Information Notice and Privacy Policy Regarding the Law on the Protection of Personal Data
 
LİKİT KİMYA SANAYİ VE TİCARET A.Ş. (“LİKİT KİMYA”) has adopted the protection of all personal data belonging to natural persons that we obtain in any manner, and the full compliance with the requirements under the Personal Data Protection Law No. 6698 (“Law”) and related legislation, as one of our institutional policies. This Personal Data Protection and Privacy Policy (“PDP Policy”) informs LİKİT KİMYA employees, job applicants, current and potential customers about the processes and principles regarding the collection, use, sharing, storage, deletion, and destruction of personal data collected by LİKİT KİMYA in any manner, as well as related principles. www.likitkimya.com users of our website, our visitors, and other individuals in a relationship with LİKİT KİMYA.
 
LİKİT KİMYA, as the data controller, has assumed responsibility for establishing the necessary organizational structure and implementing and adapting technical measures to protect the confidentiality and integrity of information in accordance with the provisions of applicable legislation.
 
LİKİT KİMYAtakes the necessary measures to prevent unauthorized access to personal data and to protect personal data against loss, misuse, disclosure, alteration, or destruction.
 
LİKİT KİMYA, upon detecting any breach, promptly informs users, facilitates appropriate legal action, and ensures the security of their information to the best of its ability.
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  1. Definition of Personal Data

 
The term “Personal Information” used in this Data Protection Policy may refer to information that identifies a natural person, such as their name, surname, date of birth, and place of birth; it may also include all data that directly or indirectly identifies an individual, such as phone numbers, vehicle license plates, Turkish ID numbers, passport numbers, resumes, photographs, video and audio recordings, fingerprints, email addresses, hobbies, preferences, people with whom one interacts, group memberships, family information, and health information. Additionally, pursuant to Article 6 of the Law, special category personal data; “Data related to a person’s race, ethnic origin, political views, philosophical beliefs, religion, denomination, or other beliefs, attire, membership in associations, foundations, or trade unions, health, sexual life, criminal convictions, and security measures, as well as biometric and genetic data.”
 

  1. Legal Basis for the Collection of Personal Data

 
Various laws contain provisions regarding the use of users’ personal data. First and foremost, Article 20 of the Constitution, Law No. 5651 on the Regulation of Publications Made on the Internet and the Fight Against Crimes Committed Through Such Publications, Law No. 6331 on Occupational Health and Safety, Law No. 6698 on the Protection of Personal Data, and other laws and related regulations establish the principles for the protection of personal data.
 

  1. Methods of Collecting Personal Data

 
 
LİKİT KİMYA collects personal data from building visitors during their visits, from documents and information provided by employees or job applicants during the hiring and onboarding process, from documents and information provided by employees for their personnel files, from insurance documents, and from contracts with suppliers and business partners, www.likitkimya.com the website, from public institutions and organizations, judicial authorities, and through other legitimate, legal means in compliance with the Law.
 

  1. Basic Rules Regarding the Processing of Personal Data

 
LİKİT KİMYA processes personal data in accordance with the Law and the basic rules set forth below.
 

  1. Compliance with legal and ethical principles,
  2. Accuracy and timeliness,
  3. Fulfillment of the obligations of transparency and disclosure,
  4. Data reduction and ensuring data efficiency,
  5. Processing for specific, explicit, and legitimate purposes,
  6. Processing that is relevant, limited, and proportionate to the purpose for which it is processed,
  7. Retention for the period prescribed by applicable legislation or as necessary for the purpose for which they are processed.

 

  1. Purposes of Processing Personal Data

 
Personal Information is part of our Data Protection Policy and www.likitkimya.com on our website, and for the purposes listed below; under no circumstances will it be used for any purpose other than those specified.
 

