, and after the end of this period, it keeps the data only for the periods required to create evidence in possible legal disputes. After the expiry of the specified periods, the relevant personal data is deleted, destroyed, or anonymized.

8. Rights of the Data Subject

8.1. Data subjects may apply to the company as the data controller for any data related to the individual;

8.1.1. To learn whether personal data is being processed,

8.1.2. To request information if personal data has been processed,

8.1.3. To learn the purpose of processing personal data and whether they are used in accordance with their purpose;

8.1.4. To obtain information about third parties to whom personal data is transferred domestically or abroad,

8.1.5. To request correction of personal data if it is processed incorrectly or incompletely,

8.1.6. To request the deletion or destruction of personal data within the framework of the conditions specified in Article 7 of the Law No. 6698 on the Protection of Personal Data,

8.1.7. To object to the occurrence of a result against the individual by analyzing the processed data solely through automated systems,

8.1.8. If personal data is processed unlawfully, to demand compensation for damages.

8.2. To exercise the above-mentioned rights, you can send your written application containing necessary information identifying your identity, along with the Wet-Signed Personal Data Information Request and Transaction Form to the address “groupprogress.com” or our company’s registered email address “[email protected]“ using secure electronic signature, mobile signature, or the email address registered in the data controller’s system by the relevant person. Applications must be made in Turkish.

8.3. If the applications are in writing, they must include name, surname, and signature, Republic of Turkey Identity Number for Turkish citizens, nationality, passport number/ID number for foreigners, residence or workplace address for notification, email address, phone or fax number, and subject of the request.

8.4. Your personal data subject application, which you will make to exercise the above-mentioned rights, must contain your explanations regarding the right you request, especially if it is related to you or if you act on behalf of someone else, you must be specially authorized in this regard and document your authority, it must include identity and address information and documents proving your identity must be attached to the application.

8.5. Within this scope, your applications will be concluded as soon as possible and at the latest within 30 days. When a response to the data subject’s request is required to be made in writing, up to ten pages are free of charge. A processing fee of 1 TL per page may be charged for each page over ten. If the response to the application is provided in a recording medium such as a CD, USB flash drive, the fee that can be requested by Progress Tekstil San. ve Dış Tic. Ltd. Şti., Mehmet Nesih Özmen Mah. Akasya Sok. Akasya İş Mrk. No: 6/8 Merter – Güngören / ISTANBUL cannot exceed the cost of the recording medium.