Data Protection Law

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Data Protection Law

POLICY ON THE PROTECTION AND PROCESSING OF PERSONAL DATA
general
Lastmar Engineering and Shipping Foreign Trade. Ltd. Sti. (as “Lastmar Mühendislik” or “Company”), the purpose of our Personal Data Protection and Processing Policy is to comply with the Personal Data Protection Law (KVKK) No. is to be enlightening about its application in concrete terms.
Lastmar Engineering and Shipping Foreign Trade. Ltd. Sti. All necessary administrative and technical measures will be taken in terms of processing and protection of personal data in line with the principles set herein, a system will be established to raise awareness of employees, necessary information processes will be carried out for new employees, necessary notifications and warnings will be made.
Personal Information Processing
Lastmar Engineering and Shipping Foreign Trade. Ltd. Ltd. Şti. acts in accordance with the following principles in the processing of personal data in accordance with the Law on the Protection of Personal Data, especially the Constitution.
Personal information is only processed by the data processing officer in order to carry out the operations specified in the Constitution and the Law on the Protection of Personal Data No. 6698.
Personal information is processed for the purpose of carrying out the transactions specified in the contract with the information owners.
Personal data is processed in a convenient way in line with the determined purposes. Personal data is processed in accordance with all laws and regulations.
In the event of a change in the legislation, in cases where it is necessary to add personal information, a statement is made to the owner of the information.
Lastmar Engineering and Shipping Foreign Trade. Ltd. Şti., in accordance with Article 4 of the Law on the Protection of Personal Data No. 6698, carries out personal data processing activities in a limited and measured manner for accurate and up-to-date, specific, clear and legal purposes, in accordance with the law and honesty rules.
Lastmar Engineering and Shipping Foreign Trade. Ltd. Şti., in accordance with Articles 4 and 7 of the Law on the Protection of Personal Data No. 6698, retains the personal data it processes only for the period required by the relevant legislation and laws or required by the personal data processing purpose.
Lastmar Engineering and Shipping Foreign Trade. Ltd. Not every employee has access to all personal data held at Şti.

Accessing and Sharing Personal Information
Lastmar Engineering and Shipping Foreign Trade. Ltd. Sti. Personal information is shared in accordance with the Law on Protection of Personal Data No. 6698, in cases of necessity in the Constitution and laws.
Before personal information is shared, information such as the shared party’s authorization to access personal information, identity information is obtained and verified, and records about sharing are taken.
In cases of legal changes, such as the formation of new personal information sharing purposes, this situation is explained to the account holder.

 

In line with the legal and legal personal data processing purposes, it may transfer personal data to third parties based on one or more of the personal data processing conditions specified in Article 5 of the Personal Data Protection Law, and limitedly:
If the personal data owner has express consent,
If there is a clear regulation in the law regarding the transfer of personal data,
If it is necessary for the protection of the life or bodily integrity of the personal data owner or someone else, or if his consent has no legal validity,
If it is necessary to transfer the personal data of the parties to the contract, provided that it is directly related to the establishment or performance of a contract,
Lastmar Engineering and Shipping Foreign Trade. Ltd. Sti. if it is necessary for the fulfillment of its legal obligation,
If the personal data has been made public by the data owner,
If personal data transfer is necessary for the establishment, exercise or protection of a right, Lastmar Mühendislik ve Denizcilik Dış Tic. Ltd. Şti. for the legal interests of personal data transfer, Lastmar Mühendislik ve Denizcilik Dış Tic. Ltd. Sti. The information of who has access to personal information on the physical and information system and with what authority is kept in the personal information inventory. Authorized Lastmar Engineering personnel only access personal information within their authorization.

Definitions
Law No. 6698
Law on Protection of Personal Data No. 6698, dated March 24, 2016, published in the Official Gazette dated 7 April 2016 and numbered 29677
Open Consent
Consent on a particular subject, based on information and expressed with free will
Anonymization
Making personal data incapable of being associated with an identified or identifiable natural person in any way, even by matching with other data
Employee Candidate
Persons who do not have a service contract with Lastmar but apply for a job by sending a CV and other methods
Employee/Employees
Refers to the people employed by the Company
Employees, Shareholders and Officials of the Institutions We Cooperate With
Real persons, who are employees, shareholders and officials of institutions with which Lastmar has a commercial business relationship, such as business partners and suppliers
Personal Data
Personal Data Any information relating to an identified or identifiable natural person.
Processing of Personal Data
All kinds of transactions carried out on personal data
Board
Personal Data Protection Board
Organisation
Personal Data Protection Authority
Customer
Real persons who benefit from the products and services offered by Lastmar
Special Qualified Personal Data
Regarding race, ethnic origin, political thought, philosophical belief, religion, sect or other beliefs, dress, association, foundation or union membership, data on health or sexual life, criminal convictions and security measures, if they are committed, may cause victimization of those concerned. data and biometric and genetic data
Potential Customer
Real persons who show an interest in using the products and services offered by Lastmar, who have been evaluated in accordance with the commercial practices and honesty rules that may have this interest, or who have requested products and services
Company/Lastmar
Lastmar Engineering and Shipping Foreign Trade. Ltd. Sti.
Company Shareholder
Natural persons who are shareholders of Lastmar
Company official
Member of the Lastmar Board of Directors or other authorized natural persons
Third Party
Real persons, such as family members, guarantors, members of the press, whose personal data are processed by Lastmar to ensure the security of commercial transactions with the above-mentioned parties or to protect the rights of the aforementioned persons and to obtain benefits, and who are not included in other data owner categories.
Data Processor
The natural or legal person who processes personal data on behalf of the data controller based on the authority given by him.
Data Recording System
The registration system in which personal data is processed and structured according to certain criteria
Data Owner
Natural person whose personal data is processed
Data Controller
The natural or legal person responsible for the establishment and management of the data recording system that determines the purposes and means of processing personal data
Visitor
Natural persons visiting Lastmar campuses or the website