  1. Information sharing necessary for the provision of the service,
  2. Purchasing and supplier relations,
  3. Hiring and employment processes,
  4. All HR matters related to company employees,
  5. Archiving activities following termination of employment,
  6. Statistical studies,
  7. Orders, instructions, and practices of official authorities,
  8. Occupational Health and Safety services,
  9. Tracking and resolving customer complaints and requests,
  10. Tracking of accounting transactions,
  11. Monitoring financial matters and, where necessary, ensuring they are reported in accordance with legal requirements,
  12. Internal control and audit activities,
  13. Establishing and managing the information security infrastructure,
  14. Processes related to the provision of building and perimeter security services,
  15. Planning and executing the necessary operational activities to ensure that company operations are conducted in accordance with internal procedures and policies prepared under the Personal Data Protection Law,
  16. Planning of internal reporting and business development activities,
  1. Planning and managing customer satisfaction activities,
  2. To ensure compliance with the laws to which our company is subject.

 

  1. Conditions for the Processing of Personal Data

 
Personal data may be processed only with the explicit consent of the data subject. In cases where explicit consent is not present, personal data may be processed only if the following conditions are met:

  1. Explicitly provided for by law,
  2. It is necessary to protect the life or physical integrity of the person themselves or another person, where the person is unable to express consent due to actual impossibility or where their consent is not legally valid,
  3. The processing of personal data belonging to the parties to a contract is necessary, provided that it is directly related to the conclusion or performance of the contract,
  4. It is necessary for the data controller to fulfill its legal obligations,
  5. The personal data has been made public by the data subject themselves,
  6. Processing is necessary for the establishment, exercise, or defense of a legal claim,
  7. The processing of data is necessary for the legitimate interests of the data controller, provided that such processing does not infringe upon the fundamental rights and freedoms of the data subject.

 
Furthermore, as LİKİT KİMYA, we do not process special category personal data without the data subject’s explicit consent. However, special category personal data other than data related to health and sexual life may be processed without the data subject’s explicit consent in cases provided for by law. Furthermore, data related to health and sexual life may be processed without explicit consent provided that adequate safeguards are in place and the following grounds exist:
 

  1. Protection of public health,
  2. Preventive medicine,
  3. Medical diagnosis,
  4. Provision of treatment and care services within the scope of occupational medicine,
  5. Planning and management of healthcare services and their financing.

 

  1. Retention Periods for Personal Data

 
LİKİT KİMYA stores personal data in physical documents and/or digital formats—but only for as long as necessary and in a secure environment—whether to carry out its business activities, to comply with legal processes, or to address potential requests from government agencies, institutions, and courts. LİKİT KİMYA will delete, destroy, or anonymize such data once the purpose of processing that personal data has ended, or—provided it does not violate laws and regulations—upon the data subject’s request, except in cases where laws and regulations require the retention of personal data for a longer period. Data deleted in this manner can no longer be used in any way.
 
LİKİT KİMYA retains personal data for the periods specified below, unless laws and relevant regulations require a longer retention period:
 

  1. Personal data regarding employees is retained for 5 to 10 years following the termination of the employment contract for any reason, in accordance with Law No. 4857,
  2. Resume information and application forms of job applicants are retained for 2 years from the date of application, in accordance with the LİKİT KİMYA HR Regulation,
  3. Health data regarding employees is retained for 15 years following the termination of the employment relationship, in accordance with Law No. 6331 on Occupational Health and Safety,
  4. Personal data regarding building visitors, for 8 years from the date of departure from the building, Law No. 5237,
  5. Video recordings collected via cameras, LİKİT KİMYA HR Regulation,
  6. Audio recordings obtained as part of building management services are retained for 10 years, Law No. 6098, Law No. 6102,
  7. All records related to accounting and financial transactions are retained for 10 years after the legal relationship ends, under Law No. 6098, Law No. 6102, and Law No. 213,
  8. Commercial electronic communications: 1 to 10 years depending on the subject matter of the communication, Law No. 6563 and relevant secondary legislation, Law No. 6102, Law No. 6098, and Law No. 213,
  9. Traffic data generated through connection to a corporate network is retained for 2 years, in accordance with Law No. 5651,
  10. Personal data regarding customers and prospective customers for 10 years, Law No. 6563, Law No. 6102, Law No. 6098, Law No. 213, Law No. 6502, Law No. 5549,
  11. Personal data regarding suppliers and prospective suppliers is retained for 10 years, in accordance with Law No. 6102, Law No. 6098, and Law No. 213.

