1. INTRODUCTION
Kirman Mülk Yatırım A.Ş. is committed to fulfilling all obligations regarding the processing, storage, protection, and disposal of personal data in accordance with the Turkish Personal Data Protection Law No. 6698 (“KVKK”). This policy explains the purposes and legal grounds for processing personal data, the rights of data subjects, and the measures taken to ensure data security.
2. PURPOSES OF PROCESSING PERSONAL DATA
Personal data collected is processed in accordance with Articles 5 and 6 of the KVKK for the following purposes:
Creating and managing records of employees and customers,
Conducting and auditing company operations,
Managing human resources processes,
Carrying out occupational health and safety procedures,
Fulfilling contractual obligations,
Complying with legal obligations and sharing information with official authorities,
Managing financial and accounting processes,
Conducting customer service and satisfaction activities,
Managing contractual processes under Labor Law and relevant legislation,
Exercising rights and fulfilling obligations arising from applicable laws,
Responding to judicial and administrative requests when legally required.
3. METHODS AND LEGAL GROUNDS FOR DATA COLLECTION
Personal data is collected verbally, in writing, or electronically via our website, e-mail, phone calls, social media platforms, and face-to-face meetings.
Legal grounds for processing personal data include:
Explicit consent of the data subject,
Situations explicitly stipulated by law,
Necessity for the establishment or performance of a contract,
Fulfillment of legal obligations,
Protection of legitimate interests.
4. STORAGE AND PROTECTION OF PERSONAL DATA
Kirman Mülk Yatırım A.Ş. takes all necessary technical and administrative measures to ensure data security, including:
Using security systems against unauthorized access, loss, or disclosure,
Performing regular data security audits,
Training employees on personal data protection.
Personal data is retained for the periods specified by applicable legislation and securely destroyed upon expiration of such periods.
5. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
Personal data may be shared, in compliance with KVKK and legal requirements, with:
Authorized public institutions and organizations,
Business partners and suppliers,
Legal advisors and competent authorities for the fulfillment of legal obligations.
Appropriate data security measures are taken during such transfers.
6. RIGHTS OF DATA SUBJECTS
Pursuant to Article 11 of KVKK, data subjects have the right to:
Learn whether personal data is processed,
Request information if processed,
Learn the purpose of processing and whether it is used accordingly,
Know third parties to whom data is transferred domestically or abroad,
Request correction of incomplete or inaccurate data,
Request deletion or destruction of personal data,
Object to adverse results arising from automated processing,
Claim compensation for damages arising from unlawful processing.
Requests may be submitted via info@kirmanmulk.com.tr
7. EXCEPTIONS TO THE RIGHT TO APPLY
Under Article 28/2 of KVKK, except for the right to claim compensation, data subjects may not exercise the rights set out in Article 11 in cases where:
Data processing is necessary for the prevention or investigation of crimes,
Personal data has been made public by the data subject.
8. UPDATES AND EFFECTIVE DATE
This policy may be updated by Kirman Mülk Yatırım A.Ş. when necessary and becomes effective upon publication on the company’s website.
FINAL NOTE
Kirman Mülk Yatırım A.Ş. processes personal data with the highest level of security and confidentiality. For any questions, please contact us at info@kirmanmulk.com.tr
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