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PERSONAL DATA PROTECTION, PROCESSING AND PRIVACY POLICY OF VERIM AGENCY IMPORT EXPORT INDUSTRY AND TRADE JOINT STOCK COMPANY
1. INFORMATION ON THE PROTECTION, PROCESSING AND DATA PRIVACY OF PERSONAL DATA
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The protection of personal data is among the highest priorities of Verim Denizcilik Gemi AcenteliÄŸi Ä°thalat Ä°hracat Sanayi ve Ticaret Anonim Åžirketi (“Company”, “Verim Agency”, or “Data Controller”). We make every effort to act in full compliance with all applicable legislation in force.
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Within the framework of this Personal Data Protection, Processing and Data Privacy Policy (“Policy”), the principles adopted in the conduct of personal data processing activities carried out by Verim Agency and the fundamental principles adopted to ensure compliance with the Law No. 6698 on the Protection of Personal Data (“KVKK”) are explained. As the Data Controller, we hereby inform personal data subjects and ensure the necessary transparency. With full awareness of our responsibility in this respect, your personal data is processed and protected in accordance with this Policy.
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The website https://www.verimagency.com (“Website”) belongs to the Company. The information and data security of real persons such as visitors to this Website, our employees, employee candidates, customers, business partners, suppliers, and other third parties are of great importance to Verim Agency.
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As the Data Controller, we would like to inform you about the KVKK, which regulates the obligations of real and legal persons processing personal data and the procedures and principles to be followed, primarily for the protection of the right to privacy and fundamental rights and freedoms.
Pursuant to the KVKK, personal data refers to any information relating to an identified or identifiable natural person (such as name, surname, Turkish ID number, IP address, contact details, etc.).
Your personal data may be processed by the Data Controller, fully or partially by automated means or by non-automated means provided that it forms part of any data recording system, within the scope of the KVKK, the Electronic Communications Law No. 5809, regulations of the Information and Communication Technologies Authority, the Personal Data Protection Authority, and other relevant legislation.
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In accordance with applicable legislation, the Data Controller continues to take all necessary technical and administrative measures to ensure an appropriate level of security in order to prevent unlawful processing and access and to ensure the safeguarding of personal data.
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Activities carried out by Verim Agency regarding the protection of employees’ personal data are managed through the disclosure texts included in Employment Agreements prepared in line with this Policy and the General Privacy Notice published on the Website.
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In the event of any inconsistency between this Policy and applicable legislation, the provisions of the legislation shall prevail. This Policy concretizes the rules set forth by legislation within the scope of Company practices.
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Your personal data may be obtained by the Data Controller only within the scope of your knowledge or consent.
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Personal data processed automatically on the Website or processed by the Data Controller by automated or non-automated means shall be protected in accordance with the KVKK and may be retained for the period permitted by law, without prejudice to your rights under Article 11 of the KVKK.
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The Data Controller may process your personal data in accordance with the KVKK and relevant legislation within the scope described below.
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Our Website may contain links to other websites not operated by Verim Agency. If you visit any of these websites, you should review their privacy and other policies. The Company is not responsible for the policies and practices of other companies.
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Finally, please note that the Company reserves the right to amend its privacy policies. Therefore, we recommend that you regularly review the Privacy Policy and Personal Data Protection pages on our Website.
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2. MATTERS RELATING TO THE PROCESSING OF PERSONAL DATA
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a) Processing in Compliance with Legal Principles
Personal data is processed in accordance with the principles of good faith and fairness, without harming fundamental rights and freedoms.
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Verim Agency takes necessary measures to ensure that personal data remains accurate and up to date during the period it is processed and establishes mechanisms for periodic verification.
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Verim Agency determines the purposes of processing clearly and collects personal data only to the extent required by business activities, limited to and in connection with the stated purposes.
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Verim Agency retains personal data for the period necessary for the purpose of processing and for the minimum period stipulated by applicable legislation.
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If a retention period is prescribed by legislation, Verim Agency complies with such period. If no legal period is prescribed, personal data is retained only for the period necessary for the purpose for which it is processed.
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At the end of the retention periods, personal data is destroyed through deletion, destruction, and/or anonymization in accordance with periodic destruction schedules or upon data subject request.
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b) Conditions for Processing Personal Data
Except where explicit consent is obtained, personal data may be processed where one or more of the following legal grounds exist:
• Where it is explicitly stipulated by law.
• Where processing is mandatory to protect the life or physical integrity of a person who is unable to express consent due to actual impossibility or whose consent is legally invalid.
• Where processing is directly related to the establishment or performance of a contract to which the data subject is a party.
• Where processing is mandatory for the Company to fulfill its legal obligations.
• Where the data subject has made the personal data public (limited to the purpose of disclosure).
