ASFAT ASKERİ FABRİKA VE TERSANE İŞLETME ANONİM ŞİRKETİ
PROTECTION AND PROCESSING OF PERSONAL DATA DISCLOSURE TEXT

This “Disclosure Text” has been published by ASFAT ASKERİ FABRİKA VE TERSANE İŞLETME ANONİM ŞİRKETİ (“ASFAT”) as the data controller in accordance with the Kişisel Verilerin Korunması Kanunu (Personal Data Protection Law) No. 6698 (‘KVKK’), to inform you on the method of collection, processing, use, transfer and disposal of your personal data.

          1. Data Controller

ASFAT is the “Data Controller” in accordance with the KVKK to process personal data and in accordance with the matters will be explained herein.

          2. Scope of the Personal Data and Cause of Action

We as ASFAT, acting as the data controller, hereby agree and declare that we would collect, compile, record, store, revise and update for the purpose of maintaining of our services, transfer to any third persons in or outside the country to the extent permitted by laws, and process by taking any required administrative and technical measures as per applicable laws, any personal data (forename, family name, address, profession, occupation, education, marital status, date and place of birth, curriculum vitae, electronic mail address, ID numbers, phone number, gender, vehicle license plate number, and any Internet access location data, IP address and onsite camera records) shared with us by using any automatic or non-automatic methods, upon your explicit consent, or in line with the Law 1325, Law 5201 on Control and Supervision of the Industrial Facilities Producing Warfare, Arm, Gun, Ammunition and Explosives, and the Ministry of National Defense Bylaws MSY 317-2 and as per our obligations arising from the related laws and regulations, including inter alia the Turkish Commercial Law 6102, KVKK, Labor Law 4857, Law of Obligations 6098, Turkish Criminal Code 5237, and Law 5651 prevailing to Regulation of Internet Publications and Crimes Committed by Such Publications,.

ASFAT may use and process such personal data upon your explicit consent or clear terms and provisions of the governing legislation or in case of need for establishing or carrying out a contract, or necessity of legitimate interest and/or fulfilling legal obligations, for any mandatory or appropriate legal purposes, provided that the same may not be used for any purpose other than those set forth under Disclosure Text. by taking any necessary actions for information security within the legal time limit for storage and maintenance, or as long as it is needed for the processing purposes, and at the end of the said legal time limit, they would be anonymized for continued use by us, or disposed in line with the Corporate Procedures according to the KVKK and related legislation.

As per KVKK, ASFAT takes care for the personal data to be processed:

  • fairly and lawfully;
  • accurately and kept updated if necessary;
  • for specified, explicit and legitimate purposes;
  • in conformity and limited with the purposes for which they are processed;
  • for no longer than necessary period for the purposes for which the data was processed or the time designated by relevant law,

  • and makes any necessary audits for such purposes. In this context, ASFAT pays utmost care, and takes any necessary technical, administrative and legal measures for the safety and protection of your personal data.

             
    3. Purpose of Personal Data Processing

    Your personal data will be processed in verbal, in writing or electronically as per Clauses 4, 5 and 6 for the following purposes:

    • Determining and implementing the business and trading strategies,
    • Ensuring the plant and staff safety,
    • Managing contracts, establishing legal transactions and monitoring legal processes,
    • Planning, controlling and implementation of the data security processes,
    • Monitoring any financing and/or accounting transactions,
    • Implementing our human resourcing processes and activities in accordance with the specified legal frame,
    • Building and management of the cyber security technologies substructure,
    • Carrying out the productivity and/or pertinence analyses for our business activities, planning and/or performing such activities,
    • Establishing and preserving intellectual property rights of ASFAT,
    • Ensuring ASFAT to perfectly fulfill its contractual and legal liabilities,
    • Evaluating and responding any proposals, requests, complaints and failure notices to be sent to ASFAT by you through our website, and taking any necessary actions for improvement in line with the notices and feedbacks of you.

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                4. Transferring Personal Data to Third Persons

      The Company may transfer to, or share such data and information with any direct/indirect/inland/abroad affiliates, participations as well as any legal entity or natural person business partners, suppliers, contractors, subcontractors, shareholders, legal, financial and tax consultants, auditors, audit companies or any public entities or competent authorities and other related persons, entities or corporations within the framework of the personal data processing conditions and purposes set forth in Clauses 8 and 9 of KVKK for and in connection with safety and confidentiality rules, upon explicit consent of the involved persons, and based on clear terms and provisions of the governing legislation, and in mandatory cases for contract conclusion and implementation, and for fulfilment of any legal liability and obligations or legal rights and interests, and any necessary measures are taken within the safety and security rules set forth in KVKK.

                5. Your Rights under KVKK

      Without prejudice to the provisions set out in Clause 28 “Exceptions” of KVKK, you as the personal data owners have the following rights as per Clause 11 of KVKK:

      a.  Learning if your personal data are processed or not,
      b.  Requesting information on any possible processing of your personal data,
      c.  Learning the purpose of processing of your personal data, and if your personal data are used in compliance with the declared purpose or not,
      d.  Knowing the third persons to whom your personal data are transferred inland or abroad,
      e.  Requesting any deficiently or wrongly processed personal data to be reviewed and corrected,
      f.  Requesting your personal data to be deleted or destroyed as per Clause 7 of KVKK,
      g.  Requesting for the third party receivers of your personal data to be made aware of the actions taken as per the above paragraphs (e) and (f),
      h.  Raising objection against any result or consequence against you as a result of the exclusive analyzing of personal data by means of automatic systems, and
      i.  Claiming compensation of your losses and damages to arise out of illegal processing of your personal data in contradistinction to the governing legislation.

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      It is important for you to use your rights hereunder; the information/data shared by you with ASFAT shall be correct and accurate, and properly transferred to ASFAT. Any liability to arise out of giving deficient or defective information or data belongs to the party who transfers the same to ASFAT.

      Any requests and claims in this context would likely be submitted in writing, with the secure electronic signature or mobile signature or via the electronic mail address already notified by you to ASFAT, and recorded in our systems within the framework of KVKK. For this purpose, you may apply online with your full name, signature, Turkish national identity number, settlement address or office address, and if applicable, electronic mail address, phone or fax numbers by means of the application form available in our corporate portal (asfat@hs01.kep.tr), or directly to the physical address of headquarters, i.e. “Mustafa Kemal Neigh. Dumlupınar Boulv. No:252 TOBB Towers Blok C Floor:21-22-23 Çankaya, Ankara, TURKEY, or send your application via a notary public, or post it through the official electronic mail address info@asfat.com.tr

      ASFAT will be free of charge to conclude any application within the legal time allowance for 30 days. In cases where a cost estimation is needed to fulfil your requests, ASFAT reserves its right to claim a fee 1 TL for per page of hardcopy responses exceeding 10 pages, and the actual cost of recording media as CD, flash memory stick etc used to fulfil your request.

      ASFAT reserves the right to make changes to this Disclosure Text due to changes in the Law and new methods or regulations that may be determined by the Personal Data Protection Board.

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