Data Categorization of Personal Data Processing Activities Conducted by Our Company
Within the scope of personal data processing activities carried out by our company; In line with the legitimate and lawful personal data processing purposes, personal data grouped according to the following categories are processed based on and limited to one or more of the personal data processing conditions specified in Articles 5 and 6 of the Law No. 6698.
Personal Data Categorization
Description
Credentials
All information regarding the identity of the person included in documents such as driver’s license, identity card, residence, passport, attorney’s ID, marriage certificate
Communication information
Information for contacting the data owner such as phone number, address, e-mail.
Location Data
Information that determines the location of the personal data owner while using our products and services or the employees of the institutions we cooperate with when using our Company’s vehicles.
Customer information
Information obtained and produced about the person concerned as a result of our commercial activities and the operations carried out by our business units in this context.
Family Members and Close Information
Information about the family members and relatives of the personal data owner, which is processed in order to protect the legal interests of the Company and the data owner, related to the products and services we offer.
Customer Transaction Information
Information such as records for the use of our products and services and the customer’s instructions and requests for the use of products and services
Physical Space Security Information
Personal data regarding records and documents such as camera records, fingerprint records taken during the entrance to the physical space, during the stay in the physical space
Transaction Security Information
It refers to the information used to ensure the security of physical and electronic transactions, including user names, passwords, log records. (such as IP address information, website login and exit information, password and password information)
Risk Management Information
In order to manage our commercial, technical and administrative risks, personal data processed through the methods used in accordance with the generally accepted legal, commercial practice and good faith in these areas
Financial Information
Personal data processed for information, documents and records showing all kinds of financial results created according to the type of legal relationship our company has established with the personal data owner
Employee Candidate Information
Personal data processed about individuals who have applied to be an employee of our company or who have been evaluated as an employee candidate in line with the human resources needs of our company in accordance with the rules of commercial practice and honesty, or who have a working relationship with our Company
Legal Process and Compliance Information
Personal data processed within the scope of determination, follow-up and performance of our legal receivables and rights and compliance with our legal obligations and company policies
Audit and Inspection Information
Personal data processed within the scope of our company’s legal obligations and compliance with company policies
Special Qualified Personal Data
Data on race, ethnic origin, political opinion, philosophical belief, religion, sect or other beliefs, disguise and clothing, membership in associations, foundations or unions, health, sexual life, criminal convictions and security measures, and biometric and genetic data are of special nature. is personal data.
Marketing Information
Personal data processed for the marketing of our products and services by customizing them in line with the usage habits, tastes and needs of the personal data owner, and the reports and evaluations created as a result of these processing results
Request/Complaint Management Information
Personal data regarding the receipt and evaluation of any request or complaint directed to our company
Reputation Management Information
Information about the information collected in order to protect the commercial reputation of our company, the evaluation reports prepared and the actions taken.
Incident Management Information
Personal data processed in order to take the necessary legal, technical and administrative measures against the developing events in order to protect the commercial rights and interests of our company and the rights and interests of our customers