• Where processing is mandatory for the establishment, exercise, or protection of a right.
• Where processing is mandatory for the legitimate interests of the Company, provided that it does not harm the fundamental rights and freedoms of the data subject.
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Special categories of personal data are processed in compliance with the principles set forth in this Policy and by taking all necessary administrative and technical measures, including those determined by the Personal Data Protection Board.
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Special categories other than health and sexual life may be processed without explicit consent where explicitly permitted by law. Otherwise, explicit consent is required.
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Data relating to health and sexual life may be processed without explicit consent by persons or authorized institutions under confidentiality obligations for purposes such as protection of public health, preventive medicine, medical diagnosis, treatment, and healthcare management. Otherwise, explicit consent is required.
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c) Informing the Data Subject
In accordance with Article 10 of the KVKK, Verim Agency informs data subjects regarding the identity of the data controller, purposes of processing, recipients of data transfers, methods and legal grounds for collection, and the rights of data subjects.
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d) Method and Legal Grounds for Collection
Personal data may be collected verbally, in writing, or electronically (mobile applications, website, email, SMS, call center, etc.), by automated or non-automated means, in accordance with Articles 5 and 6 of the KVKK and based on legitimate interests or other applicable legal grounds.
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e) Transfer of Personal Data
Personal data may be transferred to regulatory authorities, public institutions, business partners, suppliers, affiliates, banks, financial institutions, consultants, auditors, shareholders, and authorized persons domestically or abroad, in accordance with Articles 8 and 9 of the KVKK and by taking necessary security measures.
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Transfers abroad may be made to countries declared by the Board as having adequate protection.
If adequate protection is not available, transfers may be made to countries where adequate protection is contractually undertaken and approved by the Board.
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Special categories of personal data are transferred under the same safeguards and legal grounds described above.
3. MATTERS RELATING TO THE PROTECTION OF PERSONAL DATA
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In accordance with Article 12 of the KVKK, Verim Agency takes necessary technical and administrative measures to prevent unlawful disclosure, access, transfer, or other security vulnerabilities.
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Audits are conducted and necessary awareness trainings are organized to prevent unlawful processing and unlawful access.
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Verim Agency ensures employee awareness regarding personal data protection and cooperates with consultants when necessary.
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4. CONFIDENTIALITY AND SECURITY OF PERSONAL DATA
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Certain special categories of personal data (such as race, ethnicity, political opinion, religion, union membership, health, sexual life, criminal convictions, biometric and genetic data) are subject to enhanced protection under the KVKK.
Verim Agency applies heightened technical and administrative safeguards to protect such data and ensures internal controls and audits.
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5. USE OF COOKIES AND SIMILAR TECHNOLOGIES
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Information collected through the Website is processed via cookies and similar technologies to improve user experience, analyze traffic, and provide personalized services.
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The Cookie Policy is available at https://www.verimagency.com.
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Users may manage cookie preferences through browser or device settings or via relevant third-party tools such as Google Analytics and Adobe Analytics.
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6.PURPOSES OF PROCESSING, RETENTION AND DESTRUCTION
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Personal data may be processed for purposes including fulfillment of contractual and legal obligations, execution of human resources processes, conduct of commercial activities, customer services, marketing activities, risk management, fraud prevention, financial reporting, emergency assistance coordination, and ensuring legal, technical, and commercial security.
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Personal data is retained for statutory periods or as long as necessary for processing purposes.
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At the end of retention periods, data is destroyed through deletion, destruction, or anonymization.
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7. AMENDMENTS TO DATA PRIVACY PRINCIPLES
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These principles may be amended in accordance with legislative changes.
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Announcements regarding amendments will be published on the Website.
8. RIGHTS OF THE DATA SUBJECT
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Pursuant to Article 11 of the KVKK, data subjects have the right to:
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(1) Learn whether personal data is processed.
(2) Request information if processed.
(3) Learn the purpose of processing and whether it is used accordingly.
(4) Learn third parties to whom data is transferred.
(5) Request correction of incomplete or inaccurate data.
(6) Request deletion or destruction.
(7) Request notification of such actions to third parties.
(8) Object to automated decision-making.
(9) Claim compensation for damages resulting from unlawful processing.
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Requests may be submitted by completing the Data Subject Application Form available on the Website and sending a signed copy to:
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Verim Denizcilik Gemi AcenteliÄŸi Ä°thalat Ä°hracat Sanayi ve Ticaret Anonim Åžirketi
Soğanlık Yeni Mah. Aliağa Sk. Bumerang Kartal No:8/130
34880 Kartal / Ä°stanbul
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Applications will be finalized free of charge within 30 days, unless additional cost is required under the tariff determined by the Board.
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If a data subject requests that certain personal data not be used, they acknowledge that they may not fully benefit from the Website and accept any resulting responsibility.