 

  1. Technical and Administrative Measures Taken to Ensure the Security of Personal Data

 
LİKİT KİMYA has taken all necessary technical and administrative measures to ensure the lawful processing of personal data, to ensure that only authorized persons have access to personal data, and to ensure the secure storage of personal data. LİKİT KİMYA updates its security level as needed. LİKİT KİMYA implements the following measures as part of these technical and administrative safeguards:
 

  1. Ensures that personal data in paper form is stored in locked cabinets and accessed only by authorized personnel.
  2. Although LİKİT KİMYA takes the necessary information security measures, in the event that personal data is damaged or falls into the hands of unauthorized third parties as a result of attacks on platforms or systems operated by LİKİT KİMYA, LİKİT KİMYA will immediately notify you and the Personal Data Protection Board of this situation and take the necessary measures.

 
 

  1. Sharing of Personal Information

 
At LİKİT KİMYA, any Personal Information obtained in any manner is used solely for the purpose of the service provided and, as a general rule, is never shared with third parties under any circumstances. However, personal data may be transferred to the individuals and organizations listed below for specific purposes;
 

  1. To the individuals and institutions auditing LİKİT KİMYA,
  2. To public institutions, organizations, and judicial authorities, limited to the purpose requested in accordance with the law.
  3. To third-party service providers we engage with, for the purposes of improving service quality and ensuring personal data security.

 

  1. Users’ rights under the Personal Data Protection Law:

 
Under the KVKK, regarding your personal data;

  • To learn whether your personal data has been processed,
  • If processed, do not request information,
  • To learn the purpose of processing and whether it is being used in accordance with that purpose,
  • To know the third parties to whom it has been transferred within or outside the country,
  • Requesting correction if the data has been processed incompletely or incorrectly,
  • Requesting the deletion or destruction of your personal data in accordance with the conditions set forth in Article 7 of the KVKK,
  • Request that the third parties to whom your data has been transferred be notified of the actions taken in accordance with subparagraphs (d) and (e) above,
  • Object to a decision made solely through automated processing that adversely affects you,
  • We would like to remind you that you have the right to request compensation for any damages incurred as a result of the processing of your personal data in violation of the KVKK.

 

  1. Your Consent Regarding the Processing of Your Personal Data

 
By giving your explicit consent to LİKİT KİMYA or by using this website at www.likitkimya.com, you agree that we may use all information collected from you in the manner and for the reasons specified above, as described in this Privacy Policy. The information obtained for the above purpose is provided to us entirely of your own free will. Users are free to choose whether or not to provide us with this Personal Information.
 

  1. Policy Updates

 
We may review, amend, or update our Policy and the way we process personal information from time to time. We will publish the updated Policy on our website at www.likitkimya.com. The updated terms will take effect as of the date of publication.
 
In accordance with the above statements and within the scope of the disclosure obligation set forth at www.likitkimya.com, and in compliance with the Personal Data Protection Law (KVKK), LİKİT KİMYA SANAYİ VE TİCARET A.Ş. I consent to the collection, processing, updating, periodic review, storage, and retention of my personal data by LİKİT KİMYA SANAYİ VE TİCARET A.Ş., as well as the sharing of my personal data with the institutions and organizations specified in Article 4 and the storage and retention of my personal data by them.
 
This information notice has been prepared to fulfill the obligation to provide information in accordance with Article 10 of the Personal Data Protection Law (KVKK).
 
The Data Controller Representative to be appointed by our company will be announced in the Data Controllers Registry and on the website where this document is located once the legal framework is established. Data Subjects should submit their questions, opinions, or requests in writing to “info@likitkimya.com” . In such cases, a written response will be provided within 30 days.
 

  1. Our contact information

 
If you have any questions, suggestions, or other requests regarding our Privacy Policy or other data protection practices, you can contact us at the following address:
 

  • Contact address: İnfo@likitkimya.com
  • Phone number: (0216)4993000

 
 
LİKİT CHEMICAL INDUSTRY AND TRADE INC.
Last Updated: March 21, 2019