Data Subject Categories
Data owners whose personal data are processed within the scope of this Policy; customer, potential customer, visitor, third party, employee candidate, company shareholder, company official, employees, shareholders and officials of the institutions we cooperate with.
Data Owner Categorization
Description
Customer
Real persons who benefit from the products and services offered by Lastmar
Potential Customer
Real persons who show an interest in using the products and services offered by Lastmar, who have been evaluated in accordance with the commercial practices and honesty rules that may have this interest, or who have requested products and services
Visitor
Natural persons visiting Lastmar campuses or the website
Third Party
Real persons, such as family members, guarantors, members of the press, whose personal data are processed by Lastmar in order to ensure the security of commercial transactions with the above-mentioned parties or to protect the rights of the aforementioned persons and to obtain benefits, and are not included in other categories of data subjects.
Employee/Employees
Refers to the people employed by the Company
Employee Candidate
Persons who do not have a service contract with Lastmar but apply for a job by sending a CV or other methods
Intern
Refers to people who are accepted to do internship at the Company or whose internship application is evaluated.
Requesters
Refers to the people who contact the Company and make a request by filling out the contact form on the Company’s website.
Company Shareholder
Natural persons who are shareholders of Lastmar
Company official
Member of the Lastmar Board of Directors or other authorized natural persons
Employees, Shareholders and Officials of the Institutions We Cooperate With
Real persons, who are employees, shareholders and officials of institutions with which Lastmar has a commercial business relationship, such as business partners and suppliers

Shared Party Categories
Within the general principles of the Law No. 6698 and the personal data processing conditions in Articles 8 and 9; Lastmar may transfer the personal data of data subjects to the following third parties within the scope described in the table:
Work partners
Suppliers R
itanus subsidiaries
Lastmar shareholders

Legally authorized public institutions
Legally authorized private institutions
Protection of Personal Information Owner’s Rights
According to the Personal Data Protection Law, personal information owners have the following rights:
To know for what purpose personal information is collected and used, To know with whom personal information can be shared,
Knowing who can access personal information, Knowing how to store personal information,
Knowing how long personal information will be kept, Knowing how to archive personal information, Knowing how to destroy personal information,
To know how to convey your request and complaint to Lastmar Engineering in this regard.
The rights of the personal information owner are explained when making the contract and obtaining express consent.
Complaints from personal information owners are evaluated and answered.
Processing of Internet Access Records of Data Subjects Benefiting from the Internet Connection Provided by the Company
Internet access can be provided to the visitors who request it at the campus and facilities of our company. Personal data is processed by our company by logging internet access records in order to ensure security and to fulfill the legal obligation arising from the Law No. 5651 as an access provider.
A limited number of employees have access to the access records kept in this framework in connection with the purpose of processing. The Company takes the necessary technical and administrative measures to ensure the security of internet access records. The movements of the data owners who visit the Lastmar website of our company are monitored by using cookies for purposes such as facilitating their shopping experience and carrying out marketing activities. The processing of personal data in this context is governed by the www.lastmar.com Website Privacy/Cookie Policy.
Processing Activities of Personal Data Carried out at Company Campuses and Facilities to Ensure Security
Our company in order to ensure legal, technical and commercial job security; Personal data is processed by means of capturing images with closed circuit camera system (CCTV) at company campuses and facilities, creating records at the entrances to company campuses and facilities, and keeping records of visitors’ internet access.
Image Acquisition with Closed Circuit Camera System (CCTV)
Lastmar carries out personal data processing by taking images with a closed circuit camera system within the scope of ensuring the physical security of company campuses or facilities, ensuring effective crisis management by intervening in case of incident, increasing the quality of the services offered by the Company and limited to the purposes listed in this Policy. In addition to informing the data owners and the public regarding the acquisition of images by CCTV with this Policy, a lighting note is used at the entrance of the areas where images are taken.
A limited number of employees have access to the records recorded and stored in the digital environment in connection with the purpose of processing. Camera images can be transferred to the subcontractor security firm and authorized public institutions in accordance with the legislation.

Administrative Measures
Training of employees on technical measures to prevent unlawful access to personal data,
Informing the employees that the personal data they have learned cannot be disclosed to others in violation of the provisions of the Law No. 6698 and used for purposes other than processing, and that this obligation will continue after they leave their job, and necessary commitments are taken from them in this direction,
Limiting access to personal data within the Company in accordance with business unit-based legal compliance requirements, taking into account the purposes of processing,
In case of transfer of personal data, adding records to the contracts concluded between the persons to whom the personal data is transferred and our Company, indicating that the party to which the personal data is transferred will fulfill its obligations to ensure data security.
Personal Information Collection
Personal information, Lastmar Mühendislik ve Denizcilik Dış Tic. Ltd. Sti. It is collected during the contract and job application with the Company and in accordance with the Law on Protection of Personal Data No. 6698.
Personal information only Lastmar Mühendislik ve Denizcilik Dış Tic. Ltd. Sti. may be collected by authorized persons appointed by the
Before personal information is collected, it is explained to the owners of personal information for what purpose the information is collected, in which transactions it will be used, with whom it will be shared, and where to apply for information about these issues. After the personal information owner approves this statement, he signs the application contract and his personal information is obtained.
Lastmar Mühendislik ve Denizcilik Dış Tic. Ltd. Sti. It is published on the website of.
The accuracy and timeliness of the personal information received is the responsibility of the personal information owner.
Due to changes in the law, if new information is received from personal information owners and additions to the purposes of use of personal information, this situation is explained to the information owner.