CLARIFICATION TEXT ON CAMERA RECORDINGS UNDER THE PERSONAL DATA PROTECTION LAW

This clarification text, in accordance with the Personal Data Protection Law No. 6698 (“ KVKK ” or “Law” ) and relevant legislation, Muya Poliüretan Kauçuk San. Tic. Inc. It has been prepared and submitted for your information in order to fulfill the disclosure obligation of our Company, which has the title, regarding data processing activities within the scope of camera recordings.

  1. Your Personal Data We Process

Our Company processes personal data in the form of people's images and, when necessary, their voices, by taking images with a closed circuit camera system (CCTV) in order to monitor the entries and exits of employees, guests, subcontractors and their vehicles in administrative buildings, warehouse areas and open areas within the borders of our Company. .

  1. Processing Method and Legal Reason for Your Personal Data

Our company collects your personal data obtained by taking images with a closed circuit camera system (CCTV); KVKK article 5(2)(a) in order to fulfill the legal obligations clearly stipulated in the secondary legislation, including but not limited to the Labor Law no. 4857, the Occupational Health and Safety Law no. 6331, the Law on Private Security Services no. 5188 and the regulations and communiqués issued based on these laws. ) " explicitly foreseen by law " stated in KVKK article 5(2)(ç), "must be mandatory for the data controller to fulfill its legal obligation " stated in KVKK article 5(2)(e) and " establishment of a right " stated in KVKK article 5(2)(e) It is processed based on the legal reasons "data processing is mandatory for the use or protection of data" and " data processing is mandatory for the legitimate interests of our Business, which is the data controller " specified in Article 5(2)(f) of the KVKK.

In the processing of your personal data, our company adheres to the data processing principles and obligations specified within the scope of the relevant legislation, especially the Constitution of the Republic of Turkey, international agreements to which the Republic of Turkey is a party, KVKK, secondary legislation issued based on the KVKK and the guides and principle decisions published by the Personal Data Protection Authority. behaves appropriately.

  1. Purposes of Processing Your Personal Data

Your personal data stated above are processed in accordance with the principles set out in Article 4 of the KVKK, within the scope and limited to the following purposes:

  1. Depending on the service contract; fulfillment of service obligations, fulfillment of employer responsibilities, execution of disciplinary processes, ensuring occupational safety, management, supervision and execution of work,
  2. Preparation of all records and documents that will be the basis for the transaction in electronic (internet/mobile etc.) or physical environment,
  3. Providing information to public officials on matters related to public security upon request and in accordance with the legislation,
  4. Fulfilling legal obligations and exercising rights arising from current legislation,
  5. To be able to fulfill the legal obligation if requested by the relevant authority within the scope of judicial and administrative investigations and if it is necessary to respond,
  6. Carrying out occupational health and safety activities,
  7. Carrying out assignment processes,
  8. Providing information to authorized persons, institutions and organizations,
  9. Carrying out emergency management processes,
  10. Organization and event management,
  11. Execution of information security processes,
  12. Carrying out storage and archive activities,
  13. Ensuring physical space security.

In this regard, the monitoring areas of security cameras, their number and when they will be monitored are implemented in a way that is sufficient to achieve the security goal and is limited to this purpose.

The person's privacy is not subject to monitoring in areas that may result in interference that exceeds security purposes (for example, dressing rooms, toilets, etc.).

  1. Storage Period of Personal Data Obtained through Camera Monitoring Activities

Personal data recorded will be kept in accordance with the law and will be kept for the maximum period and legal statute of limitations specified in the relevant legislation or required for the purpose for which they are processed. In our company, the storage period for personal data obtained with the camera is 30 days.

  1. Domestic or International Transfer of Your Personal Data

Personal data regarding camera systems, provided that adequate and effective measures are taken in accordance with the data transfer and processing conditions specified in Articles 8 and 9 of the Law and the security and confidentiality principles determined in the legislation in order to ensure the achievement of the above-mentioned purposes; can be transferred to legally authorized public institutions.

Except as stated above, your personal data is not transferred to any third party at home or abroad. If your personal data needs to be transferred to any third party other than the cases stated above, you will be informed separately.

  1. Your Rights as a Data Subject (Relevant Person) within the Scope of KVKK

Within the framework of KVKK and other relevant legislation in force:

  1. Learning whether your personal data is being processed or not;
  2. Request information if your personal data has been processed;
  • Learning the purpose of processing personal data and whether they are used for their intended purpose;
  1. Knowing the third parties to whom your personal data is transferred at home or abroad;
  2. Request correction of your personal data if it is incomplete or incorrectly processed;
  3. Request the deletion or destruction of your personal data within the framework of the conditions stipulated in the KVKK legislation;
  • v. and vi. To request that the transactions carried out within the scope of the articles be notified to third parties to whom your personal data has been transferred;
  • Object to the emergence of a result against you by analyzing the processed data exclusively through automatic systems;
  1. Requesting compensation for this damage if you suffer damage due to unlawful processing of personal data.

You have the rights.

  1. Exceptions to the Right to Apply

In accordance with the provision of Article 28/2 of the Law, you will not be able to benefit from your rights specified in Article 11 of the Law, except for the right to demand compensation for damages in the following cases.

  1. Processing personal data is necessary for the prevention of crime or criminal investigation,
  2. Processing of personal data made public by the data subject.

  1. Application Ways Within the Scope of Your Rights

You can make your applications regarding your rights listed above in accordance with the application procedures stipulated in the Communiqué on Application Procedures and Principles to the Data Controller. Your request to exercise your rights within the scope of KVKK, together with documents that will identify you;

  • If the application is made in person, the written application will be made to the address of our business, Adnan KAHVECİ Mahallesi, İNÖNÜ Caddesi, No:95 34528 BEYLİKDÜZÜ - ISTANBUL, by writing " Information Request Within the Scope of the Personal Data Protection Law " on the envelope.
  • If the application is made by sending a notification through a notary, the written application will be made to the address of our business, Adnan KAHVECİ Mahallesi, İNÖNÜ Caddesi, No:95 34528 BEYLİKDÜZÜ - ISTANBUL, by writing " Information Request Within the Scope of the Personal Data Protection Law " on the envelope.
  • If the application is made via Registered Electronic Mail (KEP) by signing with a secure electronic signature, the written application will be made to the e-mail account muya@hs03.kep.tr by writing " Personal Data Protection Law Information Request " in the subject section of the e-mail.